Your question is unclear.

Presumably a design goal (for the antenna embedded in the meter) would be to provide something close to omnidirectional coverage. It's not as if they're able to rotate the meter, with attached building, to aim the antenna.

Patch antennas typically radiate off their flat surface. E.g. GPS antennas.

You might need to clarify your question.

P.S. Smart meters are a horrific topic. The internet is knee deep in nonsense.

FCC regulations for the type of ISM band transmitters used by smartmeters are permitted requires them to be "substantially omnidirectional". They're never perfectly omnidirectional. Antennas used tend to be (but not always) inverter-F or meander-line types as the cost is only a little PCB area.