This is Icebreaker One’s response to Ofgem’s Connections End-to-end Review consultation.

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 policy@ib1.org. We have omitted questions which we did not answer. 

Overall Position

We support the introduction of a new licence condition requiring improvement to connections data. However, the proposal would benefit from clearer definitions of sensitive data and a broader scope that includes both open data and shared (sensitive) data. It is important to note that capacity data is relational not static – interoperability between different data providers and datasets is essential.

A transparent user needs-led approach to data assurance would encourage data sharing, support higher data user confidence, and provide more flexibility than fixed requirements on accuracy, completeness and timeliness, for example regarding update schedules and interoperability. Data user needs must be explored and permitted to share improvement incentives to ensure design and use are aligned. It is important that shared data improvement is incentivised before the timeline for full DSI integration as there is demand for this data immediately. 

Consultation question responses:

Theme 1 – Improving visibility and accuracy of connections data 

Q1.1. Do you agree with Proposal 1.1. to introduce a new licence condition for accurate, complete and timely data? 

Yes, we agree with Proposal 1.1 to introduce a new licence condition, however, it should not be limited to open data publication (see question 1.2 below for sensitive data response). All data sharing would benefit from a clear assurance framework, which may draw from established assurance approaches such as Icebreaker One’s generic dataset assurance levels. Data that is not 100% accurate, complete or timely can still be valuable as long as the limitations are made clear. Assurance encourages publication rather than waiting for “perfect” data, which can mean that key datasets are not published due to data quality concerns. Assurance can include accuracy, completeness and timeliness but it enables more nuanced or context-specific signals about data quality, for example interoperability or provenance.

We encourage licensees to engage widely with stakeholders, particularly those outside the energy sector, to develop data assurance signals that meet specific user needs. Open Energy can facilitate this through a structured approach to design, implementation and governance of such standards within the Energy Sector Trust Framework.  

We support the requirement for data to be as close to real time as feasible, subject to security considerations (e.g. more granular data may be subject to additional access controls). Monthly updates should be considered a minimum baseline, not an indicator of best practice. More frequent (e.g. daily) data updates would be helpful to accelerate policy ambitions to speed up the connection queue. In all cases, update schedules should be published transparently as part of the assurance process.

It is vital that this condition has a consistent  approach across distribution and transmission networks to ensure data is as interoperable as possible. Increasing demand from new industrial plants and digital infrastructure reinforces the need for high-quality, frequently updated, relational connections data. Connections data requirements should apply consistently to both:

  • Generation connections
  • Demand connections (including large industrial loads and data centres)
Q1.2. Do you agree with Proposal 1.2. to split data into open and sensitive categories, and to use the Data Sharing Infrastructure to share sensitive data? 

No. Sensitive data is not a monolithic category, there are existing approaches (e.g. IB1 Data Sensitivity Classes) to sub-categorise which should be used in order to assess data sensitivities and place appropriate access controls/licensing. This will provide DNOs greater guidance from regulators on what should be considered sensitive data. 

DSI data sharing may not be (immediately) suitable for all use cases, it is currently unclear when and how non-regulated actors will be able to access data via the DSI and these actors constitute major customers for connections data (e.g. heavy industry, retail etc). While sensitive data may be exchanged via the DSI in future, improvements must not be put on hold until the solution is ready. Further, determining whether the DSI is used as the primary mechanism to share sensitive data should depend on the outcome of the MVP.  

Q1.3. Do you have any additional comments in relation to the decisions and proposals outlined in this theme? Do you have any additional comments related to any other aspects of this theme you think we should consider? 

Additional comments:

  • Network headroom is not static at a single supply point (substation / GSP). Capacity availability is relational and influenced by:
    • Nearby supply points and how power is drawn/combined from different points
    • Connection queues and timelines
    • Reinforcement plans and timelines
    • Local and regional constraints (e.g. DNO/TNO or cross-DNO constraint interactions)
  • The licence condition and associated data standards should better capture and communicate these relational dependencies.
  • Greater transparency regarding capacity that has been committed but is not yet utilised (and anticipated timescale for use) may support better planning.

Lessons from relevant innovation projects (e.g. work examining relational network constraints) should inform the design of data publication and visualisation tools. In particular, lessons from the Strategic Innovation Fund REACT programme which aimed to  address current planning and future planning for generation siting may be valuable. REACT’s Alpha Phase Data accessibility and interoperability report recommendations:

  • Reducing friction: To improve data assurance, reduce friction across data silos and provide forward compatibility with the Virtual Energy System, the REACT project must embrace a ‘Trust Framework’ methodology throughout its work.
  • Improving data accessibility: To improve the discoverability of datasets and encourage process innovation, Transmission Owners should publish internal process diagrams that describe the workings of complicated internal processes – such as the Network Connection Request process.
  • Improving prediction: To improve long-term planning for Transmission Owners and for other stakeholders, a statistical model of projects should be embraced that tracks a project’s estimated probability of success according to the best available data.
  • Embracing innovation: To radically embrace innovation around processes, such as the Network Connection Request process, virtual ‘sandbox’ representations of these processes with representative data should be created. This will enable innovators to safely experiment with innovative solutions without affecting Business as Usual.

As mentioned in IB1’s Response to Ofgem Modifications to RIIO-3 consultation, with the progress of the Data Sharing Infrastructure (DSI) programme, IB1 anticipates ‘Shared Data’ sharing will evolve and will inform the evolution of data best practice (DBP) guidance. In particular, as data sharing scales, the need to standardise and harmonise legal and technical approaches will become more pressing in order not to slow innovation and add unnecessary cost. IB1 recommends that DBP should include guidance around Shared Data within the triage processes and licensing decisions, highlighting the role of Shared Data Schemes to provide definitions that aid interoperability and maximise impact.