Radio Teleswitch Service: Minister for Climate Action letter to Ofgem

To: Jonathan Brearley, Chief Executive, Ofgem

From: Alasdair Allan MSP, Acting Minister for Climate Action 

10 March 2025

Dear Jonathan,

I wrote to the UK Government in January, copying Ofgem, to urge more action to protect consumers as a result of the Radio Teleswitch Service (RTS) switch-off. Protecting consumers remains the Scottish Government’s highest priority in this matter; however, feedback from consumer organisations and members of the public continues to suggest to me that the approach taken so far has been insufficient, and consumers cannot be blamed for the failure of the energy industry to properly plan for and respond to the RTS switch-off.

As your consultation rightly states, people who rely on the RTS will experience considerable detriment unless meters are replaced by the switch-off date – particularly in rural and island communities. This makes the timely replacement of RTS meters essential. I made it clear in my letter to Minister Fahnbulleh in January that there should be penalties for suppliers who fail to replace RTS with smart meters (whether fully functional or pre-programmed) by June this year. I am pleased that, by updating license conditions, Ofgem will be able to take appropriate compliance action against suppliers who fail to do so.

The consultation suggests that changing the regulations to prohibit the supply of electricity to RTS consumers through a metering arrangement which relies on the RTS infrastructure will protect consumers and reduce detriment. It also states that RTS meters should be immediately phased out of the electricity market and associated infrastructure.

While I understand that this is an important regulatory change to allow enforcement action to be taken following the switch-off, I have two concerns regarding its implementation. Firstly, that it may in practice see some consumers removed from supply and properties de-energised, and secondly, that it may see some suppliers offering imperfect metering solutions solely to avoid a breach of license conditions.

I understand from my officials that Ofgem does not expect consumers to be removed from supply as a result of these changes, however I feel duty bound to put on record how dangerous such a situation would be, with large scale contingency planning needed now to prevent serious harm to individuals. Safeguards and protections must be put in place. For example, where a supplier does not have the capacity or capability to upgrade a meter, consideration must be given to proactively offering a change of supplier to any affected consumers. Consumers cannot be left with no support and many are trying, with no success, to arrange a meter upgrade. The energy industry must ensure those consumers do not suffer any detriment either before or after the RTS switch-off.

While not included in the published consultation, the Scottish Government continues to believe that there should be penalties applied to the DCC for failing to deliver smart-meter coverage across every part of the country. While 99.3% of the UK is covered by the smart meter communications network, this coverage does not yet apply to some rural and island parts of Scotland, England and Wales.

I understand from Minister Fahnbulleh’s response that the DCC is currently undertaking work to develop technical solutions to overcome the connectivity issues that currently prevent some consumers from accessing the WAN. A solution must be put in place as a matter of urgency. I believe an update to the DCC license conditions would provide enduring protection to consumers given the pace at which technical solutions are likely to change and the potential for meters to become unfit for purpose through no fault of the consumer.

I was pleased to note that the proposed update ensures suppliers must take all reasonable steps to provide a tariff that leaves the consumer ‘no worse off’ than their existing arrangements as a result of a RTS meter replacement. However, this issue only arises post-meter upgrade whereas many still wait for engineers who never turn up or are insufficiently trained to upgrade the meter in question. I continue to believe that there is a real and pressing need for suppliers to be made to explain what their workforce plan is in terms of actually getting engineers to premises. Consideration should be given to additional enforcement action designed to reduce no-show instances and to ensure that every household is fitted with a fully functioning meter before the deadline.

Separately, and while understandably not for the license conditions to cover, it is unacceptable to expect consumers to pay for expensive re-wiring as a consequence of the RTS switch-off. As you know well, too many consumers are already in energy and other consumer debt due to the cost of living crisis – they should not be confronted with any additional anxieties. The creation of a fund to support consumers in this position is critical. If households are to be upgraded in time, and with no financial detriment, then progress on such a fund is needed urgently.

Finally, I want to repeat my assurance that the Scottish Government remains on hand to work with Ofgem, the UK Government, and industry to raise awareness of the RTS switch-off. However, devolved governments do not hold the levers to make a difference in this area, and policy power reservations mean the people of Scotland must rely on decisions taken by Ofgem and the UK Government.

I hope that these license changes are sufficient to substantially increase the number of properties upgraded, particularly in rural and island areas where the number of RTS meters is disproportionate and where the impact on already high levels of fuel poverty could be significant. However, frankly, I am not convinced that some suppliers will see the prospect of no longer having to deal with the most remote or complex cases as a spur to action to assist them.

Yours sincerely,

Alasdair Allan