ESMIG welcomes ERGEG’s guidelines of Good Practice on Regulatory Aspects of Smart Metering for Electricity and Gas and appreciates the opportunity to present industry’s views during the consultation process on ERGEG’s recommendations (http://www.energy-regulators.eu). ESMIG has not commented on all recommendations, but mainly those which were highlighted by ERGEG (recommendations 4 and 20 as well as 13) and those where ESMIG felt it was appropriate to contribute further information and/or where comments seemed to be necessary to clarify the issue better.
In general all ERGEG recommendations are relevant when implementing Smart Metering solutions in the EU Member States, probably to various degrees and with slightly different interpretations. In relation to recommendation 14, the section on costs and benefits analysis (CBA), ESMIG would like to point out that ERGEG correctly lists most of the expected benefits for the different stakeholders and highlights the crucial parameter for any CBA, namely the “extensive value chain” to be used. However, it was felt that the section falls short when addressing the expected costs for such a roll-out and how they should or could be shared among stakeholders. The main priority should be to start deployment of Smart Metering technology as soon as possible. Smart Metering is the foundation of and an essential first step towards the development of the smart grid, and the technology is available right now.
If we wait until 2020 for 80% of European consumers to be equipped with Smart Metering, and until 2022 for 100% coverage, we have no chance of achieving the “20-20-20 targets”. All three of these targets depend on the grid for their realisation, and the gateway to the grid from the final consumer/prosumer is the metering system. Therefore, meeting the 2020 goals depends on a quick deployment of Smart Metering technology, which can then be built upon to develop the smart grid.
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