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REM Tender - Section 1.2: Legal Compliance (20%)

REM Energy Services Procurement - L7 Energy Tender Response

Section 1.2: Legal Compliance (20%)


📑 Tender Response Navigation


1. Heat Networks (Market Framework) Regulations 2025

Understanding and Experience

L7 Energy has an established understanding of the Heat Networks (Market Framework) Regulations 2025 and the transition of heat networks into a fully regulated environment under Ofgem oversight. We recognise that these regulations introduce enhanced requirements around consumer protection, metering accuracy, fair and transparent billing, data integrity, auditability, and ongoing compliance reporting.

Our approach focuses on ensuring that operational processes, metering data, and billing systems are aligned with both the current requirements and the anticipated enforcement expectations of the regulated regime.

This aligns to the Service Matrix (Annex 4) as applicable.

BTR and Mixed-Use Developments

We have supported Build-to-Rent (BTR) and mixed-use developments operating communal and district heat networks, including residential, commercial, and landlord supplies. This includes preparing managing agents and asset owners for regulatory compliance by ensuring appropriate metering strategies, billing methodologies, and supporting evidence are in place.

REM's portfolio—including The Shard (understood to include circa 70+ heat meters across hotel, residential, and commercial uses), Park House, and Shard Place—represents exactly the type of complex mixed-use environment where our expertise applies.

Heat Network Billing and Compliance Services

L7 Energy provides end-to-end services covering:

  • Heat network billing design and validation
  • Fair and transparent cost allocation methodologies
  • Tariff modelling and resident-facing transparency
  • Billing data validation, reconciliation, and exception handling
  • Compliance documentation and audit-readiness support

Our Loop platform and operational processes are designed to adapt as Ofgem guidance and secondary legislation evolve.

Metering and District Heating Experience

We have experience working with:

  • Heat meters and heat cost allocators
  • Communal and district heating schemes
  • Multi-utility metering environments (The Shard is understood to have circa 250+ meters across electrical, heat, water, gas, and equipment categories)
  • Legacy and non-ideal metering arrangements, including remediation planning

Meter Reading Operations, Training, and Evidence Capture

L7 Energy operates a structured meter reading and verification model combining trained personnel with robust digital tooling.

All meter reading staff are trained in:

  • Identification and correct reading of heat meters and heat cost allocators
  • Compliance-aware data capture
  • Escalation of anomalies, access issues, or suspected faults

Meter readings are collected using a dedicated mobile application that provides:

  • Timestamped meter readings
  • Photographic evidence of each meter
  • On-site notes for access issues, damaged meters, or anomalies
  • Secure upload into the Loop billing and compliance platform

This ensures a clear audit trail, supports dispute resolution, and aligns with regulatory expectations for evidence-backed billing.

Automated Meter Reading and BMS Integration Capability

In addition to manual meter reading, L7 Energy is capable of receiving automated meter data from Building Management Systems (BMS) and metering platforms, supporting both push and pull integration models.

Loop Platform Integration Capabilities

Our Loop platform is built with direct meter and BMS data collection at its core. We have experience working with data originating from commonly deployed BMS and metering environments, including (but not limited to):

BMS/Platform Integration Capability
Trend (Trend IQ / Trend 963) ✓ Supported
Honeywell (EBI, SymmetrE) ✓ Supported
Schneider Electric (EcoStruxure) ✓ Supported
Siemens (Desigo) ✓ Supported
WebCTRL (Automated Logic) ✓ Supported
Priva and comparable estate-level systems ✓ Supported

Automated data ingestion enables:

  • Higher-frequency and more consistent meter reads
  • Improved data accuracy and validation
  • Reduced reliance on physical access
  • Scalable compliance across large or multi-site portfolios

All automated data is subject to the same validation, exception handling, and audit controls as manual reads within our Loop platform's multi-stage validation framework.


Understanding of REM Key Requirements and Added Value

Requirement from ITT How L7 Will Address Added Value to Landlord
HNR consumer service Trained CS team, Loop Case Management, transparent billing, complaint resolution with audit trails Regulatory readiness; reduced complaint escalation; Ofgem-grade evidence
Ofgem reporting readiness Structured data exports, compliance tracking, evidence retention Proactive preparation; avoid last-minute compliance scramble
Metering infrastructure for billing Meter register management, calibration tracking, remediation planning Accurate billing foundation; reduced disputes
Data audit trail/retention Immutable facts, versioned calculations, 7+ year retention Defensible billing; dispute resolution capability
MHHS readiness HH data collection, supplier/MOP coordination, settlement-ready data Future-proofed for market-wide settlement changes
Billing transparency Three-stage calculation, adjustment journals, tenant portal access RICS compliance; tenant confidence; reduced queries

Market-Wide Half-Hourly Settlement (MHHS) Readiness

L7 Energy is preparing clients for the transition to Market-Wide Half-Hourly Settlement (MHHS), which will require all meters to be settled on actual half-hourly consumption data. Our approach includes:

  • Collection and validation of half-hourly (HH) data from suppliers and AMR systems
  • Coordination with Meter Operator Providers (MOPs) to ensure meter configurations support HH settlement
  • Data quality monitoring to ensure settlement-ready accuracy
  • Integration with Loop platform for HH data storage, analysis, and reporting
  • Proactive identification of meters requiring upgrade or reconfiguration

This ensures REM is positioned ahead of MHHS implementation timelines.


2. Risk Management Strategy for Emerging Legislation

Typical Regulatory Risks Identified

We commonly identify risks including:

Risk Category Description
Metering Infrastructure Non-compliant or inaccurate metering infrastructure
Data Quality Poor data quality leading to billing disputes or regulatory breaches
Audit Readiness Lack of audit trails and evidential records
Transition Preparedness Insufficient preparedness for regulatory transition deadlines
Cost Recovery Inability to demonstrate fair and transparent billing to residents

Monitoring Legislative Change

L7 Energy actively monitors:

  • Ofgem consultations and guidance
  • DESNZ (Department for Energy Security and Net Zero) publications
  • Industry working groups and regulatory updates
  • Heat Trust developments and best practice guidance

We translate legislative change into practical operational impacts rather than abstract legal interpretation, providing REM with actionable guidance specific to their portfolio.

Compliance Tracking and Preparation

We maintain an internal regulatory tracking framework mapping:

Element Description
Applicable Legislation Heat Networks Regulations, SECR, ESOS, MEES, Building Safety Act
Client-Specific Obligations Mapped to each building and use type in REM's portfolio
Milestones and Deadlines Tracked with automated alerts via Loop platform
Required Evidence and Artefacts Documented and stored for audit readiness

Clients are supported through:

  • Compliance roadmaps aligned to regulatory timelines
  • Readiness assessments identifying gaps and remediation priorities
  • Phased implementation plans ensuring orderly transition
  • Regular briefings on legislative developments and their implications

3. Other Relevant Legislation Experience

SECR (Streamlined Energy and Carbon Reporting)

Experience supporting accurate data aggregation, validation, and audit-ready datasets for SECR reporting. Loop's analytics layer automates the extraction and formatting of consumption data required for annual SECR submissions.

ESOS (Energy Savings Opportunity Scheme)

Experience supporting data provision and analysis for ESOS assessments across complex estates. Our historical data retention (7+ years) and granular meter-level analysis supports ESOS Lead Assessors in identifying energy saving opportunities.

MEES (Minimum Energy Efficiency Standards)

Understanding of MEES obligations and how metered energy data supports compliance, planning, and landlord decision-making. Our consumption analytics help identify underperforming buildings and prioritise improvement investments.

Building Safety Act

Awareness of implications for data governance, accountability, and the maintenance of accurate system and asset records, particularly where energy systems form part of the building's information "golden thread". Loop's immutable data architecture and comprehensive audit trails align with the Act's requirements for accurate, accessible building information.

Ofgem-Regulated Environments

Experience operating in environments aligned to Ofgem expectations, including:

  • Transparency in billing and cost allocation
  • Auditability of all calculations and adjustments
  • Consumer protection principles
  • Data retention and accessibility requirements

4. Case Studies / Evidence

L7 Energy has supported clients through regulatory change by:

  • Updating billing methodologies to align with new guidance and ensure fair, transparent resident billing
  • Retrofitting compliance controls into live operational systems without service disruption
  • Improving metering data quality and auditability through systematic validation and evidence capture
  • Preparing documentation and reporting suitable for regulatory review and Ofgem oversight

We have directly supported communal and district heat network operators in improving billing transparency and preparing systems and processes for future Ofgem oversight.

Relevant Portfolio Experience

Our current management of properties similar to REM's portfolio demonstrates our capability:

Property Type Compliance Elements
Mixed-use towers Multi-utility metering, tenant recharging, landlord compliance
BTR developments Heat network billing, resident transparency, HNR 2025 preparation
Commercial offices SECR reporting, ESOS support, energy procurement
Hotel/hospitality Complex sub-metering, 24/7 operations, high data volumes

Further detailed case studies can be provided under NDA if required.


Summary

L7 Energy approaches legal compliance as a continuous, operational capability rather than a one-off exercise. Through:

  • Trained personnel with compliance-aware data capture practices
  • Robust digital evidence capture via our mobile applications
  • Loop platform providing automated data ingestion, validation, and audit trails
  • Proactive regulatory monitoring and client-specific compliance tracking

We help clients reduce regulatory risk, protect residents, and remain prepared for evolving legislative requirements.

Our Loop platform's architecture—with immutable data records, multi-stage validation, version-controlled calculations, and comprehensive audit trails—is specifically designed to meet the transparency and accountability standards that Ofgem-regulated environments demand.


This aligns to the Service Matrix (Annex 4) as applicable.


[End of Section 1.2]


📑 Navigation

Previous: ← Section 1.1: Full Managed Service Consultancy
Next: Section 1.3: Recharge Strategy →

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