Dear Coroner,

I am writing in response to the Prevention of Future Deaths Report which you sent me in my capacity as the CEO of Energy UK following the accidental death of Bernadette Grace Faulkner in December 2022. I was deeply saddened by the news of this case, and on behalf of my colleagues at Energy UK and all our members I want to express my heartfelt condolences to Mrs. Faulkner’s friends and family. I thank the Coroner for bringing the case to my attention.

Energy UK has taken the duty conferred by this report extremely seriously. Our members deliver nearly 80% of the UK’s power generation and over 95% of the energy supply for the 28 million UK homes and many businesses. I am confident that the industry supports this response and will work with the Government and the regulator to take appropriate action.

It is important to note that Energy UK does not represent all the energy network companies, which also have an important role in metering arrangements. We can put the Coroner in touch with appropriate colleagues at the Energy Networks Association, should you feel that this would be helpful or necessary. We have however, reflected the relevant issues in terms of grid connections and metering in our note.

Firstly, we would like to be clear that any customer who is concerned about the safety of their meter placement should contact their energy supplier immediately. Their supplier will be able to offer support, whether that is through moving the meter where possible, replacing the meter with smart technology, or sending staff to the property to manually read the meter. The energy company will also consider whether a prepayment meter (PPM) is in fact the right payment method for the customer, and if appropriate will discuss alternative options that would require less frequent physical access to the meter. As directed by the Coroner, our focus in this response is on identifying and taking action to reduce the risk associated with historic meter placements and help to prevent similar deaths in the future. We are confident that the existing extensive regulatory framework, overseen by Ofgem, should ensure today no supplier is installing new legacy prepayment meters at height. This is something we have been reassured of by our members.

However, we recognise that the rules around metering have developed over time, as the market and technology have also evolved. In many cases meter locations will have been determined when a meter was first installed, potentially decades ago, meaning there will be historic incidents of legacy meters installed at heights. Addressing this population must therefore be our priority.

We note, however, that meter siting is a complex matter involving several parties. While meters themselves are operated by energy suppliers, most are situated within private property (suppliers, therefore, in most situations require customer permission to access) and the connections to the grid, which define where meters are located, are determined and owned by network operators. Alongside the placement of a meter, safety then also depends on a combination of the type of meter, the payment method, the characteristics of the customer and any support they may require. These factors mean that action and co- ordination across a broad range of stakeholders is necessary to address historic incidents of traditional prepayment meters that are situated at height. We have, however, identified the following meaningful actions that we will take forward that we believe should, over time, substantially reduce historic risks, having convened our members and other stakeholders, where this was possible, to discuss what more could be done:
• Action 1. Raise customer awareness of safety issues. Energy UK will work with consumer groups, including Citizens Advice (the statutory energy advocate) and Smart Energy GB (the communications body for the smart meter rollout) to further promote the existing guidance for customers on meter safety and emphasise the importance of customers contacting their suppliers if they have concerns. This will also explain the support that is available.
• Action 2: Improve support for vulnerable customers with their energy meters. Energy UK will convene workshops with energy suppliers and other stakeholders (including energy networks, Ofgem, the Government, the housing sector and customer groups) to examine the current customer journey, and gain a better understanding of how to:
- identify customers who need support;
- deliver safety focused interventions; and
- improve data sharing to further support the identification of vulnerable customers. We will also continue to work with stakeholders to improve how we can share data about customers in vulnerable circumstances, to help target support and improve safety.

• Action 3: Accelerate the transition from legacy meters to smart meters. Smart meters offer significant scope to reduce many of the safety risks associated with inaccessible meter placement. They can greatly reduce the physical interaction a customer has with their meter. We will continue to work with Government and Ofgem to ensure that the smart meter programme is delivered, and that we have the right policy framework to ensure continued progress on replacing legacy meters, particularly traditional PPM meters. This could involve working with Smart Energy GB, Ofgem, Government and others to consider ways to ensure social housing and privately rented properties are not left behind in the transition to smart. Having now explored this issue in some depth with our energy supplier members, I am confident that we are committed to acting on this and can make progress on improving outcomes for customers. However, this is very much dependent on close working and ambition from a range of other stakeholders involved in metering processes and standards, such as the energy networks, some of whom have a (or the most significant) role in determining the placement of a meter.

We will continue to work with Ofgem, the Department for Energy and Security and Net Zero, the Department for Levelling Up, Housing and Communities, and with colleagues from charities and consumers groups to reduce this risk in the future. We would be very happy to share more information with the Coroner, or to make introductions to other stakeholders if required. I would welcome any questions and would of course be happy to discuss our response with the Coroner.

Lastly, I would like to again reiterate my sincere sympathy for the loved ones of Mrs Faulkner – of course we will do what we can, working with our colleagues who share the responsibilities around metering, to prevent any future tragedies.

Dear Ian,

I am writing to respond to the Prevention of Future Deaths report issued in relation to the death of Ms Bernadette Faulkner. You sent this report to the Minister of State for Housing, Planning and Building Safety, and it has been passed from the Department for Levelling Up, Housing & Communities to the Department for Energy Security & Net Zero for response.

This is a deeply tragic and heartbreaking case, that the Department and I take very seriously. I was very saddened to hear about Ms Faulkner’s death and would like to express my personal condolences to Ms Faulkner’s family.

The independent regulator, The Office of Gas and Electricity Markets (Ofgem), is responsible for the regulation of energy suppliers and protecting the interests of consumers.

If a customer has any concerns about the safety of operating their meter, they should contact their energy supplier immediately for support. Under Ofgem’s licence conditions, suppliers are required to ensure that a prepayment meter is safe and reasonably practicable for a customer’s circumstances. In its guidance, Ofgem set out that they would expect an assessment of this to include consideration of the location of a meter and how this may impact a customer’s ability to operate it. If at any time a supplier becomes aware that a prepayment meter is not safe to operate, Ofgem rules require suppliers to take action and offer to rectify this, which could include altering the position of the meter or providing an alternative method of payment for the customer.

In relation to future protections, Ofgem introduced new rules in November 2023 that restrict suppliers from installing a prepayment meter involuntarily for certain vulnerable groups, including those over 75 years old with no additional support in the household. These new rules also require suppliers to make at least ten attempts to contact an indebted customer and carry out a site welfare visit prior to any involuntary installation or remote switch of a smart meter taking place, to ensure the payment method will be safe in the customer’s circumstances. A remote switch involves remotely changing a smart meter from credit to smart prepayment mode. Under these new rules, suppliers are now also required to assess whether a prepayment meter continues to be safe for a customer on an annual basis as a minimum.

Alongside this, the smart metering rollout is improving prepayment customers’ experience, by giving consumers a means to top up their credit without having to access their meters. The Department will continue to work with energy suppliers to drive them to deliver smart metering to as many households as possible.

Following this case being brought to my attention, I have spoken with senior Ofgem officials who have assured me that they are looking at this case in detail and will take any necessary actions to reduce the risk of such tragic incidents happening again. I also welcome the actions for industry that have been set out by Energy UK in their response to this report.

I also welcome Energy UK’s commitment to work with a range of stakeholders, including the housing sector, to ensure more is done to identify those that need support and deliver interventions that keep customers safe. This is a useful action to bring together all those who can improve support for vulnerable customers across the energy and housing sectors. The government would welcome the opportunity to engage with these workshops, looking at relevant energy and housing considerations which could help vulnerable consumers.

My officials would be very happy to discuss this case with you further, or put you in touch with relevant Ofgem officials, if helpful. My officials will also work with Energy UK on the delivery of the actions highlighted in their letter, such as the proposed workshops on vulnerable customers, as appropriate.

Finally, I would like to reiterate my sympathies with Ms Faulkner’s family. The Government will continue to engage with Ofgem and industry on this issue, to ensure the relevant parties are doing all they can to support and protect consumers.

Amanda Solloway MP Minister for Affordability and Skills