There are some excellent points in this document. It does a good job with the issues it addresses, but it fails to address some other critical ones.One issue that it does not address is the ease of disconnection may put higher pressure on the limited resource customer to find money to put on the bill and push the customer to turn to any available source, including high cost loans that are often difficult to repay. This seems more likely to occur in the prepay than in the postpay environment.
What network will exist to accept payments - especially at night, on weekends, and holidays? Will consumers who live in remote rural areas have access to a payment system? We cannot assume they have internet access or credit cards. The data I have seen illustrate that most low income citizens do not have smart phones and thus no access to internet via wireless technology. In many rural areas wireless signals are weak and do not adequately support internet access. In my community, many families depend on the internet at the library in the community center and must drive distances that are not walkable and not covered with public transportation. That center is closed at night, on Sundays, and holidays.
Many older consumers have no interest in accessing the internet. In my experience as a consumer educator, some folks don't even want to learn to use a calculator. I don't think we can assume that this generation of older consumers will have universal access to the internet.
Also, what means will consumers have to access information concerning the quantity of energy remaining? How much will obtaining that information cost the consumer? Will it be available at night, weekends, and holidays? Most people have phones of some sort, but many who use wireless change numbers frequently.
When we employ prepay, we need to assure that we are not setting up a situation where consumers are worse off. The paper supports this and it's important to cover all of the issues before deploying the technology.