Ofgem consultation response

Scottish Fuel Poverty Advisory Panel response to Ofgem’s consultation on Radio Teleswitch Service (RTS) Electricity Supply Licence changes

Ofgem RTS Consultation – SFPAP Final Response.pdf

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While the proposals include a time limit on how long a receiving supplier has to change a new customers meter, it is unclear how long a supplier has to change an existing customers meter post-switch off. There is also a lack of clarity on what sanctions apply for suppliers who do not change meters within the timeframes. The Panel is clear that effective sanctions and accountability is vital to avoiding detriment to those with RTS meters.

The Panel recommend that there should be an obligation on any supplier accepting switches to clearly understand what they are dealing with and have demonstrated that they can meet the 30-day requirement.

Furthermore, in order to avoid detriment, we would recommend that there is a cap set by Ofgem for customers who previously were supplied through an RTS meters that is calculated on the basis of known use patterns, similar to that in place for Economy 7 meters.

The Panel has heard about the difficulties consumers face in having meters changed. This is sometimes because rewiring of supply points is needed to make a property eligible for a smart meter, a cost which needs to be borne by the household or landlord. In many cases, however, customers face difficulties in accessing engineers, especially when they live in very remote and island areas. The Panel recommends that an industry taskforce considers this issue as a matter of urgency, including the potential for energy suppliers to share engineers. We are aware that this option was discussed in a meeting with the Scottish Government’s Acting Minister for Climate Action, with a number of energy suppliers present supporting it in principle.

Post-RTS meter replacement, it is essential that suppliers effectively identify material changes in a household’s consumption in order for them to take action to avoid consumer detriment. Building on this, if energy advice organisations will be required to provide support to customers’ whose electricity is left permanently on or off they should be funded to do this, as they are already facing significant demand associated with energy debt and the cost of living crisis.

The Panel has heard from stakeholders that there is a need for a single point of contact within energy suppliers for RTS customers. Some consumers report being passed from team to team in order to receive support. This further complicates an already complex issue. We have heard of previous examples where specialist teams with detailed levels of skills and competencies were in place to support households with complex metering, and we see the consumer benefits that this can deliver.

Finally, it is important to understand that there are several issues that have led to the present situation. It is critical that Ofgem and energy suppliers do not appear to blame customers for not engaging in the run up to the RTS switch off. As we move towards net zero it is important that new relationships are established between customers and suppliers, where any sense of blame can very much destroy that.

The Panel would like to engage with Ofgem once you have considered the evidence from this consultation. We would be happy to do this either with you directly, Charlotte, or as part of a wider stakeholder group.

Yours sincerely,


Matt Cole
Chair, Scottish Fuel Poverty Advisory Panel
7th Floor
Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU

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