Customer Protections and Smart Meters – Issues for Queensland
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Monitor the customer’s compliance with the plan.
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Have in place fair and reasonable procedures to address payment difficulties a customer may face while on the plan.
Part 3 of the NERR contains the rules in regards to the ‘Customer Hardship Regime’ and unlike the Queensland Electricity Industry Code the NERR contains this notion that a customer has to be classified as a hardship customer by the retailer in order to receive basic assistance such as a payment plan. The concept that a customer has to be classified as a hardship customer by the retailer in order to receive basic assistance such as a payment plan is ill conceived and may increase the occurrence of temporary hardship cases significantly. Payment plans must be universally available to all customers in need of one. Payment plans provide customers with a tool to manage price shocks and as discussed in Section 4 below, SMI enabled dynamic pricing structures have the potential to bring about substantial price shocks to Queensland households. Recommendation 16:
That NER Rule 302 and Rule 222 (1) and (3) are amended to ensure that all customers have easy access to affordable payment plans. 2.7 Meter reads and data 2.7.1 Meter readings
When a meter can be read remotely a retailer should always base a customer’s bill on a reading of the meter. Currently the Electricity Industry Code (Clause 4.10.1 (b)) and the NER Rule 210 only require retailers to use the best endeavour to read the meter at least once every 12 months. The remote read functionality delivers one of the most significant customer service improvements associated with SMI as it abolishes the need for estimates and associated problems with over- and undercharging. It is therefore essential that the practice of issuing bills based on estimates be abolished in a SMI environment. Recommendation 17:
That the SMI Part of the NERR includes a meter reading provision stipulating that a bill cannot be based on estimates. 2.7.2 Substituted data
The SMI Part of the NERR should also address the use of substituted data. Smart meter systems will create some new challenges in regards to the use of substituted data, as the use of small amounts of substituted data may occur more frequently. The basic principle that should apply is that the customer is informed about the use of substituted data. However, there is legitimate concern about the number of customers that will contact their retailer to query the use of substituted data. Simultaneously, where substituted data applies to Critical Peak Pricing (CPP) times they may make a material difference to the energy costs and therefore become more detectable amongst customers. In order to ensure that customers can be confident that they pay for the right amount of energy consumed, it would be ill advised to not inform customers about data substitution.
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