This is Icebreaker One’s response to Ofgem’s Data Domain Coordinators role guidance consultation. It can be published openly.

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. 

Thank you for considering our submission.

Consultation response:

The Icebreaker One (IB1) NOVA principles – Networked, Open, Verifiable Architecture – guide our approach to data governance and associated responsibilities within the energy data landscape. This approach recognises that trusted data sharing requires more than technical infrastructure: it requires coordinated governance, clear rights and responsibilities, interoperable systems, and transparent, adaptive rules. This is particularly relevant to energy, where data is distributed across many organisations and across sector/vector boundaries, and where unlocking flexibility and investment depends on trusted interactions between many market participants with different characteristics. NOVA guides us to consider architecture supporting trusted, permissioned and auditable data flows in a manner that reduces friction, supports open participation, and encourages scalable reuse of data and data-sharing infrastructure. It provides the foundation for aligning technical, legal, policy and commercial requirements needed to turn fragmented energy data into a trusted, usable and investable resource within a thriving wider digital ecosystem.

Question 1: Do the data types in scope for each domain provide a complete representation of each domain?

The proposed approach and associated groupings have internal consistency. We agree that data requirements will evolve as the energy system and new use cases develop. The framework should ensure it retains sufficient flexibility to amend and expand domain scopes over time. A Digitalisation Coordinator could identify and address potential blind spots and cross-domain dependencies that may not appear when domains are defined primarily by data origination. 

We note that the current approach to data domains does not always consider data journeys, dependencies and how data is used in practice, including beyond the boundaries of the traditional energy system. This creates blind spots to energy-relevant data that exert critical influences on the practical running of the sector, particularly: 1) economic and market data, 2) demographic and behavioural data, 3) weather, climate and environmental data, 4) carbon reduction and net zero data, and 5) security data. It is difficult to provide a comprehensive set of suggestions as to how data under these categories are incorporated, as they likely extend beyond current domain categories as well as influencing the four existing domains. Categories such as carbon, weather and security data, for example, implicate all domains. 

Gaps in specific domains are addressed under Q3.

Question 2: Which domain is best placed to coordinate meter asset data, considering the use cases the data supports, governance arrangements and cross-domain interoperability? Please explain your reasoning.

We align with the position that there is significant potential for crossover between consumer and metering domains around meter asset data and note that this is reflected clearly when use cases or data journeys are considered. Whichever Domain Coordinators are assigned to lead, communication and alignment between associated domains will be essential. We suggest that this may be a role that the Digitalisation Coordinator is positioned to oversee as, in addition to this particular issue, it is likely that all domains will evolve over time and other remit boundaries are likely to come into question. The Digitalisation Coordinator could apply a consistent approach to identifying and managing where this occurs. One significant consideration when assigning the lead coordinator is the question of rights over the data. 

As domains and ecosystems evolve and become increasingly complex (e.g. due to AI application), the use cases and data journeys, rights and lawful bases for data access, and requirements for cross-domain interoperability should be considered. Identifying long-term data rights is critical to operational resilience. We suggest that the Digitalisation Coordinator may play a role in exploring this space, connecting with actors outside the sector who may use the data, and understanding data journeys / use cases which cross domain boundaries. This position does not mean that we advocate for a coordinator to overstep or take back power from the domains; rather, it is a practical note that such a body provides a useful vehicle for approaching inter-domain concerns such as those illustrated in this consultation.

Question 3: Are there any additional data types that should be included, or data types that could sit in alternative domains than their categorisation in Table 1?

We note several gaps and areas requiring clarity. Reflecting our position in Q1, five categories of data appear to be largely absent from the current model: 1) economic and market data, 2) demographic and behavioural data, 3) weather, climate and environmental data, 4) carbon reduction and net zero data, and 5) security data. We acknowledge that the four domains are framed as a starting point, therefore omissions are anticipated. However, given the importance of categories outlined above to energy system function and policy goals, we would welcome clarity from Ofgem as to the intended approach to integrating these areas in future – either within the existing four domains or in forming supplementary domains, and the associated time span for decisions.

Additional gaps within the current domain structure are outlined below:

Core energy system data: 

• We suggest the core system domain currently lacks acknowledgement of market/economic data pertinent to system operation and decision-making that informs this. While some of this is incorporated in balancing and settlement, the current phrasing risks interpretation as a primarily technical matter. Decisions pertaining to whole-of-market factors such as grid mix, generation patterns, fuel prices, interconnection and international markets are also important and do not yet have a clear home. 

Customer data domain: 

• The differentiations between data pertaining to domestic and non-domestic consumers are not always clear. While definitions may be intentionally inclusive at the current stage, there are differences which will require future clarification.
• Secondly, geographic, behavioural and demographic information – informing asset and energy use patterns, customer interactions, product and service development – is currently missing. While this data may be seen as supplementary to purely energy system functions, it is a key part of the economic landscape of the sector and has practical implications in regulation, for example reflected in Ofgem’s consultation regarding potential innovation exemptions to the Universal Service Obligation. 

Behind-the-meter asset domain: 

• Granular data concerning customer and asset behaviour and forecasting is missing from the behind-the-meter domain, which should be acknowledged under the operational data bullet. We note that providers of this data may sit outside the current regulated sector, however they are implicated in the SSES programme and critical to the achievement of policy goals for digitally-enabled system flexibility, DSO transition (e.g. localised balancing) and grid decarbonisation.

Question 4: Is the purpose of Domain Coordinators clear and sufficiently explained to guide delivery and accountability? If not, where is additional detail required? 

There is sufficient explanation to guide the purpose of the Domain Coordinators at a general level. Areas of technical, engagement,  governance and operational responsibility are clearly identified. We support the suggestion that outputs for each Domain Coordinator – data domain definition, stakeholder map and engagement strategy, and delivery plan – are published openly where possible. We also note that the current content does not explicitly include legal and licensing within technical delivery and accountability, and suggest that this must be specifically named; legal interoperability is a key driver for data liquidity which is often overlooked.

Question 5: Which areas of responsibility should transfer from Domain Coordinators to the future digitalisation coordination function? How could the transition be managed to avoid any duplication or gaps?

As flagged in Q1, we note a number of cross-domain data which currently do not have a clear home. We encourage Ofgem to consider the relationship of these horizontal data ecosystems to the four data domains as well as their relationship to the Digitalisation Coordinator.

Beyond this, we agree with the areas proposed in 3.13 for consideration of transfer to the Digitalisation Coordinator. We note that other potential areas of handover could include:

• Oversight of cross-domain engagement programmes and approaches to inclusion
• Identification and coordination of cross-domain use case development
• Identification and upward reporting of the emergence of new data domains and/or changes to existing domains (this is potentially part of the suggested horizon scan function)
• Coordinate cross-domain approaches/standards for licensing (as part of technical coordination) and integration thereof with the DSI
• Coordinate the application and interpretation of data rights across domains
• Coordinate Trust Framework interoperability within a federated landscape.

Question 6: Do you have views on the most appropriate regulatory mechanism for overseeing and enforcing the Domain Coordinators role?

Coordinators have significant influence over how data is defined, accessed, exchanged and governed, including through the development and maintenance of standards. All coordinators also lead development of infrastructure, platforms or work programmes supporting data exchange (DSI and CCS primarily, with Elexon’s DIP and future FMAR work of additional note). This creates a concentration of influence integrated across the data ecosystem in each domain. Given the breadth of influence that a Domain Coordinators have, appropriate regulatory oversight and safeguards will be important to ensure that this role is exercised transparently, proportionately and in the interests of the wider energy system – including decarbonisation goals and consumer outcomes. While we understand that Domain Coordinator embeddedness may create efficiencies, we suggest that it strengthens the argument for the Digitalisation Coordinator to hold a higher level of legal and organisational neutrality, as well as the behavioural neutrality expected from Domain Coordinators. We anticipate this will offer the advantage of an additional check/balance supporting regulatory controls.

We recognise – and support – that the data itself will remain decentralised with existing data holders. We suggest that this principle is formally written into oversight programmes for the coordinators, including the Digitalisation Coordinator.

We also recommend that safeguards outlined in the consultation must be complemented by explicit requirements around conflict of interest management, transparency, accountability, and separation of functions. This would help mitigate the risk of a coordinator inadvertently becoming a gatekeeper to data, standards or infrastructure. We suggest that Ofgem draws a clear distinction between where organisations are performing pre-existing market functions and where they are performing Domain Coordination functions – particularly if NESO is to be governed under existing Ofgem Expectations. This could be complemented by KPIs which are designed to evidence collaborative, domain-level improvement in addition to specific organisational deliverables. 

For governance of all Coordinators, we raise for consideration the potential for creation of a new, bounded licence type to support direct regulatory control. There is precedent for the establishment of defined, purpose-specific licences through the creation of the Smart Meter Communication Licence. As sector digitalisation evolves, considering a new purpose-limited type of licence for data and digital functions may hold advantages. However, this is not an area which has been subject to much exploration within existing policy, industry, or academic literature, suggesting that it may take time and resources to explore or establish. 

Question 7: Do you agree with the proposed funding approach for the Domain Coordinators role? If not, what alternative approach should be considered?

We support the proposed approach and nuance between different organisation types taking on Domain Coordinators roles. If investment in particular domains requires additional focus, funding models may need to evolve. Likewise, oversight from Ofgem will be required to ensure that Coordinators provide comparable value for money, even if responsibilities are non-identical. In considering value for money, we encourage Ofgem to measure contributions towards decarbonisation and consumer value in addition to financial metrics.

Question 8: What specific KPIs or success measures for digitalisation progress could be included to measure success of the Domain Coordinators role within each domain?

We broadly agree with the type of KPIs outlined in section 3.19 . However, these are only a baseline approach and we envisage them developing with more clarity as the coordinators take up work in this space. As outlined above, it is critical for KPIs to be tied to measurable progress at the domain level, within reason and relevant to the appropriate context, rather than relying solely on outputs delivered by the coordinating organisation. 

Areas in which KPIs could benefit from more specificity include:

• Ensuring there is an accessible feedback process for logging changes to the domain; for example, notifying the coordinator of new data assets or asset types.
• Publishing the criteria by which data quality is determined and assessed.
• Assessing balance within the engagement sphere to ensure an even spread of perspectives is included; ‘strong and active engagement’ does not necessarily require this to be open or representative.
• A commitment to regular review/challenge of governance arrangements to empower the Coordinators to act with agility.
• KPIs assessing the impact of Coordinator activity on decarbonisation and delivering customer value would be useful for tracking how digital progress interacts with wider sector objectives.

Question 9: Do you agree with the proposed governance decision-making, reporting and oversight arrangements for Domain Coordinators? Are these clear and proportionate? If not, what should be changed?

On decision-making:

• Evidencing engagement is an important part of these requirements. Reflecting our comments in Q12-14, there are certain gaps in the engagement model which require attention prior to relying on engagement as a source of validation.
• We support the proposed position to work with existing code, license or governance arrangements where possible. We query how the Domain Coordinators will interact with these mechanisms where remits exceed the definition of the data domain – for example, where using existing avenues may engage stakeholders or surface use cases that extend beyond one individual domain. Defining the approach to these instances will also be relevant for defining the role and remit of the future Digitalisation Coordinator.
• We encourage openly published meeting minutes and decisions wherever possible, alongside quarterly reporting to named stakeholders. The quarterly reporting may be in more depth or surface higher sensitivity information. 
• Decisions referred to the Digitalisation Board under 4.5 may implicate the Digitalisation Coordinator in future.

On quarterly reporting:

• We encourage open publication of reports wherever possible, with clear rules as to where information is redacted or edited for public consumption if it is sensitive. Consistent application of these rules is helpful for supporting a coherent approach to transparency and disclosure in a multi-actor system.

Upward reporting and decision-making:

• We agree that the role of the Digitisation Delivery Group (DDG) and relationship to Domain Coordinators is clear and appropriate. 
• References to the future role of the Digitalisation Coordinator providing a preparatory and advisory function match our expectations of the role and its utility in providing a space and resource for balanced consideration of materials for advisory purposes.

Question 10: Do you agree with the proposed technical requirements of Domain Coordinators, including data standards, data quality, domain definition and access to data? If not, which responsibilities should be amended and how?

We agree with the proposed technical requirements of the Domain Coordinators. However, we believe that a distinction should be made between the function of setting requirements and supporting outcomes, and that of detailed management arrangements within individual organisations, with the latter remaining out of scope for the Domain Coordinators. An outcomes-based approach would allow organisations to set requirements without prescribing the detailed arrangements that implement requirements. This would provide organisations with the flexibility to determine the most appropriate arrangements for their individual circumstances, while maintaining clear focus on achieving intended outcomes. 

Data Access

We support the proposed responsibility for Domain Coordinators to establish standardised access processes, with the additional expectation that the DSI should provide the mechanisms of access control when possible. We recommend that the guidance makes clear that Domain Coordinators are responsible for the identity verification, credentialing and licensing policies that are necessary to enact data access controls within their domain, with coordination across domains to ensure interoperability and streamline processes for data users.

Data Standards

The development and maintenance of a data standards catalogue should be represented through the DSI. We also encourage the use of open standards within the data standards catalogue rather than limiting the approach to standards that already exist. This should be accompanied by the overarching coordination function to promote interoperability between standards across the wider ecosystem. Without this cross-domain perspective, there is risk that Domain Coordinators develop standards that only work effectively within individual domains and not across domains.

Data Quality

We support the principle that the Domain Coordinators should establish expectations around data quality, but metrics and requirements should be informed by actual use cases. These quality metrics are context dependent and datasets that are fit for one purpose may not be adequate for another. We also note that many use cases are cross-domain, providing value for the overarching coordination function to examine quality across domains.

Digital Infrastructure Requirements

Requirements for digital infrastructure should similarly be developed through engagement and informed by use cases, supporting cross-domain interoperability. Additionally, while we understand the transfer of 5.24 and 5.25 responsibilities to the Digitalisation Coordinator function once established, domain-specific issues will likely need input from Domain Coordinators. 

Identification and Development of Use Cases

We agree that identifying use cases should be a critical component of the Domain Coordinator role. This responsibility should be transparent, including the logging and publication of identified use cases where appropriate. This provides visibility of the evidence base informing priorities and technical requirements. The methodology for developing and prioritising use cases should be based on genuine use cases and user needs rather than just dataset availability. This distinction avoids designing a system around only existing data rather than the outcomes that data is intended to enable. The Digitalisation Coordinator will likely have an important role in identifying and supporting use cases that extend across domain boundaries, supporting a more interoperable data ecosystem. 

Question 11: Are any key technical requirements missing, unclear, not proportionate or not deliverable in practice?

Currently, the consultation does not address standardisation of licenses as part of the technical components of delivery. This is a critical element of interoperability as, ultimately, a technically interoperable data landscape can still be limited by legal interoperability challenges that slow or stop dataset combination for the delivery of real use cases. We strongly recommend that license identification and standardisation is included in the technical remit for Domain Coordinators, supported by interaction with the Digitalisation Coordinator to enable license interoperability across domains and translation to license representations within relevant Digital Infrastructure. Where multi-party preemptive licenses are developed, we suggest that the Digitalisation Coordinator takes an oversight role to support consistency of approach throughout the sector and promote cross-sector interoperability.

We separately note that this consultation implies Domain Coordinators will take on an active role in shaping domain agreements – e.g. on standards adoption – that will then be codified into the DSI to accelerate data exchange. Formal technical and governance relationships between data Domain Coordinators and the DSI are yet to be fully established. We suggest that both data Domain Coordinators and the Digitalisation Coordinator establish and transparently document their relationships to digital infrastructure projects. This is particularly important where functions are held by the same body.

Question 12: Do you agree with the proposed engagement requirements of Domain Coordinators, including strategic engagement, technical engagement, and engagement of consumer groups and smaller organisations? If not, which requirements should be amended and how?

We support positioning engagement as a key responsibility for the Domain Coordinators. We also support consideration of engagement including technical, consumer, small organisation, and participant groups. However, certain aspects of the engagement requirements would benefit from additional robustness and prioritisation of context-specific methods to avoid over-reach or fatigue in a landscape with high existing engagement demands.

We note that meaningful engagement must be balanced with the potential for engagement fatigue, which has already been raised within the sector around digital developments. It is particularly significant for small or non-profit organisations with fewer available resources and time; engagement structures must be designed sensitively to avoid unintentional exclusion of these actors. We suggest that a clear plan for inclusion is necessary and that there is benefit to this being openly published. In future, this may be something requiring oversight from the Digitalisation Coordinator to support consistency and promote efficiencies that can reduce risk of engagement fatigue and/or flexible response to periods of high engagement demand. In parallel, we note that good stakeholder engagement practice – e.g. evidenced through IB1’s DAFNI-DINI programme – requires circularity; programmes in which participants understand the value and outcomes of their engagement are perceived more favourably than those which are considered to be more one-sided or extractive.

We also note that engagement approaches outlined do not explicitly name end users as stakeholders that should be included in engagement processes, beyond consumer groups. We suggest using a use case lens for stakeholder mapping and engagement can be constructive for ensuring representation from the full data value chain.

Finally, we suggest that Domain Coordinators may find achieving a balance between existing and supplementary routes an area requiring sensitive handling, particularly to ensure that there are not discrepancies or preferences unintentionally applied to various settings. We encourage Domain Coordinators to consider questions such as:

• Where supplementary engagement groups are constructed, how will these interact with existing forums? Are discussions in either group privileged in any way (e.g. information asymmetry, powerful voices in the room, visibility of what the other group has discussed or decided)?
• How will participants be given appropriate voices and opportunities? 
• How will disagreements be handled and/or reported between groups?
• Are there different weightings given to decisions made within or between groups? How might this interact with existing groups that have set governance and voting structures? 
• How will competing interests and priorities be balanced if discussions are separate?

This response is not to suggest that the above challenges are insurmountable, however they do flag the risk of creating unintentional asymmetries or imbalances that have potential to undermine trust and legitimacy of engagement processes without adequate consideration.

Question 13: Which strategic, technical, consumer group or smaller organisation stakeholders or stakeholder groups should be engaged for each domain?

As noted in Q12, we advocate a use case lens to approach engagement across the data value chain. This can also help reduce engagement fatigue by targeting engagement strategies to the most relevant participants informed by context. Without further context it is difficult to provide a comprehensive response. IB1 is happy to discuss our approach to stakeholder mapping and engagement separately if useful to support this consultation.

Question 14: Are any key engagement requirements missing, unclear, not proportionate or not deliverable in practice?

Reflecting Q12, we would welcome further detail and/or guidance provided to Domain Coordinators about how to set up, govern, and communicate between engagement tracks happening separately to pre-established routes.

Question 15: Do you agree with the proposed governance requirements of Domain Coordinators including requirements to participate in governance forums and operational reporting? If not, which responsibilities should be amended?

We support the proposed approach which appears proportional, deliverable and appropriate to the short-medium term. We acknowledge that approaches may require adaptation over time. We suggest that consumer outcomes and decarbonisation are explicitly included in reporting as topics for monitoring and reporting regarding the strategic direction and impact of Domain Coordinator activity. We also recommend that these outcomes are formally included under the heading ‘Track digitalisation progress’ (7.17-7.20). 

Question 16: Are any key governance requirements missing, unclear, not proportionate or not deliverable in practice?

See Q15.