This is Icebreaker One’s response to the BEIS Net Zero Review call for evidence. Please find it openly published here, and copied below. Please note that throughout this consultation, Icebreaker One uses the terms Open, Shared and Closed data as defined here.

If you have any questions about our submission or require clarifications please do not hesitate to contact us via

Overarching questions

2. What challenges and obstacles have you identified to decarbonisation?

Icebreaker One believes trusted data sharing and digitisation at national scale are core challenges to driving to net zero. 

Accurate, trustworthy data that informs net-zero actions is essential to decision-makers across finance, industry, government and beyond. It will help derisk financial instruments, accelerate new technologies to market and enable monitoring against science-based targets.

The businesses we work with have expressed an urgent need for better data to inform strategic investment decisions, understand supply chains and assess the impact of their decarbonisation efforts. As decarbonisation is a multi-sectoral challenge, relevant datasets are limited in availability and come from a wide range of sources and can be hard to find, procure or utilise. With a better data sharing infrastructure, businesses can move faster to decarbonise, with more informed confidence, less risk and lower costs.

Challenges identified:

  • Data does not flow effectively between organisations
  • Instead of being connected and networked in an open ecosystem, data is siloed
  • Most organisations believe that the correct approach to solving this challenge is to ‘build a portal’, which risks keeping data siloed in a range of different databases instead of networked. This prevents informed decision making

Icebreaker One believes that this is not a technology problem. It is a commercial, political, and cultural challenge. 

We propose the following recommendations: 

  • Use open standards for data sharing 
  • Address which data need to be shared, why, how, by and for whom
  • Anchor around common rules that address user needs (search, access, use) 

Data sharing at national scale requires a clear strategy to design the marketplace(s) across which data will be shared. The UK Government has a major role to play in that market design. 

An open market helps unlock discovery (search), access (processes), and usage (licensing), for both Open data and Shared data. We strongly recommend applying the following core principles:

  1. Design for search: Making data discoverable means designing for search
  2. Connect don’t collect: Accessibility requires addressing structure and connectivity of data
  3. Address user needs: Addressing data usability means addressing data licensing around use-cases and user needs

3. What opportunities are there for new/amended measures to stimulate or facilitate the transition to net zero in a way that is pro-growth and/or pro-business?

Icebreaker One’s extensive research has shown that for the UK to hit its national targets, it is necessary to both de-risk investment and make impact both measurable and accountable. This will require facilitating access to commercial data using low-friction, secure, trusted networks. It first requires a focus on open access and, in addition, data that is in the national interest must be published for access by anyone using Open Data licences. Examples of open standards for data sharing include Open Finance, Open Banking, Open Energy, and insurance and asset-level innovation such as the Standard for Environment Risk and Insurance (SERI).

Improving access to data for UK businesses will deliver commercial benefits and growth, in the same way that Open Banking has accelerated the growth of the UK fintech sector. 

The opportunity to deliver an open marketplace for commercial data incentivises the whole value chain because businesses thrive with better access to data. Open standards help to create open marketplaces for commercial and open data: rapidly expanding proven sector trust frameworks (e.g. that support the finance sector) to find, access and use data; to create incentives, improve decision making and radically increase transparency.

To deliver a demonstrably Net Zero future requires cultural changes to institutional frameworks of data sharing and access (governance, regulation, transparency). For example, a regulatory mandate focusing not only on what to disclose but also on how to disclose it. A trust framework can inform mandates for policy and regulation, as well as legal, operational and technical standards for interoperability. Such approaches also stimulate commercial innovation in analytics, data science and technology providers, subsequently increasing innovation, optionality and competition in the market.

Icebreaker One is engaging with the sectors that have the greatest impact on our climate and environment and creating a market architecture for data, based on the Icebreaker Principles: Organisations (e.g. Arup, Open Data Institute) are signing up to endorse these principles.

4. What more could government do to support businesses, consumers and other actors to decarbonise?

Icebreaker One recommends taking the following steps to enable our Net-Zero Future:

  1. Recognising that trusted data is essential to delivering net zero
    Accurate, trustworthy data that informs net-zero actions (‘net-zero data’) is essential to decision-making across finance, industry and government. It will help derisk financial instruments, accelerate new technologies to market and enable monitoring against science-based targets.  
  1. Mandating that access to net-zero data be open
    Data must be made discoverable and accessible to those who need it.  To unlock public and private sector benefits, the ability to effectively share data (using Open or Shared licences) across sectors is essential. This includes finance, agriculture, water, transport, energy and the built world. Net-zero data must be machine-readable, and have open metadata to enable its discovery.
  1. Ensuring the rules for data sharing address public and private sector needs
    To enable access to data, the definition of the rules used to share it requires participation from diverse actors. Data owners need to be able to control who can access it in a manner that addresses commercial, legal and regulatory requirements. Robust policies and standards can also support assurance and auditing, therefore enhancing trust.
  1. Ensuring net-zero data infrastructure is governed openly and independently
    To maintain an open market, data infrastructure must include public and private sector actors in its design, implementation and enforcement. A market-neutral Trust Framework is a preferred approach to developing such data infrastructure and includes remits of data governance, policy, licensing, technical and operational codes and principles. This infrastructure needs to be developed, and iterated upon, at a pace that is relevant to the urgency of the issues being tackled. Both its processes, and outputs related to its implementation, should be openly licensed.
  1. Creating mandates for engagement
    To create a level playing field, close data gaps as rapidly as possible and address the public interest, Government and regulators should define rules for access to specific net-zero data, mandate participation in data sharing and drive adoption. Similarly, industry initiatives can define rules for specific industry benefits, and act as catalysts to adoption. Common policies and open standards must create mandates for machine-readable data, data access processes, access control and mechanisms for enforcement that unlock data flow. 

6. How should we balance our priorities to maintaining energy security with our commitments to delivering net zero by 2050?

Maintaining energy security and net zero requires a coordinated understanding of where energy is being used, where it can be reduced, and how this relates to network supply and distribution. Current modelling, while advanced, does not have the right quantity, quality, diversity, granularity and time resolution to maximise the benefit for the whole system. Industry, Government and consumers need better access to data and information to help reduce risk, increase efficiency and maximise resilience.

The government’s energy security strategy further underscores the importance of energy data to achieving national targets,.

The challenge is to improve energy security in both supply and efficiency (reduction of consumption): to accelerate switching to a new energy mix; reducing energy use across the UK (domestic, public and commercial); to ensure economic stability and in the short term alleviate the cost-of-living crisis. 

The gap is that there are many different systems and models across organisations that make secure, resilient and repeatable sharing of trusted data difficult. An opportunity exists to accelerate the Energy Digitalisation Task Force (EDiT) recommendations, increase resilience and unlock innovation. Convening around this challenge requires public and private sector collaboration, across sectors (e.g. Electric Vehicles). 

Understanding systemic options that could help address this

We acknowledge that there will be issues regarding pricing, availability, flexibility and pressure on demand. To address this, collaboration will be required between the DNOs to have a clear view on energy supply and demand, including a better understanding of where there is demand vs flex capacity. It will require coordination between government, industry and consumers to both reduce demand and to increase production.

We recommend taking the following actions in order to enable government and industry to understand the priority data gaps that stand in the way of addressing current exposure and delivery of the energy strategy:

  1. Bringing together expertise by convening relevant stakeholders in a coordinated, agile, time-bound and results-based programme;
  2. Identifying specific use cases that can deliver solutions that can be addressed through better data sharing, and could include where data could aid government and regulator decision making (through stakeholder engagement and research);
  3. Identifying the data and information needed (both presumed open data and secure data);
  4. Building reusable data infrastructure (including that which requires higher security levels) needed for the data sharing to take place in a trusted framework (e.g. Open Energy;
  5. Analysing and reporting on Open Energy’s data sensitivity classes so that the work can be repeated, replicated and scaled across related sectors (eg. electric vehicles, water);
  6. Benchmarking current practices and reporting on improvements, evidence and outcomes that support decision-making and institutional memory, aligned with the national interest. 

Questions for businesses

9. What barriers do you face in decarbonising your business and its operations?

The businesses we work with have expressed the urgent need for better (accurate, trusted, interoperable) data to inform strategic investment decisions, understand their supply chains, and assess the impact of their decarbonisation efforts. As stated in question 2, because decarbonisation is a multi-sectoral challenge, these datasets come from a wide range of sources and can be hard to find, procure or utilise. With a better data sharing infrastructure, businesses can move faster to decarbonise, with more informed confidence, less risk and lower costs.

Utilities face particular challenges in mobilising the data within and outside their businesses to accelerate their drive to net zero. We have covered this in detail in our response to question 6.

In the financial markets, Environmental, Social and corporate Governance (ESG) data has become a crucial tool to both deploy capital to sustainable projects and businesses, and to identify climate-related risks in portfolios and the wider financial system. Our work as part of the Future of Sustainable Data Alliance (FosDA) has identified more than $500B of worldwide capital deployment through ESG-integrated funds. Companies seeking this capital investment will increasingly be required to evidence their ESG commitments, but there is a lack of coherence in both disclosure and ratings that makes reporting arduous for the companies, especially where they operate across different jurisdictions. FoSDA is working to harmonise the data critical to ESG investment deployment and monitoring.

Questions for local government, communities and other organisations delivering net zero locally

25. What has worked well? Please share examples of any successful place-based net zero projects.

Our Icebreaking initiative convenes organisations and their stakeholders in a neutral environment with a focus on specific obstacles to net zero  that can be addressed with tangible actions. Working with stakeholders, we identify priority value cases, map out the data value chain, and prioritise actions and steps which empower organisations to create a concrete plan for their delivery. Core to this process is open engagement promoting collaboration with the sector, for the sector and by the sector. 

Throughout this process, we have worked with a number of organisations to facilitate the identification and execution of their local net zero projects. Some examples include:


Icebreaker One worked with SSEN to identify and tackle data silos and develop data-sharing opportunities to facilitate electricity networks in managing the additional electricity demand caused by the uptake of electric vehicles (EVs).  First, a specific use case was prioritised to allow focus on a tightly defined scope, then a workshop was held to develop and vote on action proposals related to the prioritised use case. The workshop was so successful that plans are being made to unlock budget to further develop the top voted proposal.


Icebreaker One partnered with the Office of Zero Emission Vehicles to research and address the data gaps required to roll out thousands more electric vehicle charge points across the UK. A priority use case focussing on on-street parking availability was chosen. 

Local authorities are faced with the challenge of working out how to deliver this infrastructure in a timely, efficient, equitable and cost-effective way, while ensuring ‘location optimisation’. The focus on a single use case allowed for directed research, engagement, and participation in the project by external data controllers,consumers and local authorities. Participating in a workshop, local authorities along with DNOs brainstormed concrete actions that could be implemented locally.

27. How can the design of net zero policies, programmes, and funding schemes be improved to make it easier to deliver in your area?

We propose improving, evolving or creating funding mechanisms that address needs that fall in between explicit government and commercial interests. 

There are roles for non-commercial entities to deliver insights, activities and services that address public-private needs. This is particularly appropriate in emerging and evolving markets such as data and digitalisation, where there are new risks of commercial monopolies, and new opportunities to stimulate innovation and growth. 

Net Zero brings specific new challenges around cross-sector data sharing. For example, electric vehicles require combined digital efforts across transport, energy and the built world.  

Approaches such as these can unlock material value to the economy through the creation of open markets (for example Open Banking, which the UK instigated, is creating a $100B+ market). 

Questions for academia and innovators

29. How can we ensure that we seize the benefits from future innovation and technologies?

Our research and technology development as MEDA competition winners (Open Energy project) strongly suggests that the development of Shared data infrastructure is of high importance to the role of data and digitalisation in enabling net zero. We recommend that future investment in the ecosystem of net zero data should focus on specifying a unified approach to sharing types of data that do not meet the criteria to be published as Open data.

We suggest that a future approach builds upon the industry-tested foundations developed through the Open Energy trust framework in order to implement a clear and consistent approach to Shared data governance which can support an ecosystem of commercially, socially and environmentally valuable Shared data. We recommend that this includes:

  • The establishment of a system of data sensitivity classes, to improve consistency in sector understanding and categorisation of Shared data. 
  • The implementation of a standardised approach to Shared data access, based on a standardised range of access conditions, to enable flexible governance of data access within well-defined parameters.
  • The introduction of a standardised approach to Shared data licensing, based on a standardised range of licence conditions, to enable flexible creation of licences within well-defined parameters.

30. Is there a policy idea that will help us reach net zero you think we should consider as part of the review?

Icebreaker One has conducted extensive sector research supporting the creation of the Open Energy trust framework, including inquiry into whether this framework should mandate common standards for licensing, metadata, and data quality. 

From our research, we recommend mandating data sharing to make data work harder to deliver net zero, with the following priorities:

  1. General demand for data-sharing between regulated and non-regulated stakeholders stems primarily from Shared data, not Open data. Open data alone will not be sufficient to achieve net zero. Data exchange between regulated and non-regulated stakeholders for net zero purposes/projects is also primarily driven by Shared data, not Open data. This concerns data shared by and to regulated entities. We recommend that future investment in the net zero data should focus on specifying a unified approach to sharing types of data that do not meet the criteria to be published as Open data.
  1. Adoption of standardised licences for Open data should be prioritised. Research demonstrated that creation of bespoke ‘Open’ data licences present risks to data usability, by increasing the overheads (time, financial, legal) of interpreting non-standardised licences and/or by permitting data publishers to create licences which do not actually produce Open data (either through error or evasion). Rather than creating a new licence for this purpose, we strongly suggest that Government mandates data sharing via existing well-known licences (e.g. Creative Commons, Open Government Licence or similar). In order to minimise unnecessary conflicts which could surround the choice of a single Open data licence, as well as the burden of change for organisations that have already adopted different but well-known standard Open data licences, we suggest that Government specifies a limited set of well-established standard Open data licences that must be used to publish Open data.

Additionally, we suggest that the following net zero data policies are not enacted:

  1. Adoption of metadata standards is a highly politicised topic associated with low feasibility of reaching industry consensus on a ‘single’ standard. At present, there are significant differences between standards used by different actors across sectors. We suggest that mandating a single metadata standard risks producing inadvertent barriers to the publication of Open Data. Instead, a focus on unlocking discovery, access and interoperability can help address user needs.
  1. Adoption of data quality standards for Open data is highly contested, particularly for historical datasets and those influenced by legacy technologies. We propose that there would be value in offering support for organisations around two key issues associated with poor data quality: transparency and improvement. This does not need to be extensively technical, however it should aim to help data publishers ‘troubleshoot’ common quality issues prior to publication and thus to improve the baseline of Open data quality. For example, this could address common issues flagged within the Open Energy project, such as missing units of measurement or use of notation/acronyms without adequate explanation.

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