This is Icebreaker One’s response to the NESO’s Energy Sector Digitalisation Plan Call for Feedback.

If you have any questions about our submission, please contact us at policy@ib1.org.

Call for feedback response:

1. What areas of focus can be accelerated by Digitalisation to support a clean power system? 

Icebreaker One (IB1) is a non-profit working on data sharing and sustainability, convening organisations and governments to design market-scale solutions to make data work harder to deliver Net Zero. We create and run programmes to reduce barriers and costs to finding, accessing, using, and sharing data, which will ultimately reduce costs for consumers.

As noted in IB1’s response to DBT’s Invest 2035 consultation, achieving net zero and delivering the British Energy Security Strategy means addressing all aspects of the energy trilemma: affordability, security, and sustainability. The latest CBI Economics report found the “net zero economy is a powerhouse of job creation and economic expansion with 10.1% growth in the total economic value supported by the net zero economy since 2023”. We need to deliver a flexible, decentralised, and digitalised energy system that is critical to Net Zero. 

Energy data is currently hard to access (it is not ‘digital ready’ and requires multiple bilateral requests and contracts). It is disconnected from related sectors. An open standards-based, transparent, market-wide framework can allow rapid scalability of secure access to data. A framework for trusted data sharing will unlock the increasing variety, veracity and volume of energy data to system participants to adapt, evolve and create services that enable better network management, and respond to rapidly changing patterns of energy supply and demand.

As digitalisation of the wider economy accelerates it is essential that any governance mechanism is built to function flexibly within a shifting technical landscape. 

There will be a continual balance between addressing user needs and potential threats, necessitating robust governance to be participatory and responsive to a full spectrum of social and environmental considerations shaping the operational landscape, for example including capacity to respond to forthcoming Net Zero milestones, negative incentives, corporate capture, unintended monopoly positions, and data misuse.

We recommend digitalisation and data sharing builds upon prior art – simple and low friction options which build on previous implementation in other industries –  for example Open Banking which has been endorsed by the Competition and Markets Authority (CMA) and the Financial Conduct Authority (FCA), and taking a joined up approach to be interoperable with initiatives across the economy.

See our Open Energy use cases for examples of the benefits and barriers to data sharing with the energy sector https://ib1.org/energy/reports/ 

2. What specific activities are needed in each of the five capability areas to achieve our clean power? 

Governance and operating model

Addressing governance, user needs, business, social, legal, engagement and communications is critical to ensure any solutions are fit for purpose, and can be adopted by the market. We observe that technical-led programmes tend to fail to gain traction or deliver against material user needs. See IB1 governance standard operating procedures here: https://ib1.org/sops/governance-schemes/ 

Governance must address five pillars 

  1. User needs & impact: Identify user needs, explore / prioritise use cases, and mapping the data value chain
  2. Technical: Agree data and metadata standards, operational technical systems
  3. Licensing & Legal: standard legal data licences, apply data sensitivity classes to datasets identified
  4. Engagement & Communications: Address user needs, experiences, and create awareness and engagement for the programme
  5. Policy: Identify potential policy implications, blockers, or interventions

IB1 encourages cross-sector collaboration and learning wherever possible. We recommend engaging with cross sector stakeholders (i.e. water, transportation, local authorities, etc) and working with citizen advocacy groups to learn from best practices, ensure guidance is consistent for cross sector use cases (hydrogen, electric vehicles, electrifying public transport, etc), and understands the impact of digitalisation on different socio-economic stakeholder groups.

As noted in IB1’s response to Ofgem’s DSI governance consultation, IB1 suggests there is clear guidance as to how rules are established, overseen, enforced, and changed. These must be explicit and transparently codified roles of the governance body and must also detail under what circumstances any of these roles can be delegated and/or subcontracted to specialists.

Accordingly, we recommend that the roles include definition of processes and/or rules for the establishment, oversight, enforcement, and change of:

  • Stakeholder mapping, engagement and representation
  • Goal setting
  • Defining success criteria (across technical, socio-economic, and environmental domains)
  • Monitoring, reporting, and verification (MRV)
  • Change management
  • Communications
  • Dispute resolution
  • Liability and redress
  • Any formal responsibilities towards meeting cross-economy policy goals such as:
    • Net zero
    • Industrial strategy
    • Social policy

We further recommend that roles are included to oversee – where not already covered by another body in the broader environment – the definition of processes and/or rules for the establishment, oversight, enforcement, and change of:

  • Data rights
  • Adjacent agreements (e.g. membership contracts / terms of use)
  • Guidelines (e.g. antitrust, fairness, transparency, publishing)

Finally, we suggest that the governance body should have an active and transparent role in defining formal and informal relationships with adjacent bodies in the energy sector and beyond. This role may include jointly establishing and maintaining:

  • Channels of communication 
  • Obligations on reporting or information sharing
  • Formal processes and roles for engagement (e.g. assignation of ‘observer status’ in certain governance fora)
  • Approaches to sharing and/or allocating roles when approaching shared issues 
  • Appropriate accountability structures
  • Approaches to reduce forum proliferation (and ensuring associated fair access to governance fora for smaller organisations with less resource)
  • Approaches to contributing or responding to cross-sectoral policy and regulatory developments in a joined up manner.

The suggested roles above imply a set of associated responsibilities which are outlined in the sub-bullets. Many of these responsibilities are likely to constitute oversight rather than design/delivery, allowing for subcontracting arrangements to take place where required. We suggest that a governance body also holds responsibilities for the oversight of:

  • User needs identification, testing, and convening
  • Assessing and measuring impact across socio-economic, environmental, and technical domains
  • Where impacts are undesirable, performing impact mitigation 
  • Ensuring cohesion (of procedural, legal, technical approaches)

Weaving through all our suggestions is the principle that key roles and responsibilities explicitly include reference to the wider socio-technical landscape. We suggest that codifying these responsibilities would provide an improved balance between technical, social, and operational elements of governance. While not all areas of responsibility need to be undertaken directly by a proposed governance body (e.g. it may be possible to subcontract an appropriate body to support stakeholder engagement) we strongly suggest that the following (non-exhaustive) points would benefit from more formalised oversight, governance integration, and appropriate resourcing : 

  • Data rights and surrounding legal structures governing the exchange of data and associated intellectual property
  • Stakeholder engagement and communications
  • Cross-sector, policy and regulatory input/coordination (including social, economic, and environmental factors)

Applications

Applications must be designed with governability as a requirement. The data governance in play will affect or even mandate the way functions such as access control, permissions, licensing, data catalogue publication, metadata provision, record-keeping and logging are implemented. These requirements can be fundamental to systems architecture choices, making them  much harder to retrofit than to design in from the outset. 

The technical infrastructure advisory group exists to collaboratively define, agree on and publish the requirements for applications under governance

Integration

Regarding data sharing, we recommend considering:

  • Taking an open standards-based, transparent, market-wide framework approach to allow for the rapid scalability of secure access to data
  • Mandating specific technical security standards. These must be agile to respond to changing security requirements and threats.
    • An example is FAPI, which mandates specific security choices with sufficient implementation flexibility to be practical in most environments.
    • Open ID
    • OAuth
  • Using available web standards developers are familiar with to build 
  • Making APIs explainable to machines (i.e. Open API spec when describing an API being registered on the registry – this can generate the code in most languages)
  • Data access. There can be an assumption that the data holder controls data access, and while technically they do, in a scheme they sign up to rules that may require them to release the data. They therefore cannot make ad hoc decisions that give access to a data user (company 1) but not give access to another data user (company 2) who fit the same criteria within the scheme. 
  • Describing data access rules as part of specification for data sharing. Therefore participants can understand on what terms they get the data. IB1 recommends the governance function provides oversight to ensure it is not abused (e.g. anticompetitive practices)
  • Mandatory access control, which should be applied equally (unless otherwise noted)
  • Defining data standards that align with common requirements across schemes, such as for data catalogues, licence representations, permission, assurance or provenance. 
  • Defining metadata standards – and publishing them openly. As mentioned in IB1’s response to Ofgem’s Updates to data best practice guidance, we supported requiring the use of Dublin Core as a Core Standard. We agreed with Ofgem’s recommendation for publishing metadata using the Dublin Core standard, but we also suggested further refining it to specify the Dublin Core-based Data Catalog Vocabulary (DCAT), which is supported by the main data catalogue platforms and is the metadata standard adopted for all EU public sector data publication.
  • Considering how an interoperable identity mechanism may be possible across different schemes. We think this should not be a centralised identity, but a mechanism which can enable cross scheme identity verification. 
  • Building on the work around machine readable licensing terms
  • Developing standards on monitoring, auditing, logging (tools which can look across schemes make sure data is not leaking out of them)
  • Starting with conceptual alignment for interoperability (i.e. data field and protocol alignment) and then moving on to technical alignment

Physical components 

We note there is a risk of unequal access to the benefits of digitalisation and potential smart services if we do not fully understand and address the challenges known to exist in the physical infrastructure within the energy system including smart meters. Smart metering reporting can be inaccurate, offline, and in 2024 Energy UK confirmed there is a regional divide because of the way meters send usage data back to suppliers. Acknowledging and addressing this will reduce the risk of baking in non-equal access to the benefits of digitalisation and smart services, and may unintentionally miss out key beneficiaries. 

3. How can we ensure effective governance and collaboration across the sector to leverage benefits of digitalisation? 

Open Energy is an example of an energy sector data sharing programme with a governance process and sector engagement. Through IB1’s UKRI Modernising Energy Data Access competition-winning programme Open Energy, we identified and articulated the need to make it straightforward to find, access and share energy data. Through three phases, we convened 100s of organisations, 500+ public webinar attendees, and over 80 Steering and Advisory Group members to develop operational services for search and access control that are now live and market-facing, and have set the foundations for an Energy Trust Framework. 

Open Energy makes it easy to search (via https://openenergy.org.uk), discover, access and securely share energy data using a Trust Framework and any Schemes which are built within the Trust Framework context. It covers Open Data, commercial Shared Data with pre-authorised access controls, and commercial Shared Data where access requires end-user permission/consent.

As mentioned in our response to Ofgem’s consultation on DSI governance we suggested that Open Energy be formally considered as a vehicle for the governance of the Trust Framework node. Open Energy was funded by public money and has been specifically developed for this purpose using a combination of radically transparent methods of open working, extensive consultation with stakeholders, and the input of specific domain expertise from energy industry, academic, and Open Banking specialists. IB1 has already been involved in the DSI as the governance advisory partner, and is involved in the MVP through inputting into the pilot development, and use case exploration. It already has DNO and energy sector members. 

4. Are there any key areas of consideration missing from the capability requirements? 

Key areas of consideration:

  • Drafting design principles which can be aligned around – and consistent with DSI and the energy smart data scheme (DESNZ) proposed principles
  • Legal and licensing – including standard legal data licences, and applying data sensitivity classes to datasets identified
  • Policy: Identifying potential policy implications, blockers, or interventions
  • Interoperability: IB1 strongly recommends taking a joined up approach which is interoperable with initiatives across the economy. We suggest the solution define relationships with adjacent bodies in the energy sector and beyond to enable cross sector interoperability.
  • An avenue to engage with security stakeholders – we recommend working closely with NPSA and NCSC to ensure their feedback is incorporated.
  • Openly published documentation – financial, legal, operational to ensure it is clear what is required to become a scheme participant.
  • Clear area where strategy and direction are discussed and implemented. Currently the use of data for strategic direction is not explicit. See top layer of the ArchiMate specification (fundamental to DSI design approach)
5. What existing projects and activities are supporting, or acting contrary to delivering these capabilities? 

Current existing projects supporting the above capabilities:

Open Energy is an example of an energy sector data sharing programme with a governance process and sector engagement (detailed in question 3)

Data Sharing Infrastructure

A DSI is a collection of open-source software packages that enables data sharing. As an open-source solution, the burden of take-up and use of the DSI for sector participants is lessened compared to use of proprietary technologies. However, the end design (once established) of a DSI may incorporate commonly used and generally available proprietary software.

Credo+

A digital twin platform for climate change adaptation that improves system-wide resilience across infrastructure networks.

6. Are there any digitalisation related activities or initiatives needed to support the transition to clean power that you think are strategically important? 

Open Energy https://ib1.org/energy/ provides three services:

1. Community: an expert network of professionals – the IB1 Constellation

2. Governance: co-design of data sharing Schemes using our Icebreaking process

3. Trust Services: Search services and Energy Sector Trust Framework for Scheme implementation

Trust in data is essential to investment and use. Our approach helps drive the design, implementation and adoption of open standards to create assurable data flows between organisations. This enables verifiable Open Data and pre-authorised Shared Data (including smart data where consent/permission is required).

As the data sharing economy develops in a manner which is increasingly fluid and cross-sector there is an ongoing need for policy and regulatory development which horizon-scans, assesses, and defines responsibility for addressing different aspects of the regulatory landscape. Providing this form of policy and regulatory join-up presents essential support to the incentivising and de-risking of investment in strategic sectors. 

Other initiatives to be aware of include:

7. Of the activities or initiatives provided in answer to question six, what outcome and capability does that relate to?

Open Energy primarily relates to governance and operating model, but as detailed above has an impact on all of the outcomes and capabilities.