IB1 response to Ofgem’s Enhancing asset visibility: DNO options consultation

This is Icebreaker One’s response to Ofgem’s Enhancing asset visibility: Distribution Network Operator options 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.

Consultation response:

Q1. Do you agree with our case for change and that policy intervention is needed for DNO asset registration? 

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. IB1 creates and runs programmes to reduce barriers and costs to finding, accessing, using, and sharing data, which will ultimately reduce costs for consumers.

IB1 supports better data on assets, and data sharing between DNOs, suppliers, and other organisations who need to understand headroom capacity and demand. We note there is a need to distinguish clearly between asset type(s) and capacity at the initial phase. In future, better data on asset performance and behaviours would be helpful to ensure this initiative can be most useful – e.g. capacity is not static with flexibility assets in play.

Q2. Do you agree with our priority use cases, and are there any other use cases we should consider? 

We agree with Ofgem’s identified use cases, however, we note that the data end user within the priority (regulated entities) and further use cases may have very different needs and data sharing instruments available. As mentioned in IB1’s response to Ofgem’s Energy digitalisation governance: architectural coordination letter, we propose that an industry-independent coordination body helps coordinate a flexible energy system. Data sharing at scale requires the separation of ‘the data’ from its governance and the technology used to host and transfer it.

We encourage the inclusion of potential ‘further users’ as a part of a governance process from the outset to ensure a solution suits their needs and does not exclude the solution from expanding past the priority use cases. We advocate for starting with a use case with external (non-regulated / less digitally mature) players, then a B2B DNO focussed use case to make subsequent use cases easier and less likely to inadvertently produce blockers. Leaving local authority use cases for “later” risks local planning and investment being disconnected from the physical reality of supply. A key use case to consider is data centre energy demand, which reinforces the need to urgently prioritise local authority use cases. 

IB1 has worked on a few other relevant collaborative use cases in this area, including:

• Getting small scale assets / flex services online (Open Energy Future of heating –  Residential Property Developer use case).
• How data sharing can be used to better understand how to maintain the assets already in place. IB1, SSEN-Transmission, IBM, and Palantir on a Strategic Innovation Fund programme, NIMBUS, which focussed on granular weather data and network innovation to build for sustainability. See the Discovery Phase report and the Alpha Phase report.
• IB1 partnered with SSEN-Transmission, Olsights, Mapstand, SGN, and National Grid on a Strategic Innovation Fund programme REACT to address current planning and future planning for generation siting. See the Discovery Phase report, and the Alpha Phase report. This use case reinforces the need to know other assets on grid to aid grid capacity understanding and future planning.

Q3. Are there any other policy or industry initiatives that we should seek to align with? 

IB1 encourages seeking alignment with:

• Open Energy – run by IB1, has expertise articulating use cases, and designing and quickly implementing shared data schemes with appropriate governance – includes legal agreements, assurance and technical specifications – in collaboration with stakeholders.
• Connections end-to-end review: updated proposals and next steps​ consultation. To what extent are external entities interested in assets as opposed to capabilities?
• Consumer Consent Solution, currently being developed, designed and delivered by RECCo Ltd, as small scale asset data is in scope (unless this programme is using another lawful basis for processing, this would need to be articulated clearly).

Q4. Do you agree with the scope proposed for assets, data, entities, and data stages, should anything else be considered?

As mentioned above, there needs to be a defined governance process for considering and agreeing upon the proposed scope for assets, data, entities, and data stages. 

IB1 would highlight there is a need to identify current data uses, and to be flexible enough to incorporate new ones as they emerge, to establish both the scope and the data quality and completeness requirements for asset information. For example, there is likely to be a difference between the DNOs’ data quality requirements at the lowest end of the asset capacity scale and the data quality requirements for users like councils, planners, microgrid/heat network assessors etc. Additionally if this asset data feeds into the flex market, missing or incorrect installations could lead to financial consequences for asset owners. 

While not in scope for the initial phase of development, our suggestion for future development would be the ability to transfer data on asset profiles/behaviours. This would be incredibly useful to better understand how flexible assets actually behave and their real-life impact, for example on network capacity.

Q5. Do you agree with our enablers and dependencies, and are there any others we should consider? 

IB1 would add on the lawful basis for processing – if not using consent then clarify on what lawful basis the register operates under. It would also help to understand how any data protection risks potentially associated with the register will be managed and governed. It is not currently clear how the lawful basis distinguishes between household and business (including microbusiness/SME) assets. This will interact with the Data (Use and Access) Act for businesses and requires clarification.

Q6. Do you have any suggestions for collecting legacy data, or for integration of other datasets into DNO registers? 

No comment. 

Q7. Do you agree with the advantages and disadvantages for the proposed options, are there others or any wider aspects we should consider? 

Wider aspects to consider on Option 2:

• May require upskilling/investment by DNOs, with an opportunity to subcontract if they are lacking skills in-house. This is a low risk if data standards are agreed through a governance process.
• As mentioned in Question 2, this initiative must be mindful of restricting use cases to regulated entities first which may make it harder for other users in the future. 
• As there is demand by non-regulated users for asset data now, there may be a benefit to spinning up a scheme in the short frame which is ready to integrate with DSI but has governance to engage a wider range of end users at the start. 
• This option has the highest potential to scale as it does not bottleneck in a single database/register, and provide utility for a wide range of use cases. 

Wider aspects to consider on Option 3:

• New databases and portals struggle to scale for a wide array of use cases as infrastructure systems are being digitalised in a decentralised and distributed way
• This option gives liability to a central entity versus distributed liability to DNOs
• May conflict with current DNO autonomy in deciding what data to publish and how to publish it, guided by DBPG. In particular may lead to a lowest-common-denominator approach that disincentivises DNOs from publishing otherwise-useful data that isn’t needed by the central register

Wider aspects to consider on Option 4:

• Operating a flexible market is a significantly different use case from the ones articulated above – expanding existing initiatives may result in a loss of focus on the original challenge it was solving
• Suggest a focus on harmonisation rather than making FMAR even more complex.

Q8. Are there any changes you would make to any of the proposed options to enhance them? 

IB1 would emphasise the need for a determination on what body would govern the standards for Option 2, and how stakeholder engagement beyond the regulated entities will be managed. There is a need to convene stakeholders within and outside the industry to ensure it is fair and accessible as well as implementable by the data holders. 

Q9. Have we missed or discounted any options that you think are suitable? In particular, for option 4 is there a preferable alternative to FMAR for expansion, and why? 

No Comment. 

Q10. Which option is your preferred option, and why?

IB1 would encourage Option 2, as it is the fastest to market and lowest cost, and can be decoupled from other initiatives, so can run in parallel and at pace. We would suggest this happens through a trial ‘scheme’ developed as and will be DSI integration ready for when DSI is ready to support asset data sharing. 

This option also has the opportunity to have the simplest governance (only DNO liabilities) – although this needs defining – as referenced in Question 8.