Dear Utility Regulator (Northern Ireland),
I am submitting this as a Freedom Of Information Request 2000 I request all replies to be provided inline and in the spirit of current GDPR
Does the utility regulator think the Gas Connection forms for the Greater Belfast license holder act are in the best interest of the general public? Particular concerns that those connecting to the Natural Gas network are
1a.Denied the right to decline marketing, a breach of the ICO regulations and GDPR regulations.
2. Their personal details are transferred to a separate limited company for marketing of bait and switch services. would the regulator support such action?
2a. When they decide to sign to the network their details are passed for the sale of gas to the
commissioning supplier and again without the ability to refuse marketing from that company. what action are our regulator doing to stop this action?
3. Should they decide to move to another energy supplier their data remains with companies they did not give permission to have their data. would the regulator support such action?
4.This is unfair competition abusing their market position. Most people who then engage this
company are totally unaware it is not the transporter but a separate limited company.
5. Is it fair that the transporters call centre is used for out bound marketing calls for the separate limited company to sell private services have the cost borne in the network over heads? Do our regulator support such action ? if not what are you doing about it?
6. Is it fair that the fleet procurement and insurance services also cover the separate limited entity which engage to actively compete with contractors, this provides them with an unfair sales,marketing operation and vehicle provision. do the regulator support this action?
7. Whilst we understand there will be a need to transfer to data to deliver the emergency gas
service as this is not an in house operation as it is with Transco in GB is it fair that this sub
contracted company operatives carry out marketing whilst providing the ESP response?
Why does the transporter not have in house engineers like Transco totally separate from private work as it is in GB as the network has grown to a size to make it sustainable?
8. Does the regulator deem it acceptable for work carried out in breach of the Gas Installation and Use Regulations where meters are installed without support brackets and left to swing free on double anaconda’s in meter enclosures? The regulations state it is not acceptable to carry out substandard works. Should the contractor who carried out these sub standards works not be required to return at their cost and put right the defective work as every meter change is tracked and documented and the engineer can be identified. No money from the network operator overheads should pay again to put right incorrect installs which they have been paid for before. Do you support this action?
9. We have seen in large apartment developments where gas meters are directly supported from the gas pipe work as opposed fixed to the structure? Does the regulator approve of this deviation from the industry standard by the gas transporter? Do you support this action?
10. In large apartment developments and multiple meter installations in commercial property there is often multiple meters and none of the meters are identified to which dwelling or unit they serve.The attending gas engineer has no way of identifying which meter is supplying which property.Can a service be provided where a telephone call be made to enable meter number so it can be traced by engineers calling in?
11. It has been noted in commercial rigs of some not being commissioned when engineers have been told in writing they are commissioned. Some are tagged commissioned but no Emergency information decals provided, no working pressure information or maximum incident pressure identified. Also allot of commercial rigs lack a basic test point available to enable tightness test to be under taken a basic requirement for Gas Safety. Has the regulator issued a relaxation to these basic features? if not why is this common practice?
12. We note the emergency planning in the event of a serious escape in the network requiring a main service to be shutdown requiring a large number of customers to have their gas cut off, the standby system to call on contractors to respond to assist in purge and relights. Has the effectiveness of the system and the turn out rate of an unannounced test ever been carried out to see if the response would be sufficient as not to leave customers without gas for an extended period? How many engineers are recorded as promised to attend if required? if so how many are registered as available , also when was the last dry run carried out? why has the rate for attendance not be implemented to reflect the increase in practical costs since the implementation of this request or at least inline with RPI?
13. Now that contractors are sufficiently trained and qualified to sign up customers to license operators gas network in the greater Belfast do they still require the need for energy advisors as contractors are best pace to carry out this role this will inevitably reduce overheads thus reducing the price of natural gas to the consumer?
14. The Belfast gas license operator is supporting a select group who of contractors over the majority who are able to provide finance to customers would this be considered by our regulator as fair and unbias practice?
15. have the utility regulator engaged with the gas trade outside of NINGA ? if not why not , if so where and when? gas engineers are the second largest stakeholder after the public?
16.Why within Gas Bills being issued that they are accompanied with sales and marketing literature, again the customer have an inability to opt out of this form of inconsiderate advertising? why are the customers rites not respected in the gas connection agreement?
Confirming receipt of your request below and advising that Barbara is not the FOI Officer. I deal with FOIs and have copied my contact details below. Please be advised that we are treating your request as an information request rather than an FOI request.
I will be in touch again in due course.
Corporate Affairs Executive
14 Queen Street
Belfast BT1 6ED
Direct Tel: +44 (0) 28 9031 6664
General Contacts: T: +44 (0) 28 9031 1575 F: +44 (0) 28 9031 1740 E: [email address]
Thank you for your email below. Your request covers a wide range of areas in relation to the operation of the gas network, however the majority of the issues raised do not fall within the remit of the Utility Regulator.
We are an independent economic regulator who regulates the activities of regulated companies via a licence, which outlines the requirements and obligations that the company is required to comply with. The charges passed onto consumers by these companies are calculated by a tariff, which is informed by a price control process. We consult on all price controls that we put in place, allowing all views to be heard and considered. If you are interested in reviewing certain licences and price control decisions, I have provided a link to our website – www.uregni.gov.uk where you can access these documents.
As we are unable to deal with the points raised on an individual level, I have grouped together a number of questions which all have a similar response.
In respect of 1, 2, 2a, 3 and 4
The points raised are the responsibility of the distribution network operator (DNO) as we do not have the vires to approve their individual processes. Protecting the personal details of customers is the responsibility of the data holder (which in the issues you have raised is the DNO). If you have a complaint regarding the use of personal data, you should refer it to the Information Commissioner’s Office (ICO).
In respect of 5, 6, 7, 12, 14 and 15
The points raised are considered as part of our price control process. However, the more specific details on how the licence holder carries out its operation, is largely at the discretion of the company/licence holder, subject to complying with the licences and applicable codes of practice.
In respect of 8, 9, 10, 11 and 13
These points refer to technical aspects on how gas connections are undertaken. All DNOs are responsible for their own health and safety matters. If there are any issues that need addressed, they should be referred to the Health and Safety Executive Northern Ireland who may be able to assist.
In respect of 16
Obligations regarding customer bills are covered within gas supply licences. However, if personal data is not being treated appropriately, this would be a matter for the ICO.
You may be interested in taking part in our future consultations and price control processes. We recently published a Cost and Performance Report, available at - www.uregni.gov.uk/news-centre/cost-and-p..., which mentions our plan to review sales related activity in 2020. This would be done through an open consultation process with all views and opinions welcomed. You may also wish to sign-up to receive email alerts when we publish news items on our website. To do this, scroll down to the bottom of our home page – www.uregni.gov.uk and enter your email address.
Thank you for taking the time to contact us.
Corporate Affairs Executive
Dear Utility Regulator (Northern Ireland),
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Utility Regulator (Northern Ireland)'s handling of my FOI request 'Safety and Value For money Of The Natural Gas NetworkRE ]
The questions put to you have not been answered fully and to generalise my questions in this way is inappropriate and not acceptable, taking 20 days to give partial answers to very specific questions!
This is not in the spirit of current GDPR legislation and if the review is unable to clearly answer the questions put before you I will have no choice but to forward this and all correspondence in this matter to the ICO for their consideration and judgment.
A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/s...
Dear Irwin, Greg,
Having passed the “long stay” GDPR time line and failed to request additional time to respond, I am now left with NO choice but to pass all correspondence to the ICO for their judgement and consideration of this case.
I will give you a further 3 days to respond to demonstrate to the ICO I have been more than considerate in the time line after this period I will forward to the ICO under “casework” for a judgement. Hopefully this will not be necessary but after the additional 3 days I will send onto the ICO.
Dear Mr Steward
Thank you for your email.
Firstly, we note that in your most recent email you state that we have passed the "long stay" GDPR time line. Having considered this statement carefully we did not immediately see the relevance of GDPR to your correspondence with us and do not therefore recognise the timeline that you identify in your email.
In your original correspondence of 26 November 2018 you asked a series of questions relating to the Natural Gas Industry and for our view on several matters and indicated that you were submitting the correspondence as a Freedom of Information request. Having reviewed your original correspondence it was our view that, since no information was being requested, we would not be treating the correspondence as a Freedom of Information request. We advised you of this position in an email to you on 5 December.
However, we did undertake to respond to the questions that you raised in so far as we are able to. Our gas networks team reviewed each of your questions in turn and it became clear that many of them related directly or indirectly to specific items outside our remit. In that context we provided a response to you on 21 December (within 20 working days of your original correspondence). Finally we did signal to you our intention to publicly consult on sales related activity next year and we would welcome any response you may wish to submit to that consultation .
You wrote to us on 21 December seeking a review of our response. We acknowledged this request on the same day. We are now assessing whether we could add to our original response in order to be as helpful as we can and will be in touch as soon as possible.
Dear Irwin, Greg,
I am still waiting on a timely reply at your earlies convenience
Dear Mr Steward
Further to my email to you of 4 January 2019. Apologies for the delay in
In my email of 4 January I made clear that we were not treating your
original correspondence as a Freedom of Information request, since no
information was being requested. However, we did undertake to review
whether we could add to our original response, in order to be as helpful
as possible to you.
We have, since my email, taken some further time to review each of your
questions in turn and our response. I am attaching an annex which lists
each of your questions and our consideration of same, including whether we
have any further comment to make or if there is relevant information
available that we should draw your attention to.
I hope this email and the associated correspondence finally clarifies
things for you and brings matters to a close.
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