Jonathan Brearley
Chief Executive Officer
Ofgem
10 South Colonnade
Canary Wharf
London
E14 4PU
28th May 2025
Dear Jonathan,
Radio Teleswitch (RTS) Phase Out – Contingency Planning
I hope you are well.
Further to my question at the Ofgem CEOs Roundtable meeting last week, I am writing to seek assurance on the actions being taken by Ofgem to ensure that RTS Meter Consumers will continue to be appropriately protected following the commencement of the gradual switch-off of the RTS signal on 30th June 2025.
Consumer Scotland understands that, as of 18th April approximately 132,000 households in Scotland continued to receive their electricity supply through an RTS Meter. I know that you will share our concern that this figure remains so high considering the time suppliers have had prior to now to switch consumers’ meters.
We are aware that Ofgem continues to work closely with suppliers to ensure that as many consumers as possible will have had their RTS Meter replaced by the end of June. It is important that Ofgem uses its full regulatory toolkit in support of this goal. This includes action to ensure that consumers across Scotland, including those in rural, remote and island communities, are able to access an appropriate and timely appointment for the replacement of their RTS Meter. Given the geographical spread of these customers, we recognise that there may be a different set of challenges in replacing meters at pace. We would support a decision by Ofgem to allow and encourage suppliers to pool resources in order to speed up meter replacements. We also consider action is needed to ensure that consumers are not exposed to incidental costs, such as the cost of any rewiring which may be associated with RTS Meter replacement.
While we are encouraged that RTS Meter replacement run rates are improving, there remains a significant risk that not all RTS Meter Consumers will receive a meter upgrade by the time the relevant RTS Group Code broadcasts end. In these circumstances, it will be essential for suppliers and Ofgem to have clear and robust plans in place to mitigate the risk to RTS meter consumers of a potential loss of heating and hot water following the switch off given the consumer harm this would present, and the risk to security of supply arising from significant ‘clock drift’ (where RTS meters may be able to continue switching rates, but their internal clocks gradually drift out of alignment as they no longer receive updates).
To that end, I would be grateful for any reassurance you are able to offer on the steps that are being taken to ensure that effective plans are in place, including on the following points:
a) Risk-based phase out approach: We understand that the phased approach to RTS switch-off between June and September will be delivered using a risk-based model. We assume that this means that those areas of the country, such as northern Scotland, where a high number of RTS meters are still in use, will not be switched off until near the end of the phase out period to ensure consumers in these regions are not negatively impacted. However, it would be beneficial for consumers and stakeholders for Ofgem to publish further details on the approach that it is being taken, including the planned switch off dates in different regions across GB and the criteria and modelling work that is being used to determine which areas will be switched off when.
b) Action in event of a power interruption: A loss of power following the end of the relevant RTS Group Code broadcasts is likely to expose consumers to additional risk of adverse outcomes. Some RTS meters are unable to recall switching instructions from memory upon the restoration of power to an RTS meter customer’s premises, following a power interruption which occurs after the cessation of relevant RTS Group Code broadcasts. For others an outage could mean the RTS meter’s internal clock is then significantly off, which could manifest as cost and comfort issues for affected RTS meter Consumers and, in exceptional circumstances, could threaten wider security of supply.
It is important that suppliers and DNOs work together to respond to this risk appropriately. A consolidated list of power interruptions issued daily to suppliers could aid the sector’s ability to take proactive action to identify and remedy RTS meter issues following a loss of supply, before significant detriment occurs.
i) What plans does Ofgem expect suppliers and DNOs to have in place to allow swift and proactive action to be taken to support RTS Meter consumers in the event of an interruption to supply following the cessation of relevant RTS Group Code broadcasts?
ii) What action has Ofgem taken to assure itself of the robustness of supplier and DNO plans on this matter?
c) Action in the event of a partial loss of supply: The Electricity and Gas (Standards of Performance) (Suppliers) Regulations 2015 currently require suppliers to respond within 3 hours on a working day (and within 4 hours on a non-working day) when a consumer reports that a prepayment meter is no longer “operating so as to permit a supply of gas or electricity to be given to a customer’s premises in the manner for which that prepayment meter was designed”, where the issue is reported during working hours. Suppliers must issue a statutory payment to customers where these requirements are not met, and must report on their performance quarterly. There is however no equivalent provision for credit meter customers. For RTS meter consumers this presents an inconsistency, in that a partial loss of supply (i.e. through the loss of schedulable heating and/or hot water provision) following the cessation of relevant RTS Group Code broadcasts would appear to engage the Guaranteed Standard for affected prepayment RTS meter consumers, but no such protections are provided for credit RTS meter consumers.
As a principle of consumer fairness, the experience of credit RTS meter consumers under a partial loss of supply following the cessation of the relevant RTS Group Code broadcasts is no different to the experience of a prepayment RTS meter consumer faced with the same restriction to RTS Meter functionality under identical circumstances. At present, however, there is little to give assurance that suppliers will be under any obligation or expectation to respond in a timely manner to reports by a credit RTS meter consumer of a partial loss of supply.
(i) What specific actions does Ofgem expect suppliers to take to restore access to schedulable heating and hot water to RTS meter consumers following a reported partial loss of supply?
(ii) To what timeframes does Ofgem expect suppliers to meet these expectations, and what remedies does Ofgem consider appropriate if suppliers are unable to meet these?
(iii) What action has Ofgem taken to assure itself of the robustness of suppliers’ plans?
d) Support for consumers in vulnerable circumstances: Many consumers in vulnerable circumstances, including but not limited to those with high essential energy expenditure, have enhanced heating needs. These consumers are at additional risk of harm should their access to a reliable source of space heating and/or hot water be removed, or the nature of their tariff arrangements change significantly as a consequence of the switch-off of the RTS signal (for example, where the continuance of ‘heat with rent’ arrangements for consumers in sheltered or very sheltered housing is precluded by the replacement metering infrastructure specified by suppliers and/or their representatives). It is important that suppliers have robust plans in place to meet the additional needs of these consumers, and that delivery against these plans is appropriately monitored.
(i) What actions does Ofgem expect suppliers to take to ensure that RTS meter consumers on the Priority Services Register (PSR) are appropriately supported?
(ii) What action has Ofgem taken to assure itself of the robustness of suppliers’ plans on this matter?
Consumer Scotland has been pleased to contribute to the regular stakeholder meetings that Ofgem has convened in recent months on the RTS phase out programme. We will continue to be an active participant in these meetings, in the run up to 30th June and beyond.
If you require any further information regarding any of the queries set out in this letter, please do not hesitate to let me know. Otherwise, I look forward to hearing from you timeously on the matters set out above.
Best wishes,
Sam Ghibaldan