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Confidential:
No
Yes
(A)
Do the CEER 2012 recommendations need to be updated and if so, how?
1.
CTs reliability and customer confidence
Do you think that different or further recommendations are needed in order to promote overall CTs reliability and customers’ confidence in those tools?
What should those recommendations focus on?
What elements are considered by commercial CTs as obstacles to their participation in a regulated verification scheme?
How could these obstacles be removed while preserving customers’ interests?
In which terms do you think CTs should manage the information submitted by customers?
Comparison Tools play a key role in the energy market. CT can help consumers to understand energy offers, to be active players and to build confidence in the market. At the same time CT can force suppliers to do more pedagogy with customers to explain the details of the offers, and develop more customer oriented offers and products. In that sense, we agree to consider essential to guarantee that CT offer clear, fair, comprehensive, neutral and verifiable information to customers. The main risk for the CT is related to unappropriated use of CT linked with commercial objectives that can distort or favor some offers over others. We believe CTs’ purpose in energy sector must be different than CTs in other sectors. In that sense, we consider that CTs should only provide a complete set of information to compare and choice the most appropriate offer. It is crucial to avoid that CTs implemented attract customers to switch immediately through them. For this reason it would be advisable to develop some control or accreditation system for CT in order to ensure the compliance of the principles of neutrality, information and transparency. 1.- Reliability and customer confidence We don’t think it’s necessary to develop other or further recommendations for CT. We consider that CT owners should be free to develop their tools. The contents and information available on CTs can be reviewed by NRAs or Customer protection Authorities who can take decisions if they consider that information is unappropriated or induces to mistakes. An accreditation for CTs (renewable every year or two years) could be useful to guarantee customer confidence and to ensure that commercial CTs.
Confidential:
No
Yes
2.
Scope and usability of the tool
Do the GGP recommendations related to the scope and structure of the information provided by CTs need to be enhanced, or cover additional issues?
Should the stance in recommendation 4 that CTs should ideally show an exhaustive picture be reconsidered?
Does this stance remain relevant to both commercial and non-commercial CTs?
Should additional recommendations specifically address the comparison of customers’ current contract with available offers, and in what terms?
How could this be done without a much bigger data management load on customers, energy suppliers and CT operators?
The GGP includes enough recommendations and criteria to guarantee that CTs provide consistent, relevant and transparent information with impartiality.
Confidential:
No
Yes
3.
Clarity and comprehensibility of price and non-price information
Do the recommendations need to be modified in order to ensure that CTs offer clear, comprehensible and verifiable information to customers?
What aspects of information should they address?
How should information about elements other than price be presented in CTs in order to allow customers a valuable comparison based on their preferences, and to avoid that information overload results in less transparency?
Do you think that the GGP should address how users’ reviews or other subjective ratings should be reported in CTs (which offer this information) and, in that case, what principles should be considered?
CT’s owners should be free to decide on the design of their CTs and how information is presented. Nevertheless CTs should not only compare prices before taxes. It is necessary also to add the taxes and help customers to distinguish the different components of the prices. Beyond a comparison of prices without taxes, CT should enable people to do a simulation regarding their consumptions, so that the CT perfectly reflects what would be the final bill. The simulation should be based on this type of operation : [(consumption x price without taxe) + subscription charge]. It should also take into consideration an average volume of consumption according to the specificities of the house. Indeed, sometimes, the price per kWh can be very low, but the subscription charge quite high, and induce people wrong. CT’s should take into account vulnerable customers. Special warnings for these customers (or specific offers) should be underlined in order to avoid they switch and contract unsuitable conditions.
Confidential:
No
Yes
4.
Customer involvement and activation
Should the GGP include additional recommendations aimed at removing obstacles in the use of CTs by particular groups of customers, or at improving inactive customers’ involvement?
Do you have any specific recommendations on consumer data disclosure related to CTs that should be implemented?
What actions could be taken by different stakeholders (including NRAs) in order to encourage a wider number of customers to use CTs?
Stakeholders (basically NRAs and consumer organizations) can take promotion campaigns to inform and encourage customers to compare offers.
Confidential:
No
Yes
(B)
What developments in different fields (technology, retail markets…) may make further updating of the GGP necessary in the future?
5.
Smart meters and innovative tariffs
Due to the expected development of more complex indexed or dynamic electricity tariffs, do you think that there is a need for CTs to compare the final costs resulting from different price structures and indexes?
In your opinion, what is the best way for a CT to compare different tariff structures and provide customers with the most accurate comparison?
To help customers with indexed or dynamic tariffs, it can be useful to provide customers with (1) historical information regarding the main ratios: as the yearly total cost (or unit kWh price) they would have obtained if they had contracted the same tariffs in previous years and (2) future expectations on energy prices at short/medium or long term.
Confidential:
No
Yes
6.
Data management
What is the best way to provide customers with all relevant information in CTs?
Do you think an initiative that pursues the standardisation and easy access of the customer’s information (like QR codes, Green Button or similar) will be helpful in order to empower and activate energy customers?
In that case, should this standardisation be done at national or at European level?
There isn’t a better way to provide information. We consider that it should be helpful to agree on some minimum ratios to compare offers, products and CTs. In that case it would be more interesting to have the same ratios at European level.
Confidential:
No
Yes
7.
Demand side response
Do you think that future developments could raise the need to include demand side response in CTs?
If so, what is the best way to include demand side response offers on existing CTs? (If possible, please provide examples.)
We consider that a CT is different to an assessment on other energy matters as demand side response, energy efficiency, etc..
Confidential:
No
Yes
8.
Prosumers
Do you think that there is a need to include the market of self-generated electricity and offers for prosumers in the CT? (If possible, please provide examples of current offers in your market.)
How should offers addressed to potential prosumers (e.g. offers including products or services related to the installation of a generation equipment) be managed by CTs, and help customers to valuably assess the opportunity to become a prosumer?
We consider that a CT is different to an assessment on other energy matters as self-generation.
Confidential:
No
Yes
9.
Services added to energy contracts
Do you think that future services added to energy contracts would change the way CTs work and should this be addressed in the GGP?
In this regard, which services will be most relevant, and what will not be suitable for presentation in CTs?
How should CTs present multiple services bundled with energy supply in a way that consumers can make informed decisions?
How do you think that CTs could help customers in assessing the price elements of services that are bundled into an offer?
Information on services added to offers is essential for consumers (on price and details of the services). CTs should also provide information related with termination fees and the specific time validity of each offer. CT owners should be free to decide the best way to provide with this information.
Confidential:
No
Yes
10.
Access at the CT by mobile devices / apps
Do you think CTs have to be compatible with mobile devices in order to foster their use?
Do you think that the different level of information and functionalities that apps or mobile versions of CTs can offer with respect to web-based CTs will have to be specifically addressed by the GGP?
What aspects and principles should be considered?
1) Of course. 2) No.
Confidential:
No
Yes
11.
Collective switching
Are collective switching initiatives and CTs compatible?
Or do you think they are competitors?
Can we envisage a possible role of CTs in promoting consumers awareness of collective switching opportunities?
Should a future GGP review include collective switching issues?
Collective switching can help to boost the market. However, the calls for tenders and the following must respect the rules. This could also be done under the control of an organization.
Confidential:
No
Yes
12.
CTs providing overview of different CTs (meta-CTs)
Do you think web services comparing the results of different CTs will be developed in the energy sector?
What specific recommendations will they require from a customer perspective?
Yes. In fact it would be provide a wider over-view on the market and the different available CTs. We don’t think it’s necessary to develop specific recommendations for that subject.
Confidential:
No
Yes
13.
Other topics
Do you have any other ideas or suggestion that could be interesting to analyse about the topics that CTs will face in the future?
Confidential:
No
Yes
Thank you for participating in the public consultation!
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