Consultation outcome

Electric vehicle smart charging consultation: summary of responses

Updated 21 December 2021

Executive Summary

Introduction

Electric vehicles (EVs) offer new opportunities for consumers to be part of a smarter and more flexible electricity system. Smart charging, for example during off-peak periods when electricity demand is low, means consumers can benefit from cheaper electricity and avoids triggering unnecessary network reinforcement. Charging of EVs can also be shifted to periods where there is plentiful renewable electricity generation and support system operation by providing services to the electricity grid. Smart charging of EVs plays an important role in driving the transition to a smarter and more flexible energy system. Government is already taking action to drive this transition as set out in its smart systems and flexibility plan and 2018 progress update.

The ‘Automated and electric vehicles (AEV) act 2018’ gives government the powers through secondary legislation, to mandate that all chargepoints sold or installed in the UK have smart functionality. Government is planning to take forward these powers to help ensure these vital building blocks of a smart system are in place from an early stage. Government has now consulted on taking forward powers under the AEV Act and is considering the next steps.

Electric Vehicle Smart Charging Consultation

The ‘Electric vehicle smart charging consultation’ opened on 15 July 2019 and closed on 7 October 2019. Government consulted businesses and individuals on implementing smart charging requirements under the ‘Automated and electric vehicles act 2018’, with particular consideration of important issues like cyber security and interoperability.

The aim of the public consultation was to outline the government’s approach and objectives for smart charging of EVs (chapter 1); seek views on the first phase of regulations (“phase 1”) (chapter 2); gather evidence on a second phase for a long-term solution (“phase 2”), which we believe will be required by 2025 (chapter 3); and gather evidence on how best to use the AEV act power on the transmission of chargepoint data (chapter 4).

In chapter 1, we set out that the government’s overall aim for smart charging is to maximise the use of smart charging technologies to benefit both consumers and the electricity system, whilst supporting the transition to EVs. To meet this aim we believe we need to encourage consumer uptake and innovation, which is why we propose that these are 2 key government objectives. However, without coordination and regulation, the smart charging market could evolve in a direction that has negative consequences for electricity grid stability and consumer protection – our third and fourth proposed objectives.

Chapter 2 described the approach for phase one in detail. We proposed to use the powers under section 15 of the AEV Act to mandate that new non-public chargepoints will be required to have smart functionality, and that they will have to meet device-level requirements, including on cyber security and smart interoperability. In the consultation, interoperability or smart interoperability refers to a consumer being able to switch chargepoint operator without the chargepoint losing its smart charging functions and without a visit to the premises to restore it.

To deliver consistent minimum standards, we proposed that the regulations will ordinarily require compliance with elements of the British Standards Institution (BSI) standards for energy smart appliances (ESAs) (publicly available specification (PAS)1878). This standard will be technically compatible with both the GB smart metering system and existing international standards. This standard is currently under development, through an industry-led process. We proposed that compliance with the standards would be mandatory, except where organisations can prove that their chargepoints comply with suitable equivalent standards that meet the same outcomes.

Chapter 3 was a call for evidence on phase 2 that sought views on a long-term approach for delivering smart charging, including operational requirements that could help deliver government’s objectives. It sought views on the need for a decision point to be between 2020 and 2022, to allow time to gather evidence whilst also leaving enough time for an approach to be implemented by 2025. We proposed that the same objectives as set out in chapter 1 should be used as criteria to determine the best solution for phase two. The GB smart meter system was put forward as the current lead option, and views were sought on this approach and alternative solutions.

Chapter 4 was a call for evidence on whether government should introduce regulations under section 14 of the AEV act, which relates to the transmission of chargepoint data.

Summary of responses overview

This consultation received 129 responses. A breakdown of respondent by type is included in table 1. This document is a summary of responses only. It sets out the government’s intended next steps to progress the policy issues within the smart charging consultation and summarises the views of respondents for each question. It does not include a government policy response to the smart charging consultation.

When reading this summary of responses, please note that:

• respondents used either an online response form, a downloaded response form, or wrote their responses freeform, not all respondents answered every question
• government held several stakeholder events throughout the consultation period, any views expressed just at these events are not summarised in this document, only written responses have been included
• given the large volume of responses and questions, this document doesn’t capture every view each respondent expressed but aims to summarise the more frequently mentioned points
• for static “agree/disagree” questions, the views of some groups of respondents has been noted
• the approximate number of respondents who expressed a particular view is written in brackets within each sentence

The aim and objectives proposed in chapter 1 of the consultation overall received high levels of agreement. Some respondents suggested other objectives, including protecting user functionality, cost and carbon intensity.

The proposed standards and requirements set out in chapter 2 for smart chargepoint regulations were largely welcomed by respondents. However, many respondents noted the need to balance objectives on consumer and grid protection, with those on innovation and consumer uptake. This was particularly the case for questions relating to smart interoperability, BSI standards, and Vehicle to Grid (V2G). A few respondents also asked government to provide greater clarity on the types of interoperability we propose to mandate. Some levels of interoperability (for example switching energy suppliers) were supported more than others (for example the ability to switch chargepoint operator without the chargepoint losing smart functionality and without visiting the premises).

Responses to chapter 2 demonstrated strong support for the inclusion of smart cables^{[footnote 1]} in proposed regulations and applying standards to public chargepoints which happen to be smart. The proposed 12-month lead-in time for “phase one” regulations was also supported. There was less consensus amongst respondents on some specific technical proposals such as including a randomised delay function and defining minimum charging rates.

In chapter 3 (a call for evidence for “phase 2”), most respondents agreed that a decision on a long-term solution for smart charging should be made between 2020 and 2022, with industry generally in favour of an early decision to provide certainty. There were mixed views amongst respondents on the government’s proposed lead option of mandating the GB smart metering system as an enduring solution for smart charging. Many respondents highlighted both benefits and drawbacks of the approach, with some respondents suggesting elements of alternative, market-driven approaches.

Finally, in chapter 4 (a call for evidence for the transmission of data relating to chargepoints), many respondents thought that regulation of chargepoint data transmission was needed for network planning and reinforcement. Some respondents raised concerns about sharing this data, specifically citing it may be commercially sensitive. Many respondents recommended aggregation and anonymisation of consumer data as a solution. The rate of EV uptake and network planning were two factors many respondents said should determine the timing of regulation on data transmission.

Table 1 – Breakdown of respondents by type

Respondent type	Count
Local government or council organisation	17
Other	16
Individual	16
Trade association	15
Energy company	10
Company involved in smart metering	8
Chargepoint operator	7
Energy infrastructure company	6
Chargepoint manufacturer	5
Software solution provider	4
Distribution network operator	4
Industry body	4
Vehicle manufacturer	3
Aggregator	3
Consumer group	3
Consultancy	2
Transmission system operator	2
Company involved in cyber security	2
Academic organisation	2
Total	129

Next steps

The government is publishing this summary of responses to update stakeholders on the key themes within the consultation responses. A full policy response from government will follow in due course.

In relation to chapter 1 of the consultation, it remains government’s overall aim to maximise the use of smart charging technologies to benefit both consumers and the electricity system, and retain the 4 objectives for smart charging (consumer protection, consumer uptake, innovation and grid stability).

It is our intention to mandate that all new private chargepoints are smart, subject to further policy development and the continued development of device-level standards. To deliver consistent minimum standards and meet government objectives for smart charging, as outlined in chapter 2 of the consultation, the smart chargepoint regulations will ordinarily require compliance with elements of the BSI PAS standards for energy smart appliances (specifically PAS 1878), which are currently under development. Government will continue to engage with the BSI to develop these PAS standards in 2020, through an industry-led process. We encourage further engagement with the development of these standards including during the public review period, expected in June/July 2020. If you are interested in being involved in the development of PAS 1878 please contact BSI directly on SmartAppliances@bsigroup.com or visit the BSI Standards Development Portal and further details are available.

Government intends to engage further with stakeholders in the context of developing the phase one smart chargepoint regulations this year. This will aid further policy development on a number of areas where there was a lack of consensus amongst respondents. Once the BSI PAS 1878 is finalised and published (due in early 2021), it is our intention to take forward regulations for compliance with elements of PAS 1878 through secondary legislation under section 15 of the AEV act.

In relation to the call for evidence on the phase 2 long-term requirements in chapter 3, government welcomes the evidence provided by respondents. We intend to engage with stakeholders to progress the key policy questions within this call for evidence during 2020, and in due course it is our intention to consult further before setting any requirements relating to the phase 2 call for evidence. The policy issues raised in the call for evidence are wide-ranging and we are actively using the evidence provided in our work to progress this area.

The call for evidence in chapter 4 of the consultation related to the transmission of chargepoint data. We will be undertaking further policy development on the questions within this call for evidence before reaching a decision on regulation under section 14 of the AEV act. As part of this ongoing policy development process, there will be continued engagement with stakeholders and consideration of the relevant proposals from the Energy Data Taskforce and Electric Vehicle Energy Taskforce reports. Government has also announced it is looking at how to make static and dynamic data from all public chargepoints openly available in a standard format for the first time, as well as considering what further electric vehicle charging data is needed to support network infrastructure planning.

Chapter 1 - Introduction and objectives

Government’s aims and objectives for smart charging

Question 1: Do you agree with the government’s proposed aim (to maximise the use of smart charging technologies)?

One hundred and thirteen answered: 106 agreed, 3 disagree, 4 neither agreed nor disagreed, and 0 didn’t know.

Question 2 to 5: Do you agree with the following objectives?

	Agreed	Disagreed	Neither agreed nor disagreed	Didn’t know	Total answered
Grid protection	103	5	4	0	112
Consumer protection	101	7	3	1	112
Consumer uptake	101	2	4	1	108
Innovation	100	3	4	2	109

Question 6: Please provide reasons why you agree or disagree with the above aim and objectives, including any objectives that you think should be added or removed.

Proposed aim to maximise the use of smart charging technologies

Many (10) respondents were supportive of the government’s broader zero emission targets, increasing the benefits of flexibility (for both consumers and the grid), and the aim to maximise the use of low carbon electricity by supporting the move to electric vehicles (EVs) and smart charging.

Some (4) noted that smart charging should not be seen in isolation from upgrading homes generally in light of net zero and should be done in tandem with the electrification of heat.

A few (2) commented on the type of chargepoints, saying that the aim to maximise the use of smart charging technology should apply to both public and private chargepoints, whereas one respondent stated that a public/private split is too simplistic and a ‘use case’ approach should be taken when assessing how to achieve this aim.

Grid protection

Some (8) respondents mentioned here that smart charging could shift demand peaks and help to reduce the need for grid reinforcements. They thought grid connection restraints and upgrade costs could curtail the amount of EV charging supported by the energy system.

A few (3) respondents thought that government should ensure consumers are not penalised for charging when needed (e.g. during peak times). A few (2) noted that there will be an increase in the number of actors managing charging and therefore governance is needed to determine a hierarchy and definitive roles.

Some (5) respondents highlighted that they welcomed the cyber security aspect of the grid protection objective.

Consumer protection

Some (4) respondents emphasised the importance of ensuring consumers have equal and fair access to charging, that vulnerable consumers are protected, and that efforts are made to reach out to consumers who maybe harder to engage. A few (3) respondents mentioned a concern for who pays for chargepoints, specifically chargepoints installed in housing with shared car parking. A few (2) noted the importance of the consumer being able to override smart functionality, specifically the emergency services.

A few (2) respondents thought that a detailed specification of smart chargepoint system functionality to protect consumers would conflict with the government’s innovation objective. They thought this would reduce the competitiveness of UK-based companies and thus be counterproductive to outcomes which benefit the consumer.

The theme of interoperability dominated the responses to the consumer protection objective, with comments on the balance between consumer protection and innovation. Some (6) respondents noted that this objective does not make the distinction between different types of interoperability, and suggested that the 3 key types of interoperability considered by government should be maintaining smart functionality when the:

1. energy supplier is changed
2. vehicle make or brand is changed
3. chargepoint operator is changed

Some (6) respondents who agreed with interoperability cited the risk of a smart chargepoint ‘locking’ a consumer to one energy supplier or chargepoint operator. A few (3) thought that interoperability was needed to minimise disruption to consumers, by minimising the frequency that chargepoints are replaced and allowing software to be updated remotely. A few (3) thought that interoperability would encourage consumers to seek a service provider that provided the best value for money and would encourage a competitive market.

Some (5) respondents who disagreed with interoperability thought that regulating for complete interoperability would conflict with the innovation objective, and therefore regulation should be proportionate with minimal requirements.

Consumer uptake

Some (7) respondents who agreed with this objective said it should focus on making charging easier, cheaper and more attractive, to incentivise consumers to change their charging habits.

A few (3) respondents suggested to ensure consumer uptake, more needs to be done on training chargepoint installers, and one suggested that an installer certification process should be in place.

Innovation

A few (3) respondents thought innovation is important given chargepoint design and functionality is at a very early stage. A few (2) suggested that this objective is extended to “flexibility and innovation” in recognition that this is an early and evolving market, and some (5) respondents said this objective should be technology agnostic.

Some (7) respondents suggested that the innovation aims of the consultation should ensure UK smart charging requirements are compatible with prevailing international standards in order to maximise the competitiveness of UK-based companies and avoid the UK market becoming isolated. Some (7) respondents also thought that regulations should be “light touch” and not too prescriptive to avoid stifling innovation, whilst ensuring consumers and the grid are protected with some minimum requirements.

A few (3) respondents agreed with the innovation objective but stated innovation should not be sought at the cost of consumer protection and other objectives.

Other Suggestions

Some individual respondents made the following suggestions for amended or additional objectives:

• an objective to agree a hierarchy of control for smart charging functionality
• a “protecting user function” objective to ensure that users with specific needs (such as the military, emergency services) are not negatively impacted by smart charging
• an objective for carbon intensity and utilisation of renewables
• a “cost” objective for government to strike a balance between consumer uptake and protection, and innovation
• amending the grid stability objective to “grid support”, as smart charging benefits local and national grid services

The government’s proposed approach

Question 7: Do you agree with the proposal to have a phased approach?

One hundred and seven answered: 76 agreed (including 11 local government or council organisations, 9 energy companies and 7 trade associations), 12 disagreed (including 2 local government or council organisations, 2 trade associations and 2 individuals), 18 neither agreed nor disagreed and 1 didn’t know.

Question 8: Please provide reasons why you agree or disagree, including supporting evidence or analysis, and suggesting any alternative approaches

Many (25) respondents who agreed thought the phased approach was sensible, citing that the smart charging market and technology is at an early stage and continues to evolve. There were comments from some (9) respondents, stating that the phased approach will allow the market to mature, encourage innovation and reduce the risk of technologies failing to integrate into future frameworks. A few (3) respondents supported implementing requirements now to help ensure renewable energy is utilised to power EVs, and to reduce the need for retrofitting.

Some (5) respondents were positive about the approach of encouraging smart charging in an interoperable way, but without mandating at this stage. A few (2) respondents emphasised that data protection needed to be considered as part of the long-term approach too.

A few (3) respondents thought the whole smart ecosystem should be considered before defining one part in detail and that government should only take a decision once there was sufficient evidence and EV uptake. A few (2) respondents said they supported the phased approach, but the lead option for phase two appeared to have been put forward without any detailed quantitative analysis or substantive evidence base, and that it is too early to set out what a solution could look like. Some (4) respondents said they agreed with the phased approach but the target dates are too ambitious and will not provide enough time for the evidence base to develop. A few (2) agreed in principle but voiced caution around legacy systems that would not meet later requirements.

There were some suggestions by a few respondents for an alternative or different approach recommending that:

• all objectives except innovation were fully met at phase one, following up with an innovation-focussed phase two (1)
• government had more phases, due to the complexity of the system (2)
• a continuum (overlapping phases) would be more appropriate (1)

Chapter 2 - phase one: using the AEV act powers to develop device-level requirements

Types of chargepoint and definition

Question 9: Do you agree that the smart regulations should apply to charge points, and to charging cables which contain a smart charging-enabling device?

One hundred and one answered: 85 agreed (including 12 local government or council organisations, 9 energy companies, 9 individuals and 7 trade associations), 6 disagreed (including 3 individuals), 7 neither agreed nor disagreed and 3 didn’t know.

Question 10: Please give reasons, including any supporting evidence or analysis, for your answer.

Many (25) respondents agreed because they viewed smart cable functionally to be the same as smart chargepoints, so they should both be treated the same. Many (22) respondents thought that if regulations didn’t apply to smart cables then it would create a loophole that would mean government objectives are not met. A few (3) thought that regulating smart cables is important because they predict the cables will become prevalent.

A few (2) respondents commented on the anticipated increased and varied use of EV batteries and therefore the need for regulation on every device that could allow a two-way current flow. A few (2) respondents agreed with the proposal but emphasised the importance of having an appropriate definition of “smart charging”, with another stating a technology agnostic approach that focused on outcomes was important. A few (2) respondents thought government should be anticipating innovation in this area, particularly with lamp-post charging so that households that do not have access to off street parking are still able to utilise smart charging. A few (2) thought that specific and consistent regulation across smart devices would make it easier to provide interoperability for chargepoint users.

A few (3) respondents agreed as they thought any opportunity to relieve pressure on the grid should be utilised and therefore smart cables should be regulated to bring energy management to as many users as possible. A few (2) respondents referenced standards development, noting that the scope of regulation should be in line with the British Standards Institution (BSI) Energy Smart Appliances (ESA) Publicly Available Specifications (PAS) being developed and that this standard would easily allow for updates in scope.

A few (2) disagreed as they interpreted the proposal to mean that costs would increase for consumers, if they had to buy new, more expensive, cables. A few (3) respondents thought that it added complexity and cost that will slow down adoption.

Some (6) respondents who suggested alternative approaches said regulations should apply at battery-interface level and that obligations should be directly on service providers rather than products, or stated that regulations will have to recognise different ‘use cases’ as well as different smart charging devices.

Question 11: Do you agree that the regulations should require that all new chargepoints except for public chargepoints (as defined in the AEV act) are smart?

One hundred and three answered: 43 agreed (including 10 local government or council organisations, 7 individuals, 5 energy companies and 4 energy infrastructure companies), 42 disagreed (including 6 trade associations, 6 individuals, 4 energy companies and 4 chargepoint manufacturers) and 17 neither agreed nor disagreed and 1 didn’t know.

Question 12: Please give reasons for your answer, including explanations of any other types of chargepoints that you think should or shouldn’t be smart and evidence for any exemptions needed.

Many (11) respondents who thought only domestic chargepoints should be smart citied that domestic charging has the greatest potential for smart and that without regulation, domestic consumers will not purchase smart chargepoints. A few (2) agreed because they thought all chargepoints will eventually be smart so it reduces the need to replace non-smart chargepoints.

Many (11) respondents who thought public chargepoints should be included citied specific examples to include, primarily destination and on-street residential chargepoints. Many (11) said there would still be benefits of making public chargepoints smart, including utilising low carbon generation, storage and grid flexibility. Some (5) thought that the benefits of public smart charging were being underestimated. Some (6) thought that Distribution Network Operators (DNOs) could benefit from being able to influence public charging rates if they are smart and that public chargepoints tend to be higher-powered so can have a greater impact on the grid.

Many (11) respondents commented on the need to ensure consumers have equal access to the benefits smart charging can bring, including those who do not have access to private chargepoints. Some (4) thought that adding smart functionality to public chargepoints wouldn’t have any drawbacks, would be low cost and relatively simple. A few (2) mentioned the impact the exclusion of public chargepoints could have on the market, saying it could stunt smart charging uptake and segment the market.

A few (2) respondents referred to the example of the ‘Flexpower’ project of smart public chargepoints in Amsterdam, citing that some concerns around public chargepoints being smart were shown to be misplaced and that legitimate concerns can be managed by regulating the service rather than the hardware. Others (2) referred to similar public smart charging examples in the Netherlands.

A few (2) respondents thought that smart requirements should be technology neutral and at a smart systems level instead of chargepoint level, so that smart charging via the vehicle is included. Some (6) respondents questioned the public-private split, suggesting further distinction should be made by use case. Some (4) thought that both public and non-public chargepoints should be smart by the start of phase 2 or in the long term.

Question 13: Do you agree that public chargepoints that are smart should comply with the relevant elements of the regulations?

One hundred and one answered: 86 agreed (12 local governments or council organisations, and 12 individuals), 5 disagreed (including 2 energy companies and 2 trade associations), and 10 didn’t know or neither agreed nor disagreed.

Question 14: Please give reasons for your answer, including identifying which of the proposed regulations should or shouldn’t apply to public chargepoints.

Many (17) respondents agreed as they thought that if regulations didn’t apply to smart public chargepoints then it would leave a loophole in meeting government objectives, such as cyber security. Some (4) agreed because they thought both public and non-public chargepoints should have smart requirements, as explained in their responses to question 12.

A few (2) thought that for equity reasons there is a need to have similar charging rates and protections (particularly data and cyber security) across both public and private chargepoints. One respondent thought that users wouldn’t use public chargepoints unless they had confidence that they are secure, with another respondent saying that inconsistent requirements across private and public chargepoints would lead to confusion and fragmentation in the market.

Some (4) respondents disagreed and said that public chargepoints are needed for immediate demand and therefore smart functionality isn’t required, but requirements should be placed on the information that is gathered by the chargepoints.

Many (11) respondents gave a view on different requirements that would be needed for public chargepoints. Some (4) thought that a randomised delay function and default off-peak charging mode wouldn’t work for public chargepoints, as they would be consistently overridden by EV drivers. A few (3) thought that cyber security and other requirements may need to be different for public chargepoints. One respondent said that the method of monitoring and control may need to be different for public chargepoints but the basic specification can be standardised to be aligned with private chargepoints. One respondent said public charging load should be managed by offering a lower maximum charge option.

Question 15: Do you agree that a smart chargepoint should be defined as being communications enabled and able to respond automatically to remote signals by adjusting the electricity consumption flowing through the chargepoint?

One hundred and one answered: 74 agreed (including 11 local governments or council organisations, 9 individuals and 8 energy companies), 17 disagreed (including 3 chargepoint operator, 2 vehicle manufacturers and 2 companies involved in smart metering), 7 neither agreed nor disagreed and 3 didn’t know.

Question 16: If not, how should it be defined instead?

Some (7) disagreed because they thought the definition needed to be more defined and limited. Some (4) thought the definition should make clear that many different parties could control smart chargepoints and provide smart signals, such as suppliers, DNOs and the Electricity System Operator (ESO). A few (2) respondents said it should include cases where the EV itself can control the smart charging functionality and also take into account that a series of devices can communicate and perform defined smart functions.

A common response was to suggest alterations to the definition. A few (2) thought that the response didn’t need to be immediate, because a form of smart charging could still take place via a pre-programmed schedule. A few (2) thought that a form of smart charging could happen only by receiving signals, rather than sending them as well.

A few (2) thought that some smart charging functions could be carried out in response to local, rather than remote, signals. A few (3) respondents stated that the definition should reference functionality to measure and record consumption/export and a distinction should be made between an automatic response (locally controlled devices responding on previously downloaded tariffs) and a remote response (remote controlled devices responding to commercial or other signals).

A few (2) respondents recommended including the assumption that the system will be used to transfer power 2 ways, so that the definition considers bidirectional technology. Others (2) noted that the definition should remain open to new and innovative solutions, with one respondent mentioning charging cables and future innovation for Home Energy Management Systems.

One respondent suggested that the term “communications enabled” should be changed to include both sending and receiving communications. One respondent thought that the definition shouldn’t focus on adjusting electricity consumption, because that could then be interpreted as the only requirement for smart charging. Whereas, another respondent suggested adding further detail on the term “adjusting” to reflect that chargepoints do not have a binary on/off setting, and the need for a definition of “adjusting incrementally”.

Cyber security and data privacy

Question 17: Do you agree with our approach of having both outcome-based security requirements alongside technical security characteristics from the BSI standard or a proven equivalent?

Ninety five answered: 68 agreed (including 12 local governments or council organisations, 8 individuals and 6 chargepoint operators), 6 disagreed, 13 neither agreed nor disagreed (including 2 energy companies) and 8 didn’t know.

Question 18: Please give reasons for your answer.

Many (10) respondents agreed with this approach as the BSI ESA PAS standards were not complete and an impact assessment had not been published. A few (3) thought that this approach would allow for innovation whilst also providing consumer and grid protections. Others (4) said that it was appropriate to specify outcomes for cyber security requirements as cyber security is an evolving space, and therefore the approach should allow continuous improvement. A few (2) supported the proposal as it aligns with the smart metering approach to security, but some said government needs to ensure alignment with Commercial Products Assurance (CPA) too.

A few (2) respondents who disagreed with the proposal thought that an impact assessment and/or cost benefit analysis is needed to understand the additional costs. Others (2) stated government should not be overly prescriptive and should defer decisions until there is greater clarity over needs and use case scenarios, as future solutions may supersede current standards. A few (3) respondents thought that the sector wasn’t being given the opportunity to establish its own systems and processes, with another suggesting the chargepoint can be protected without requiring specific technical standards.

A few (2) respondents were concerned about costs. They referenced costs and delays associated with the SMETS2 (smart metering equipment technical specifications) CPA process and stated that all efforts should be made to streamline the approval process. Another urged government to ensure that additional requirements do not place burdensome costs on consumers.

Some (4) highlighted the importance of requirements beyond the device to cover the entire system, with others suggesting that the outcome approach should ensure critical national infrastructure is protected.

There were some comments on how technical security characteristics should be implemented. Some (6) respondents thought that requirements should not be UK-specific, stating that security is already embedded into international standards (such as ISO15118 and ISO63310), and the European Network for Cyber Security (ENCS) minimum requirements. A few respondents (2) recommended that these international requirements are studied as part of the BSI ESA PAS work, both in terms of referencing or adapting them, and considering the timelines of UK versus EU standards.

A few (3) respondents suggested the National Cyber Security Centre (NCSC) set up a platform to bring stakeholders together across industries on cyber requirements, and ensuring that emerging market players are included in the BSI ESA PAS standards process. A few (3) thought that NCSC or another organisation should stipulate minimum certificate-based or end-to-end encryption-based requirements, similar to the Open Charge Point Protocol (OCPP) v1.6 and 2.0 requirements, and let industry deliver on them. A few (2) respondents stated they already adhere to OCPP v1.6, and thought it was current best practice in industry. A few (2) respondents highlighted that external audits could be included as part of the requirements.

A few (3) respondents commented on areas not covered by the proposal that they thought could cause security issues of not resolved. One respondent highlighted that unauthorised usage (such as street trading) should be considered. Another mentioned that asset managers and the building industry is not currently equipped to deal with chargepoint hacking and that it isn’t clear where responsibility lies. One thought government should consider whether central routers for communication are used.

Question 19: Do you agree with the proposed list of outcome-based security requirements?

Requirement a) Protect the integrity of chargepoints through physical protections

Eighty eight answered: 74 agreed (including 11 local government or council organisations, 11 individuals and 9 energy companies), 4 disagreed, 5 neither agreed nor disagreed and 5 didn’t know.

Requirement b) Protect operational interfaced of chargepoints and prevent use of non-operational interfaces

Eighty eight answered: 73 agreed (including 11 local government or council organisations, 11 individuals and 9 energy companies) 3 disagreed, 5 neither agreed nor disagreed and 7 didn’t know.

Requirement c) Protect communications and messages sent from and received by chargepoints

Eighty six answered: 76 agreed (including 10 local government or council organisations, 12 individuals and 9 energy companies), 2 disagreed, 3 neither agreed nor disagreed and 5 didn’t know.

Requirement d) Protect firmware on chargepoints, and enable secure updates of firmware

Eighty nine answered: 76 agreed (including 10 local government or council organisations, 12 individuals and 9 energy companies), 5 disagreed, 3 neither agreed nor disagreed and 5 didn’t know.

Requirement e) Protect electric charging, metering, payment charging and other functions of chargepoints (where applicable)

Eighty eight answered: 77 agreed (including 11 local government or council organisations, 12 individuals and 9 energy companies), 1 disagreed, 5 neither agreed nor disagreed and 5 didn’t know.

Requirement f) Protect data held by chargepoints

Eighty seven answered: 74 agreed (including 10 local government or council organisation, 12 individuals and 9 energy companies), 3 disagreed, 5 neither agreed nor disagreed and 5 didn’t know.

Requirement g) Ensure that messages sent to chargepoints are sent from a certified and trusted source

Eighty eight answered: 73 agreed (including 11 local government and council organisations, 11 individuals and 9 energy companies), 5 disagreed, 4 neither agreed nor disagreed and 6 didn’t know.

Question 20: Please give reasons for your answer, including any other requirements you think are necessary.

Respondents to this question tended to support the outcome-based security requirements put forward. Comments from respondents included support for requirements that would provide protections for consumers and networks, and give the public confidence that chargepoints function on a consistent basis. A few (2) respondents agreed but were concerned about the increasing costs that additional security requirements can bring.

Some respondents disagreed with the proposed requirements. A few (2) respondents thought the requirements were unnecessary for private chargepoints. There were also a few (2) comments stating that the communications relating to the ‘smart’ vehicle itself should be protected from a cyber-attack.

Some comments were specific to a given outcome:

a. Protect the integrity of chargepoints through physical protections

One respondent suggested that this would lead to just allowing upgrade by replacement, which will add cost to the consumer. Another respondent commented that this outcome was vital to ensure that devices cannot be tampered with, or have malicious hardware or software installed to them. One respondent said that ‘physical protections’ should not lead to installers having atypical tools for installing chargepoints.

b. Protect operational interfaces of chargepoints and prevent use of non-operational interfaces

One respondent highlighted that certain interfaces involved in the validation of payment methods and connections to a battery’s circuitry help to protect from cyber-attack.

c. Protect communications and messages sent from and received by chargepoints

One respondent suggested three ways to protect communication and messages: (i) sender and receiver to both be encrypted; (ii) secure connection to ensure no one can conduct a “man-in the-middle” attack; and (iii) logging all communications so that it can be diagnosed how and when an attack occurred. One respondent noted that due over-the-air transmission, communication protection is not entirely down to chargepoint industries.

d. Protect firmware on chargepoints, and enable secure updates of firmware

One respondent suggested that this outcome should be explicit about requiring remote updates, to avoid the consumer having to initiate the update themselves and mitigating the risk of outdated firmware. They also suggested making a distinction between downloading software and activating firmware, so that firmware activation messages are secure. Another respondent suggested that firmware should be validated and authenticated, and security updates must be easy to do. A few (2) respondents noted that this outcome, along with outcome (f) may not be fully compatible when interoperability is applied.

e. Protect electric charging, metering, payment charging and other functions of chargepoints (where applicable)

One respondent said that one motive for attacking chargepoints is theft, therefore chargepoints should secure payment functions and should be protected in line with current standards such as the Payment Card Industry Data Security Standard (PCIDSS).

f. Protect data held by chargepoints

One respondent made five suggestions in relation to protecting user data that the chargepoint holds:

1. ensure that the keys used for sending data are encrypted
2. protect user data through anti-tamper mechanisms
3. protect updates, recovery and booting of device firmware
4. protecting payments
5. ensure confidentiality and integrity of user data

g. Ensure that messages sent to chargepoints are sent from a certified and trusted source

One respondent suggested authentication and analytics to spot anomalous behaviour could achieve this outcome. A few (2) suggested this outcome needed to be clarified, as messages can be authenticated in different ways. One respondent commented that this outcome in the consultation document should include a provision to allow parties (e.g. DNOs, emergency services) to locate chargepoints. One respondent suggested that this outcome could be achieved through requirements on the vehicle manufacturer, with references to the Extended Vehicle concept and ISO 20078.

Many (13) respondents put forward additional requirements and comments:

• some (4) highlighted the need for system-based requirements to ensure the cyber security of chargepoint operators, with some citing a role for the Network and Information Systems (NIS) regulations
• some (3) thought we should ensure that data is made available to certain actors (with consumer consent) to assist network planning. Anonymising data, ensuring consent mechanisms are non-circumventable and geographic isolation could help with security implications
• one suggested that cyber security should be limited to ‘essential functions of smart charging’, providing protection for critical functions but allowing for innovation
• one suggested that the chargepoint should alert operators to cyber security events or incidents
• one thought we should ensure that account-based user access to chargepoints is secure and fully verified, and any non-EV charging technology that is installed at charge point device-level, is fully ring-fenced to prevent alternative routes for attacks
• one thought we should require compliance with other legislative requirements, such as General Data Protection Regulation (GDPR) and Payment Card Industry (PCI) standards, and align with Internet of Things (IoT) security principles
• one thought the requirements should follow those that the Data Communication Company’s (DCC) system security developed following recommendations by the Government Communications Headquarters (GCHQ)
• one thought that smart chargepoints should have the same level of protection as smart meters

Question 21: Do you agree with the proposal that chargepoints should undergo mandated security testing and assurance before they are installed or sold?

Ninety four answered: 67 agreed (including 11 local government or council organisations, 9 individuals and 7 companies involved in smart metering), 6 disagreed, 16 neither agreed nor disagreed and 5 didn’t know.

Question 22: Please give reasons for your answer.

Many (14) respondents who agreed stated that mandated security testing and assurance reassures consumers that chargepoints are safe and secure. Many (10) stated that mandated standards decrease the risk of a cyber-attack. A few (2) respondents thought that this reduces the chance of faulty equipment being installed, and suggested the approach had been successful as part of the development of the high security standards for smart metering. A few (2) were in favour of using the CPA scheme as a baseline.

Many (11) respondents cited concerns about cost, complexity and the burden on manufacturers. Some (9) respondents requested clarity on the assurance regime itself first. Some (4) respondents thought that an assurance process would bring unnecessary expense and administration. A few (3) respondents thought that true security comes from operational requirements, including ongoing maintenance, support and upgrades. One respondent thought that the CPA does not have a positive reputation in industry, saying it is slow and expensive. It was noted that there are efforts to phase out CPA in favour of a more holistic approach. A few (2) respondents raised some concerns about the existing, fragmented assurance landscape, and continued uncertainty regarding its future development.

There were suggestions from respondents for how a testing and assurance process might work. A few (2) indicated that the security testing should be proportional to the risk, and that some elements could be ‘pushed upwards’ to a distributed interface system at a higher level than an individual chargepoint, to reduce the costs to the consumer product. A few (2) respondents said assurance should be based on type testing, rather than individual products. One respondent suggested using honeypots - hardware which looks standard to an attacker but is monitored for intrusions. Another respondent suggested that testing also includes “red teaming” exercises to test the system’s defences and should fit with Elexon’s forthcoming Code of Practice 11 for metering systems. One respondent thought that the recommendations of the BSI ESA PAS Strategic Advisory Group should be considered.

There were mixed views amongst respondents on the value of self-assessment with one respondent stating it was not a satisfactory means of assurance and another suggesting it could play a role if followed by inspection of evidence by a nominated party. A few (2) mentioned the European Measuring Instruments Directive (MID) highlighting that similarly the chargepoint manufacturer could be audited and suggested that the testing should be outsourced to local certified test houses. One respondent thought testing should occur at regular intervals.

Question 23: [For chargepoint companies only] Which of these outcome-based security requirements do you already comply with? Please explain how you meet them.

Requirement	Response
a. Protect the integrity of chargepoints through physical protections. For example, ensuring a tamper-protection boundary surrounding the smart chargepoint to deter access to key components	17 said yes, 1 said no and 6 didn’t know
b. Protect operational interfaces of chargepoints and prevent use of non-operational interfaces	17 said yes, 1 said no and 6 didn’t know
c. Protect communications and messages sent from and received by chargepoints	18 said yes, 0 said no and 5 said didn’t know
d. Protect firmware on chargepoints, and enable secure updates of firmware	18 said yes, 1 said no and 5 said didn’t know
e. Protect electric charging, metering, payment charging and other functions of chargepoints (where applicable)	14 said yes, 0 said no and 7 said didn’t know
f. Protect data held by chargepoints	18 said yes, 0 said no and 5 said didn’t know
g. Ensure that messages sent to chargepoints are sent from a certified and trusted source	16 said yes, 3 said no and 5 said didn’t know

Chargepoint companies provided several examples of the ways in which their products meet the requirements, including:

• ensuring encryption of data, using public key infrastructure (PKI) technology (1)
• ensuring encryption of communication, through certificate-based messaging (5)
• a secure bootloader to load only signed, authorised firmware onto the device (4)
• routine penetration tests (1)
• tamper protections (3)
• ensuring compliance with OCPP 1.6 (2)

Question 24: Do you think any other data privacy requirements are needed either from these regulations or from other methods?

Many (17) respondents stated that other data privacy requirements were not necessary, saying existing legislation should be sufficient, or that the proposed regulations exceeded the level of protection needed.

A few respondents (3) commented that organisational level requirements were required for the companies accessing the data, or that chargepoint operators should be regulated like electricity suppliers and District Network Operators (DNOs).

Some (6) respondents discussed the importance of consumer ownership of data, including that:

• the regulations should explicitly acknowledge consumers’ ownership of energy consumption data
• consumers must be able to access their data easily
• consumers must have control over who accesses it

Some respondents made suggestions on how to secure data, including:

• to ensure that no data other than that used for time of charging is kept, stored or transmitted (2)
• for there to be a decommissioning service to ensure data privacy when devices are no longer used (1)
• a requirement that smart chargers physically store only 12 months of consumption data in a secure and private way (1)
• reviewing polices/protocols at least annually for ongoing compliance with relevant European and international standards (1)
• mandating that all data centres handling UK data are SSAE16 compliant and are using industry best practice encryption protocols TLS1.2 and AES-256 (1)
• that certified new methods and protocols should be investigated and included too (2)

Some (4) thought that anonymity of data is required in every situation apart from where precise identification is specifically required, through DSO and ESO controls.

Interoperability

Question 25: Do you agree with the proposed requirement that the chargepoint is capable of retaining smart functionality if the chargepoint operator is changed without the need for a visit to the premises?

Ninety eight answered: 69 agreed (including 12 local government or council organisations, 10 individuals and 7 companies involved in smart metering), 12 disagreed (including 4 energy companies, 2 chargepoint operators and 2 chargepoint manufacturers), 15 neither agreed nor disagreed and 2 didn’t know.

Question 26: If not, then please give reasons for your answer.

Many (20) agreed with this requirement and interoperability to ensure a positive consumer experience, including by preventing consumers being tied into a single operator, reducing the need for a visit to the premises and avoiding restricting choices of tariffs. Some (5) respondents said this proposal would encourage a flexible and competitive market, allowing for new electricity pricing opportunities. Some (9) said interoperability would reduce risk of waste from chargepoint replacement and others supported the development of standardised user interfaces, both for smart functions and EV energy consumption data. A few (4) respondents thought this would ensure that that the benefits of smart EV charging were sustainable and others (3) that it would also improve the reliability of demand side response. Some (5) respondents commented on how to implement the requirement, saying there were learnings from the smart meter rollout.

The private chargepoint communications method OCPP was put forward by some (4) respondents as a way in which government could deliver its outcomes, saying it is an open, secure and industry-led standard. One respondent stated that government could facilitate OCPP adoption by supporting a certification programme for OCPP. A few (2) respondents stated that the communications protocol should be an internationally recognised one and highlighted innovations across Europe, including decentralised interoperability networks and new communication protocols such as Open Charge Point Interface (OCPI).

Some (9) respondents suggested caution in implementing the proposal, warning that though interoperability was desirable, it would be hard to implement, and would add costs to the chargepoint in the short term. A few respondents (2) stated that the definition in the consultation was too broad, and that a basic set of functions should be selected for interoperability to allow for proprietary functions to be unique to a specific company. A few (2) respondents thought that there wasn’t yet sufficient evidence or clarity on the proposal for it to be implemented. A few (3) did not think changing chargepoint operator was necessary or desirable. A few (2) respondents mentioned that, in the event a chargepoint operator went out of business, this could be delivered through a basic reset function, not full interoperability requirements. Some (4) respondents mentioned the danger of limiting competition and innovation within back end functionality if interoperability was mandated. A few (2) thought the consumer should have the choice as to whether they want interoperability, if an interoperable chargepoint is cheaper than a non-interoperable chargepoint. One respondent also raised a concern that this could be a UK-only requirement would reduce chargepoint models brought to the UK market, limiting consumer choice.

Other comments included:

• ensuring a chargepoint requires at most a minor modification (such as a cable swap) to ensure it is interoperable with different electric vehicles (1)
• ensuring government encourages interoperability for all smart appliances (1)
• investigating technical interoperability between public chargepoints (i.e. the ability to use services offered by different public charging providers), citing it is a very important factor in managing EV ‘range anxiety’ (2)
• requiring a default non-smart mode to ensure basic functionality is retained when operators cannot control the device (e.g. if they went out of business) (1)
• using ‘eSIM’ technology to provide interoperability (1)

Question 27: Do you agree that compliance with interoperability requirements of a BSI standard, combined with a certification and assurance regime, could help ensure interoperability?

Ninety six answered: 58 agreed (including 10 local government or council organisations and 10 individuals), 17 disagreed (including 4 chargepoint operators and 4 trade associations), 15 neither agreed nor disagreed and 6 didn’t know.

Question 28: If not then please give reasons for your answer.

Some (4) respondents who agreed said that this approach is a normal means of ensuring compliance. A few (3) respondents commented on the need for consistency and standardisation to ensure interoperability, protect consumers and remove reliance on one manufacturer or service provider by allowing consumer to switch chargepoint operator. A few (2) respondents said the suggested approach would help ensure consumers know which chargepoints were compatible with different chargepoint operators. A few (2) said that when products are shown to meet a standard, consumers can be assured of the quality of the product.

Some (9) respondents said they needed to see a finalised version of the BSI ESA PAS standards before providing a detailed response. Some (5) emphasised the importance of the BSI ESA PAS standards covering hardware and software and smart communication platforms. A few (2) said that a formal impact assessment is required before a decision can be made. Some (6) respondents mentioned that OCPP is a good starting point and achieves much of the necessary functionality. Some (5) respondents also recommended ensuring alignment with international standards to ensure compatibility with international markets.

A few (2) of the respondents who disagreed wanted a more flexible approach and believed that BSI ESA PAS standards would keep up with the continually changing landscape and new advances in technology. Other respondents reinforced their opposition to enforcing interoperability in response to this question on the proposed approach.

Some (5) respondents commented on assurance and testing. One respondent suggested random checks on installations should be implemented, sufficient training should be available and a centrally managed audit process for product claims, advertising standards, operating capabilities, safety and compliance for the hardware needs to enforced. One respondent suggested a self-certification scheme that was backed up by random audit, while another respondent recommended that the certification process is handled by an external agency. A few respondents (2) commented on the need for interoperability testing to be simple and affordable to ensure small companies are able to make investments in the UK market.

Grid stability: randomised delay function

Question 29: Do you agree that the regulations should include a requirement for a randomised delay function?

Ninety four answered: 43 agreed (8 local government or council organisations, 5 companies involved in smart metering and 5 energy infrastructure companies), 23 disagreed (including 4 chargepoint operators), 22 neither agreed nor disagreed and 7 didn’t know.

Question 30: Do you agree that a randomised delay function for smart EV chargepoints should have a maximum delay of 10 minutes?

Fifty four answered: 20 agreed (including 5 companies involved in smart metering), 15 disagreed (including 2 DNOs, 2 chargepoint manufacturers and 2 energy companies), 4 neither agreed nor disagreed and 15 didn’t know.

Question 31: Please give reasons for your answer, including evidence for any impacts on benefits to consumers and any suggested exemptions.

Some (9) respondents who agreed commented on the use of this function when recovering from outages. One respondent highlighted specific issues where a randomised delay function would be beneficial and suggested that a randomised delay function was deployed at a level proportionate to the distribution substation service area. However, they also noted that this function will not assist with mitigating charging demand over longer charging durations and may not be compatible when an aggregator is utilising Vehicle to Grid (V2G) for frequency response. Some (4) also noted that a randomised delay function could avoid creating peaks in demand when there is step change in price signals, which one respondent noted had been an issue in Germany and California. Some (5) provided reasoning why they thought a maximum of 10 minutes would be sufficient for most grid stability issues. Another respondent thought it was a well-established way to protect the grid using simple and low-cost technology.

Some (7) respondents disagreed because they thought it would lead to an undesirable customer experience if consumers were required to wait up to ten minutes for their car to start charging. One respondent thought this would hamper adoption and consumers will think the chargepoint isn’t working. Some (5) respondents thought that the maximum time should be as low as possible to avoid a bad customer experience. Some (4) respondents commented on consumer experience and suggested consumers should be well informed of this function and should know when to expect their vehicle to start charging.

Some (4) respondents noted that chargepoints are likely to be operated by flexibility providers in a way that doesn’t threaten grid stability, therefore there is no need for this function. Some (5) thought that randomisation could be managed at chargepoint operator, or aggregator level as the chargepoint can be managed remotely, and one of those respondents thought that the My Electric Avenue project had demonstrated there wasn’t a need for random delays. Some (8) thought the proposal was quite arbitrary and lacked evidence, and that it was not clear from the consultation whether this proposal is supported by analysis of possible aggregated impacts on electricity distribution networks.

A few (2) respondents thought that 10 minutes would not be sufficient to smooth out peaks in demand, particularly at the local level where slower timescales are of concern. A few (2) others believed that this length of delay would prevent a market being developed for response in this time range. A few (2) of the respondents said that the time delay maximum would need to be below a minute.

A few (2) respondents who suggested exemptions to this function stated that a randomised delay function should not apply to the emergency services, to ensure it does not negatively impact on response times. A few (2) agreed that public chargepoints should be exempt from this requirement as it wasn’t appropriate to add a 10-minute delay due to the habits of public chargepoint users. Many (11) respondents stated that the delay function should not apply in scenarios where Demand Side Response (DSR), frequency response or V2G is required. One respondent advised that a use case approach should be taken to consider where this function should and shouldn’t apply.

Some (4) respondents encouraged the use of other methods of avoiding synchronisation of system loading. A few (3) thought that this question should be left for ESO, DNOs and DSOs to decide as this is not a simple question, it was overly prescriptive to provide a randomisation period, and industry had proved other ways that this could be managed.

One respondent suggested having similar functions to SMETS 2, such randomising on or off an auxiliary load switch, or aligning the auxiliary switch with price changes to avoid grid load spikes as prices drop. A few (2) respondents noted its use for simple, timer-based chargers. One respondent noted that the smart meter system ‘allows for a configurable randomised offset of between 0 and 30 minutes for any change in price’, and it is not clear how a smart charger with a randomised delay of 10 minutes operating through a smart meter would interface in practice. A few (2) others echoed this, suggesting that an up-to 30 minute delay would be better aligned with the smart meter.

Question 32: What other methods could achieve the same outcome of ensuring electricity system stability in response to numerous chargepoints turning on or off at the same time?

The following alternatives were suggested:

• management of electricity system stability by the chargepoint operators, aggregators or energy supplier (9)
• ‘soft-start’ ramping up of chargepoints (e.g. gradual increase charging over a time period such as ten minutes) (5)
• accurate and dynamic pricing signals which would spread demand appropriately (2)
• battery storage (2)
• better grid management via the use of artificial intelligence (AI) and other tools to predict surges (3)
• use the randomised function in smart meters to trigger the off-peak charging to start in the chargepoint via the Auxiliary Load Control Switch (ALCS) (3)
• grouping the response times across a geographical area (2)
• existing diversity of consumers’ charging behaviour (2)
• V2G and frequency response from chargepoints (2)
• organising chargepoint operators so that they do not all send charging signals at the same time (2)
• DNOs could use tele switches to control local demand as seen with the uptake of storage heaters – this is where there are defined ‘operating windows’ for different ‘groups’ (2)
• “bundling” of low carbon technologies (e.g. solar and storage linked to charging technology) (2)
• via the limited smart meter “filter” or alternatively through a single platform that monitors Electric Vehicle Supply Equipment (EVSE) instructions and ensures that they are not going to result in a grid event (2)

Minimum charging current or power

Question 33: Do you agree that the regulations should include a requirement for a minimum charging current (or power)?

Eighty nine answered: 34 agreed (including 11 individuals, 7 local government or council organisations and 4 companies involved in smart metering), 34 disagreed (including 5 chargepoint operators and 5 trade associations), 13 neither agreed nor disagreed and 8 didn’t know.

Question 34: Why? And if so, please provide suggestions for an appropriate minimum amount of current or power.

Most respondents who agreed did not provide a reason why. One respondent said this requirement will protect against battery deterioration and dis-incentivise a consumer from plugging an EV into a domestic 13A socket.

Many (10) respondents disagreed on the basis that this issue should be addressed by chargepoint manufacturers, with a few (3) suggesting this will happen without government intervention. Some (8) respondents stated that this is a vehicle related, rather than a chargepoint related issue. Some (4) respondents were concerned about this restriction reducing energy flexibility. A few (3) other respondents urged the government to be cautious with this regulation and stated that more evidence is required to ensure there will be no future negative impacts. A few (3) respondents thought that the cut-out issue was small, but that charging at low power should be avoided because the efficiency of chargers currently becomes very poor.

Some (5) respondents, regardless of whether they agreed or disagreed, stated the need for an ability to reduce charging rate to 0 in cases of emergency. A few (2) suggested that the limit should be different for each vehicle or vehicle-chargepoint combination. Some (4) said that this question should be posed directly to vehicle manufacturers. The majority of respondents did not suggest a specific minimum current or power.

Question 35: How else do you think this issue could be addressed?

Respondents suggested alternative mechanisms. Some (5) suggested more detailed communication between the vehicle and the chargepoint was needed. Some (5) respondents thought that issues identified mainly lay with the vehicle manufacturers.

Default off-peak charging mode

Question 36 and question 37: Do you agree that the regulations should include a requirement for a default off-peak charging mode? Alternatively, would it be better for the regulations to require reduced peak charging by default?

Eighty five answered:

• 40 agreed with including a default off-peak charging mode only
• 10 agreed with including a default reduced on-peak charging mode only
• 1 wanted to include both a default off-peak charging mode and reduced peak on-peak charging mode
• 24 did not want to include either a default off-peak charging mode or a reduced on-peak charging mode
• 10 wanted another option of their choice.

Question 38: Please give reasons for your answers, including your consideration relating to a combination of the two options.

Many (50) respondents supported the concept of default settings in general for increasing uptake of smart charging, although many (13) emphasised that there must be an opt-out or override options. Some (6) felt that off-peak charging should be incentivised, but ultimately left up to the vehicle owner to decide.

A few (2) respondents supported the idea of a default off-peak charging mode, on the basis that it requires low investment and is easy for consumers to understand. However, a few (3) said that this should only be used in the short-term until the National Grid can cope with EV demand or until dynamic charging scheduling is possible.

Some (4) respondents preferred the idea of a reduced on-peak charging mode, as it still allows some charging on peak. Again, a few (3) stated that simple solutions were important for public support. A few (2) respondents suggested the amendment that vehicles with a very low battery should gain a minimum amount of charge before they enter the off-peak mode.

Many (26) respondents thought that defining a specific off-peak time period would result in a new peak in demand at the start of that period. Some (6) also expressed concern that a default off-peak mode would not work for those who needed to use their vehicle before the off-peak time started.

Some (9) respondents noted that there is no standard off-peak period, or that the ideal period is likely to change in the future, and that the off-peak period varies regionally and will not consider availability of renewable energy. A few (3) suggested that time-of-use tariffs allow more flexibility, providing the price bands are updated.

A few (2) respondents expressed concern that these proposals would limit the flexibility of smart charging, while a few (3) believed that over prescriptive regulation could hinder competition between chargepoint operators. A few (2) respondents thought that it was too early to determine the optimal response and that further research was necessary.

Question 39: What time should be the specified off-peak period?

Many respondents (20) suggested specific time periods.

Off peak:

• overnight off-peak period (14), with start times ranging from 21:00 to 00:00 and end times from 06:00 to 07:30. 00:00 to 06:00 was the most popular (4)
• daytime off peak period (2), with a start time of 10:00 and end time of 15:00

On peak:

• late afternoon and evening on peak period (8) with start times ranging from 16:00 to 17:00 and end times ranging from 20:00 to 22:30. 16:00 to 22:00 was the most popular (3)
• morning on peak period (3), with a start time ranging from 06:00 to 07:30 and end times ranging from 09:00 to 12:30

Some (7) respondents said that the off-peak period should be set by national grid. A few (2) said that the off-peak period should be set by the DNO. A few (2) respondents reiterated the need for staggering of start times if there were to be a fixed window.

Many (31) respondents said there should not be a regulated window. A few (2) said that the window would need to be updated as the systems evolves. Many (15) explicitly stated that this needs to be done dynamically. Many (13) believed that window should be customer and location specific.

A few (2) respondents mentioned the Electric Nation trial, commenting that it found the time of maximum flexibility to be approximately 17:00-19:00 on weekdays and that peaks occurred just after the off-peak periods ended. Others (4) reiterated the concern that a single off-peak period would create a new peak in demand.

Safety

Question 40: Do you agree that chargepoints under these regulations should be required to be safe, with due regard to the existing safety framework?

Ninety one answered: 82 agreed (including 12 government or council organisations, 10 individuals and 8 trade associations), 2 disagreed (including 1 chargepoint operator), 4 neither agreed nor disagreed and 3 didn’t know.

Question 41: Please give reasons for your answer.

Most (56) respondents agreed that regulated chargepoints should be required to be safe by having due regard to the safety framework and reiterated that safety is paramount to ensuring public trust in chargepoints.

Some (4) respondents specified that they deemed the current regulations regarding safety fit for purpose, as they provide a useful minimum standard of safety provisions. Some (6) thought that product hardware standards would need to be assessed and enforced. Some (6) respondents noted risks associated with chargepoints if incorrectly installed and suggested that there is regular maintenance and safety inspections, alongside educating the public regarding safe use.

Some (4) respondents suggested that standards should be adapted in the future to incorporate any lessons learnt, that operation/logistics/information related guidelines (not necessarily regulations) should be added and that consideration needs to be given to inspection of older chargepoints.

Question 42 and question 43: Do you think any other safety requirements should be included in these regulations? Please give reasons for your answer.

Many (33) respondents made suggestions concerning other safety requirements to be included in the regulation. The most mentioned suggestions were cyber security (20) and the need to minimise the “three pin plug” approach to ensure consumer protection and safety (2). A few (2) respondents mentioned infrastructure design and building regulation-related issues and it was suggested that smart chargers include electromechanical switches. A few (3) respondents also suggested the regulations could better facilitate the monitoring and enforcement requirements of existing associated safety legislation.

A few (2) respondents highlighted the importance of regulations being compliant with codes and documents relating to the connection of EVs to the distribution network specifically, the GB Distribution Code and the Northern Ireland Distribution Code, and the System Security and Planning Standards documents. A few (2) made suggestions for additional guidelines to sit alongside regulation, namely guidance from DNOs to take advantage of local knowledge and geology, or guidelines for consumers on safe charging practices. A few (3) respondents raised a concern regarding the safety requirements contained in IEC61851 and a recommendation was made to compare IEC61851 and BS7856 for electricity meters.

Some (7) respondents disagreed on the necessity to have other safety requirements included in the regulation and have confidence in the existing framework. Some respondents (4) thought that the existing assessment process requires a high amount of safety testing and additional legislation in this area isn’t needed.

Question 44: Are you aware of any important safety factors that are not being sufficiently considered in relation to EV charging?

Many (24) respondents agreed that there are further safety factors related to EV charging that haven’t been adequately considered. Suggestions covered a wide range of issues, including:

• a mandatory thermal protection software (2)
• overheat protection (1)
• specifying the responsible party for compliance (1)
• a clear legal guidance on safety of charging practices for public spaces alongside appropriate education on the dangers of improper home charging methods (1)
• the position of the charging socket on the car (1)
• different assessments and fault current protection, with the approved installer responsible for complying with IET wiring regulations (1)
• the application of safety requirements as related to the ongoing demonstration of an effective earthing policy (1)

Vehicle to Grid (V2G)

Question 45: Do you agree that any smart charging regulations should provide adequate space for V2G solutions and other advanced smart charging, such as flexibility and balancing services, to develop?

One hundred and four answered: 83 agreed (including 12 local government or council organisations, 10 trade associations and 9 individuals), 6 disagreed, 9 neither agreed nor disagreed and 6 didn’t know.

Question 46: Do you believe that smart charging regulations should include specific requirements for V2G solutions?

Eighty nine answered: 43 agreed (9 local government or council organisations, 6 trade associations and 6 individuals), 27 disagreed (including 5 chargepoint operators), 11 neither agreed nor disagreed and 8 didn’t know.

Do you believe that smart charging regulations should include specific requirements for other advanced smart charging, such as flexibility and balancing services, to develop?

Eighty six answered: 38 agreed (9 local government or council organisations and 5 companies involved in smart metering), 27 disagreed (including 4 energy companies), 10 neither agreed nor disagreed, and 11 don’t know.

Question 47: Please provide reasoning for your answer, including reference to any consultation proposals that could potentially conflict with V2G or other smart charging services and suggest any specific requirements.

Respondents who thought V2G should be included in the regulation cited reasons including: its ability to provide balancing services to the grid and decarbonise the transmission system (2) and potential to reduce energy costs to consumers (1). A few (3) respondents said that they wanted regulation for V2G but did not want any additional regulations added to unidirectional chargers. Others (4) respondents favoured regulation of V2G to ensure that it did not result in unwanted effects for the electricity network. Some (7) respondents said V2G should not be considered in the regulation, but asked government to ensure that there would be no compatibility issues if it were added later.

Many (21) respondents said that it was too early to define specific requirements for V2G. Some (6) thought that the market could change significantly and that the government should wait for the technology to develop and V2G trials to conclude. Some (6) thought that regulations at this point would stifle innovation. Some (4) respondents said it was not yet clear whether V2G would benefit the consumer.

Some (9) respondents said the regulations needed to allow for more innovation in general. Several (6) respondents said that the regulations should be kept simple or high level at this point, and others suggested that regulation could be achieved exclusively through metering of imports and exports on the grid side.

Monitor and record EV electricity consumption

Question 48: Do you agree that these regulations should include a requirement to monitor and record electricity consumed and/or exported?

Ninety eight answered: 85 agreed (including 13 local government or council organisations, 11 individuals and 9 trade associations), 8 disagreed, 4 neither agreed nor disagreed and 1 didn’t know.

[On the online form only] Do you agree that these regulations should include a requirement to monitor and record the time the charging event lasts?

Ninety two answered: 79 agreed (including 13 local government or council organisation, 10 individuals and 9 trade associations), 8 disagreed, 4 neither agreed nor disagreed and 1 didn’t know.

Should this information be available for the consumers to view?

Ninety four answered: 74 agreed (including 10 local government and council organisations, 11 individuals, 8 trade associations and 5 DNOs), 12 disagreed (including 3 chargepoint operators), 7 neither agreed nor disagreed and 1 didn’t know.

Question 49: Please give reasons for your answer and specify what format should be required for the consumer to view the information.

Many (15) respondents thought that allowing customers to view the information would help them track their consumption and some (7) thought this would allow them to make informed tariff decisions. Many (12) thought it would be good for engaging consumers with the concept of smart charging. A few (2) respondents pointed out that consumers are currently able to monitor how much petrol they are putting into their vehicles and believed that this ability should be maintained. A few (2) said that as this data concerned the consumer they should have access to it and it would provide evidence that DSR calls had been responded to.

Some (4) respondents disagreed on the basis that the information is not relevant to consumers or that they would not be interested. Some (7) respondents mentioned the role of chargepoint operators, stating they were better placed to decide what information was available or should pass the information to the consumer. Some (4) respondents thought that it should be optional for chargepoints to record power, stating that there are cases where consumption is measured elsewhere and that unnecessary regulation could restrict simple market solutions. A few (2) said that this regulation should not apply to domestic chargers and some (4) raised data privacy concerns.

Some (6) respondents thought the regulation may be unnecessary, saying that public chargepoints do this already due to the Alternative Fuel Infrastructure regulations. Others (5) said that domestic charging may already be measured by smart meters. A few (2) respondents mentioned the accuracy of metering, questioning whether the regulation needs to specify MID approved meters.

Respondents also suggested modifications to the proposal. Some (11) suggested that the information be made available, but that the regulation should not specify the exact method. A few (2) suggested that the information be displayed to users in units that are meaningful to them – such as cost in £ or equivalent grams in CO2.

For a display medium, many (16) suggested an app, and others (7) suggested a website or online portal. Some (5) thought that the user should be emailed their usage and the information should be displayed on the chargepoint.

Enforcement authority and penalties

Question 50: Do you agree that the Office for Product Safety and Standards (OPSS) should be the enforcement authority for the regulations?

Eighty eight answered: 46 agreed (including 9 energy companies, 8 local government or council organisations and 7 individuals), 5 disagreed and 37 didn’t know.

Question 51: Please give reasons for your answer.

Many (13) respondents who agreed with having the OPSS as the enforcement authority said they had the resources necessary to regulate the requirements. Some thought the appointment of the OPSS was appropriate as the regulations are in connection with the sale and installation of EV charging products, and OPSS are responsible for related matters such as the Alternative Fuels Infrastructure regulations.

Some (4) respondents who disagreed thought OPSS didn’t have the needed and therefore might be unsuitable. A few (2) respondents thought that whilst OPSS may be suitable for determining whether the regulations are being complied with and for administering financial penalties, they might not be best placed to enforce other necessary actions in the case of non-compliance.

A few (2) respondents raised questions about how the OPSS would enforce regulations and standards, identify where to carry out inspections, handle regulation updates and ensure updates are universally enforced.

Some (5) respondents commented on the regulatory split between OPSS and Ofgem. A few (2) respondents thought Government should consider an approach for any compliance and enforcement actions that cut across both Ofgem and OPSS responsibilities. A few (3) respondents suggested that consumers, energy suppliers, electricity networks and other third parties will come to rely on the consistent management of data and communications and supply of energy to and from smart charge points, so suggested that Ofgem should play a role in regulating and enforcing compliance.

Question 52: Do you agree that the penalty for non-compliance should be a fine for each non-compliant chargepoint sold or installed?

Eighty four answered: 44 agreed (including 10 local government or council organisations, 7 individuals and 7 energy companies), 11 disagreed, 16 neither agreed nor disagreed and 13 didn’t know.

Question 53: Please give reasons for your answer.

Many (18) respondents who agreed with the proposal thought a fine was a strong but proportional deterrent which would prevent non-compliance. A few (2) respondents recommended that the cost of the fine should reflect the standard or regulation breached and that penalties should be related to the issues that could emerge if the grid is not adequately protected. A few respondents (2) suggested we treat repeat offences more severely, and others (2) suggested safety as well as maintenance standards should be included.

A few (2) respondents who disagreed thought that penalties would need to be established on a case by case basis, having large fines for deliberate breaches but small fines for other instances. A few (2) respondents said market-based decision-making is the best option.

A point was raised by a few respondents (2) on the need for a mechanism which could exist alongside fines and by which the non-compliant chargepoints could be made compliant or replaced.

Time for compliance

Question 54: How long should sellers or installers have to comply with the requirements once the final version has been published?

Sixty seven answered: 12 agreed with up to 6 months, 34 agreed with up to 12 months, 9 agreed with up to 18 months, 10 agreed with up to 24 months and 2 agreed with more than 24 months.

Question 55: Please give reasons for your answer.

Some respondents provided a reason for their response, including:

• 6 months is sufficient for some requirements as smart technology is already in existence, however more complex and costly requirements, such as interoperability, will need more time, for example up to 2 years (2)
• it depends on the complexity and cost but it is hard to say until the BSI ESA PAS standards are finalised (2).

Question 56: [For chargepoint companies only] What would the impact be on your business?

Some (5) respondents said it was difficult to determine the adequate length of the timeframe for compliance at this stage, and this may depend on the specifics of the regulations. A few (2) respondents disagreed with the 12-month window for compliance, arguing that this would make it necessary for chargepoint providers to review their multi-year strategy and capital expenditure programmes

Other points respondents made included that: clarity on the requirements is needed as soon as possible (1); government needs to ensure that the testing infrastructure is in place (1) and; a short lead in time was needed as some smart technology is already in place (1).

Question 57: [For chargepoint companies only] Subject to passing the testing schemes for security and interoperability, are any of your chargepoints likely to comply with these requirements either currently or with minor modifications?

Some (9) respondents noted that responding to this question was made difficult due to the lack of visibility of requirements and specifications which would be included in the regulations. Some respondents (4) also highlighted their experience with testing with smart metering infrastructure.

Some (4) chargepoint companies provided specifics on modifications they would need to make to their existing products:

• buying NIST approved security libraries and upgrading all test tools, which would add significant costs and complexity (1)
• a review of existing security protocols in order to ensure compliance, alongside additional work to ensure interoperability (1)
• a major hardware change in order to comply with the potential requirement for a manual override for default charging profiles and a partial re-certification (1)
• software and firmware modifications, potentially alongside a new certification (1)

Other considerations

Q58 Are there any suggested requirements that you think could disadvantage people with particular protected characteristics, as defined by the Equality Act 2010, or could otherwise cause equality issues? Please explain any issues and any potential solutions.

Respondents identified a range of issues that could disadvantage those with protected characteristics:

Lack of connectivity – a few (2) respondents noted that some consumers are not connected to the internet and it was recommended that the government continues to work towards guaranteeing a high-speed connection to all consumers, focusing in particular on provision in rural areas.

Complexity of smart functions – a few (3) respondents noted that some consumers may need help with understanding smart charging tariff options. It was suggested regulations consider the impact on elderly people, considered to typically be late adopters of technology and therefore likely to not participate in smart charging.

Accessibility – a few (2) respondents highlighted that the proposals could potentially put people with protected characteristics at a disadvantage. Respondents recommended that this was addressed from the outset using a range of smart charging formats for example the web, apps, home assistants and wireless charging. One respondents stated that it is important those who require alternative arrangements do not face higher costs.

Night shift work and emergency response – a few (3) respondents noted that the proposal might have a negative impact on those who work night shifts, as they may only be able to charge during the day when energy prices are higher. Similarly, it was recommended by one respondent to take into consideration companies or individuals requiring their vehicles to maintain a constant state of charge due to emergency response.

Costs - one respondent said regulations need to ensure smart charging does not become a ‘premium’ product and exclude low-income households. A few (2) respondents said Government should ensure that those who are unable to take advantage of flexibility are not faced with price hikes.

Other equality issues – a few (2) respondents thought that if cybersecurity and safety standards are not applied to public chargers, those without access to off-street parking may be at a disadvantage.

A few (3) respondents gave suggestions for schemes which could assist with mitigating the above risks. One suggestion was to have a priority registration scheme for the emergency services. Some (4) respondents thought the BSI ESA PAS standards should be used to ensure inclusive service provision and mitigate possible risks to vulnerable consumers.

Question 59: Do you think we should have specific energy efficiency requirements for chargepoints?

Eighty six answered: 45 agreed (including 10 local government or council organisations, 9 individuals and 6 trade associations), 26 disagreed (including 4 chargepoint operators) and 15 didn’t know.

Question 60: Please give reasons for your answer, including suggestions for any specific requirements.

Some (8) respondents who agreed welcomed the additional focus on introducing energy efficiency requirements for chargepoints and considered increasing energy efficiency measures a reliable alternative to network reinforcement. There was also agreement from some (4) respondents that green energy should be utilised to support a low carbon future. A few (3) respondents suggested requirements for a minimum acceptable standby power draw. Some (4) respondents suggested a consistent labelling system to ensure manufacturers make the details of the energy efficiency clear, such as the A to E rating system used for housing energy efficiency.

Some (6) respondents who disagreed said chargepoints are largely efficient products (>95%) and that, whilst the efficiency of the chargepoint should be clearly displayed, a minimum level of required efficiency should not be mandated. Some (5) respondents stated that having specific requirements would add unwanted complexity, due to the difficulties in measuring a system output in large, complex multi-vendor installations, and that energy efficiency should be left to competition. A few (2) noted that the chargepoints use very little electricity, so little would be gained from adding requirements.

Some (8) respondents suggested alternatives, including focussing energy efficiency measures on the vehicle. Some (4) respondents noted that, due to the charger and/or inverter being on the vehicle, the efficiency of the charge is typically down to the vehicle rather than the charge point.

Question 61: How will different parties be affected by the proposed measures outlined in the first two chapters of this consultation?

For your answer, please consider consumers, charge point manufacturers, DNOs, energy suppliers, charge point operators, government (local/national) and any other relevant party. Please provide evidence and analysis to support your answer where appropriate.

Consumers

Many (11) respondents stated that the proposals would benefit consumers but gave no further detail on why. Others (3) suggested that smart charging would benefit customers by improving EV uptake, increasing the reliability of charging infrastructure, encouraging participation in energy services and increasing the security of electricity supply.

Many (10) respondents thought that the proposed measures would lower charging costs to consumers, yet many other respondents (11) thought that the additional hardware would increase the cost of chargepoints. A few (2) respondents thought that consumers may be financially disadvantaged in the short term, but in the long term they would be gain financially from smart charging.

Some (9) respondents thought that consumers would be negatively affected by the proposal. Some (4) thought that smart charging would unnecessarily complicate the charging process for consumers. A few (2) thought that government intervention would restrict the market, resulting in a worse outcome for consumers. Other (4) respondents thought that the proposals could lead to a rejection of smart charging by the consumer if poorly implemented.

Chargepoint Manufacturers

The most common point raised by respondents (19) was that the regulation would increase costs to chargepoint manufacturers. Some (7) respondents thought that manufacturers might have to revise their designs to satisfy the requirements. Some (4) respondents thought that the proposals would reduce competition and innovation by manufacturers.

However, some (5) respondents thought the challenge posed to manufacturers would be worth it if the benefits of smart charging are realised. Some (5) respondents thought that these regulations would make the manufacturing of chargepoints simpler, create a level the playing field between manufacturers, and increase competition.

DNOs

Many (15) respondents thought that the proposals would benefit DNOs. Some (9) cited reasons including improved control, flexibility, and visibility of electrical load. A few (2) respondents thought that DNOs would benefit from a reduced uncertainty about the future of smart charging.

Some (5) respondents thought that DNO costs would be reduced due to avoided network reinforcements, while others (5) thought that costs would rise due to increasing workload, staffing requirements, and computational burden.

Energy suppliers

Some (4) respondents thought that the proposals would have no effect on energy suppliers. Some (6) thought that the proposals would lead to better management of supply, increased supplier revenue, and provide certainty about the future for smart charging. Some (6) respondents thought that the proposals would increase competition between suppliers on smart charging tariffs.

A few (2) respondents thought that suppliers would have an increased workload and would be crucial in getting consumers to engage with smart charging. A few (2) respondents noted suppliers needed to work more closely with CPOs.

Chargepoint operators

Some (5) respondents thought that the proposals would give chargepoint operators more commercial flexibility and give them the certainty and confidence to make investment decisions.

Some (5) respondents noted that the operators were likely to incur additional costs because of the proposals. Some (5) respondents raised concerns about the increased complexity of operators’ task, specifically on interoperability, security, compliance, and reliability of charge points. A few (2) respondents raised concerns that current equipment would become obsolete.

Local government

Some (4) respondents thought that the proposals would have no effect on local government.

Some (4) reported that the proposals would benefit local government but did not specify why. Others (4) thought that the proposals would provide clarity, both for residents and for planning purposes. A few (3) respondents thought that air quality would be improved due to an increased number of EVs.

Some (4) respondents thought that there would be additional costs incurred by local government because of the proposals. Others (3) said that there would be additional work required on local planning.

National government

Some (4) respondents thought the proposals represent a positive step towards the government’s decarbonisation objectives. A few (2) respondents thought that the proposals would increase the investment opportunity in the UK. Some (4) respondents thought that the proposals would be unpopular and expensive.

Other parties

A few (3) respondents mentioned that the transmission system operator would be able to better manage the system because of the proposals. A few (3) respondents mentioned that there would be new opportunities for aggregators or mobility-as-a-service (MaaS) providers. A few (3) respondents were concerned that vehicle manufacturers had not been given sufficient consideration in these proposals.

Chapter 3 – phase two: smart charging long-term approach – call for evidence

Decision on a long-term approach

Question 62: Do you agree that, in order to implement a long-term approach to smart charging by 2025, government should make a decision between 2020 and 2022? Noting the example stages in the chart set out in paragraph 3.6. of the consultation.

Ninety five answered: 69 agreed (including 12 local government or council organisations, 9 individuals and 7 trade associations) 17 disagreed and 9 didn’t know.

Many (17) respondents agreed that in order to implement a long-term approach to smart charging by 2025, government should make a decision as soon as possible to provide industry clarity, inform long term planning and to ensure a solution is in place before a large number of chargepoints are installed.

A few (2) respondents supported a decision between 2020 and 2022 but not at the expense of reducing innovation. A few (2) respondents stated that the regulatory landscape should remain open to alternative innovations, and that the proposed timeline should allow time for evidence from phase one and elsewhere to be fully considered.

Some (6) respondents thought that the 2020 to 2022 timeline may be too ambitious, hadn’t been fully justified in the consultation and should be kept under review.

Question 63: What is your preferred year for a decision?

Sixty nine answered with a preferred year for a decision, of these:

• 38 said 2020 (including 9 individuals and 7 local government or council organisations)
• 13 said 2021 (including 3 trade associations)
• 9 said 2022 (including 2 chargepoint operators)
• 3 said 2023 (including 2 companies involved in smart metering)
• 1 said 2024
• 5 said 2025 (including 2 individuals and 2 trade associations)

Question 64: Please provide reasons for your answer, including evidence (where relevant) of the impact that an earlier or later decision could have.

Some (4) respondents commented on the need for an earlier decision to ensure climate targets are met by decarbonising transport, yet a few (2) respondents commented on the trade-off between meeting climate targets and ensuring the best decision on phase two is made. Some (5) respondents said an earlier decision would increase the amount of electric vehicle (EV) infrastructure and therefore increase EV uptake, leading to improved air quality and overall ensuring that the benefits of smart charging are realised. A few (2) respondents said that an earlier decision will give industry time to innovate in response and export to other markets. A few (3) respondents said an early decision is needed to avoid rushing to install systems/meters, to avoid higher costs through replacement of stranded technology that is not interoperable and to prevent lost savings for consumers.

A few (3) respondents thought that Distribution Network Operators (DNOs) needed to submit business cases for RIIO ED2 (Electricity Distribution price control) within the next 2 years, and by then, they will need a decision on phase two to inform their estimates of EV uptake/charging patterns and help determine how much to invest in network upgrades.

A few (2) respondents were concerned that the government may take too long to make a decision. Some (4) respondents said a decision should only be taken once a strong enough consensus existed amongst industry on a solution, and therefore timelines should be kept under review. A few (3) respondents thought that SMETS 1 (smart metering equipment technical specifications) provided evidence that a decision shouldn’t be taken too early – they said they thought an early decision could end up costing more in the long term and require consumers to replace technology.

Question 65: Do you agree that the factors listed in paragraph 3.5 are the key criteria to consider in determining a decision point?

Eighty seven answered: 63 agreed (including 10 local government or council organisations, 9 individuals, 7 trade associations and 7 companies involved in smart metering) 11 disagreed (including 3 energy companies), 9 neither agreed nor disagreed and 4 didn’t know.

Question 66: Please provide reasons for your answer, including a consideration of additional key criteria we should consider in determining the timing of the decision point.

A number of general comments were made relating to factors for helping determine a decision point. Some (5) thought that the strength of the evidence base was important in determining the criteria and timing. A few (2) thought it was important to consider the wider picture, such as the move towards electrification of heat and associated network improvements.

Some respondents provided specific comments supporting the objectives put forward in the consultation:

Grid protection - a few (3) thought this was necessary because grid reinforcement adds to customer bills. Others (2) thought this was necessary to ensure people have access to flexible electricity at the low voltage network as demand increases.

Consumer protection – a few (2) thought this was needed to ensure safety and data protection for the user, provide access to fair prices and thought that it should also include interoperability of suppliers.

Consumer uptake - one thought uptake must be high to meet net zero targets and that high uptake is needed to optimise charging patterns.

Innovation – a few (2) thought it was important not to rush decisions to the detriment of innovation. Others (2) thought it was important to note that innovation is continuous, and this should be considered in terms of an agile, flexible approach to allow technology to upgrade and evolve.

Alternative and additional criteria were put forward. Several (6) respondents stated that cost should be a factor. Some respondents thought that investment costs for industry should be considered, both in terms of increased manufacturing costs that would passed onto the consumer, and in terms of ensuring smaller companies aren’t priced out of the smart market to ensure competition. Some (4) respondents suggested that ensuring competition in the market itself was an additional factor, specifically to ensure actors other than energy suppliers have access to the market.

Question 67: Do you agree that smart metering system offers a viable solution for the smart charging of EVs, with appropriate system changes in terms of access and functionality?

Ninety seven answered: 53 agreed (including 8 local government or council organisations, 8 individuals, 7 companies involved in smart metering and 7 trade associations), 23 disagreed (including 3 trade associations, 3 software solution providers and 3 chargepoint operators), 21 didn’t know.

Question 68: Please provide the reasons why you agree or disagree.

Many (10) thought that the smart metering system was a good solution for smart EV charging as it would make use of existing investment and be more efficient than setting up a new system. Some (8) respondents also cited the benefits of using smart meter infrastructure due to its interoperability, and others (9) mentioned it had a high level of security. These respondents agreed that the solution achieved the objectives of consumer and grid protection.

Some (5) respondents were supportive of the smart metering system being an option for smart EV charging but were not supportive of it being mandated as the only option. Some (4) respondents thought that the smart meter system was not ready to be a viable solution today, but it could be in the long term.

Some (5) respondents who disagreed thought that the smart meter network isn’t capable of the second-by-second updates needed for smart charging and that the live consumption data provided through the smart metering system would include all other usage within the household too. Many (15) respondents thought that mandating the smart metering system for smart EV charging could hinder innovation in the space and limit consumer choice. Some (5) respondents similarly said it would hamper competition in the market and extend the remit of a monopoly service provider. Some (4) respondents thought that the DCC (Data Communications Company would be a single point of failure, and others (6) expressed concerns about the impact of the UK market being isolated. Some (5) respondents thought that changes to the DCC could be slow to be implemented.

Some (4) respondents raised concerns about the status of the smart meter rollout and a few (3) thought this could hinder the government’s 2025 implementation goal. A few (2) respondents thought that at least 0.75% of households would be unable to access the smart metering solution and a few (2) respondents said that this wouldn’t provide a solution because smart meters are a consumer choice. Some (5) respondents mentioned that consumer uptake could potentially be low, due to the poor public perception of smart metering.

Some (7) respondents thought the costs of the approach could be significant, saying that service providers would need to build parallel systems to access the DCC, a specific issue in Northern Ireland. Some (4) respondents thought that the smart metering system only covers domestic properties and would therefore not provide a solution for all premises, public charging, EV-driven smart charging and smart cables.

There were some (5) respondents who thought that the objectives could be achieved through a different, non-prescriptive solution. A few (2) respondents said they specifically supported a market-based approach to determining a long-term solution

Question 69: In relation to smart charging, how would the smart meter system need to be improved in order to meet reasonable customer expectations of the use of their vehicle? What would be required to do this?

Some (10) did not offer suggestions for improvement, instead saying they thought smart metering systems did not offer a viable option for smart EV charging.

A few (3) respondents identified specific settings or requirements that they thought the smart metering system would need to be expanded to cover, including: large business premises, lamp post chargers, smart cables, real-time control, and allowing multiple providers load control functionality. Many (13) commented on improving the system’s capacity in terms of latency and volume of data in order to achieve required response times.

A few (3) respondents emphasised the need for changes currently under way, specifically on Proportional Load Control functionality to allow intelligent load management. Some (5) respondents also thought that capacity for more granular and bi-directional data (both to and from the charge point) was needed to allow real-time control and participation in frequency response market. Some (6) respondents made general comments, including that they thought the smart meter platform needed to ensure it could support Demand Side Response (DSR) and data aggregation.

Many (15) raised the issue of consent and control in relation to the consumer’s ability to override suppliers’ power on/off signals and the ability of their EV or charge point system to control charging rate.

Many (13) respondents noted that the scope of the DCC system would need to be expanded to allow more actors to participate and its access costs, as well as the flexibility support of the Smart Energy Code (SEC).

Many (15) respondents highlighted concerns in relation to the levels and types of interoperability of home displays, energy suppliers, chargepoint, vehicles and payment systems. Some (7) respondents thought there was a need to improve the control, programmability, connectivity and communication between the control hub and devices (for example meter, charge point, EV, CADs (consumer access device).

Some (4) respondents thought there was an issue of consumer data security and system integrity, suggesting improvements are made to ensure greater security requirements are in place.

The following points were also raised:

• ensuring the system supports V2G (Vehicle to Grid) functionality (2)
• improving the consumer experience (compared with that of SMETS1 and 2 installation programme) (2)
• improving signal coverage and network reach (2)

Question 70: What would you think would be the implication of the UK not following developing international standards in this area and requiring the GB based smart meter rollout for the control and operation of smart EV chargers?

Some respondents described positive implications and highlighted the uniqueness of the UK system.

Many (21) respondents highlighted risks, such as isolating the UK market and making UK businesses less competitive internationally. Many (11) respondents thought that requiring GB smart meters for the control and operation of smart EV chargers would minimise imports/exports to and from the UK, lead to higher costs (to consumers or government) and increased complexity. A few (3) respondents thought this could mean longer lead times before a product launches in the UK and the UK becoming a secondary launch market for manufacturers i.e. EV imports.

Many (16) respondents thought that there would be reduced choice and competition, leading to a reduced choice for consumers, and hindering EV uptake.

Many (13) respondents also commented that not following international standards could reduce innovation, and lead to compatibility issues with EVs abroad and vice-versa. Some (7) respondents also thought that this would reduce the UK electric vehicle supply equipment (EVSE) manufacturers’ ability to compete in the international market.

A few (2) respondents suggested that it might limit the ability of the UK Electric Vehicle manufacturers to develop global solutions, as they wouldn’t have any local presence for testing or development. They thought this could lead to more offshoring of key UK engineering resources.

A few (2) respondents thought not following international standards would have implications for the wider clean technology and ‘flexibility’ industries, saying that smart chargepoints are cornerstone products in domestic flexibility provision, and that this could hamper roll out of other technologies such as onsite solar PV and battery storage.

A few (2) respondents thought that there is a risk the UK develops a specification which is not reflective of best practice established elsewhere. However, a few (2) respondents added that the roll-out of the technology shouldn’t be significantly delayed whilst waiting for international standards to be agreed.

Alternative options

Question 71: Do you think that an alternative approach, as outlined in the consultation, could deliver the government’s objectives on smart charging by 2025, with similar outcomes to the smart meter system on cyber security?

Eighty three answered: 32 agreed (including 6 energy companies, 6 individuals and 3 chargepoint operators), 10 disagreed (including 5 companies involved in smart metering), 17 neither agreed nor disagreed and 24 didn’t know.

Do you think that an alternative approach, as outlined in the consultation, could deliver the Government’s objectives on smart charging by 2025, with similar outcomes to the smart meter system on interoperability?

Eighty three answered: 31 agreed (including 6 individuals and 5 energy companies and 2 chargepoint operators), 11 disagreed (including 5 companies involved in smart metering), 16 neither agreed nor disagreed and 25 didn’t know.

Question 72: Are there other alternative approaches that could deliver the Government’s objectives on smart charging by 2025, with similar outcomes to the smart meter system on cyber security?

Seventy one answered: 25 agreed (including 5 energy companies and 3 chargepoint operators), 8 disagreed (including 4 companies involved in smart metering) and 38 didn’t know.

Are there other alternative approaches that could deliver the Government’s objectives on smart charging by 2025, with similar outcomes to the smart meter system on interoperability?

Seventy one answered: 29 agreed (including 5 energy companies and 4 trade associations), 7 disagreed (including 5 companies involved in smart metering) and 35 didn’t know.

Question 73: Please provide reasons for your answer, including what technologies and approaches to regulation could be used and information and evidence on how any alternative options would deliver similar outcomes to the smart meter system on cyber security and interoperability.

Please say how much time you think developing the approach would take and what costs may be incurred.

Some (8) respondents were supportive of an alternative approach as they favoured a lower level of regulation and thought that market forces would deliver the best solution for smart charging. A few (3) respondents thought that an alternative approach would be better from a cyber security perspective as services would be distributed across different providers. A few (2) respondents provided evidence that alternative options could be ready by 2025, including suggesting that some relevant capabilities and standards already exist.

Some (5) respondents thought that smart meters were the best option as they thought that developing an alternative approach would be too time consuming. A few (2) respondents also raised concerns about the additional cost of developing an alternative approach.

A few (3) respondents thought that a single approach should not be picked. A few (2) thought that the government could achieve their security objectives by placing requirements on CPOs, aggregators, and manufacturers, with the DCC being an option if it is most effective.

Some respondents suggested imposing minimum standards, including:

• Open Charge Point Protocol (OCPP) which prescribes communication between EV charging stations and central management (3)
• ISO 15118 which defines a vehicle-to-grid communication interface; (3)
• ISO 27001 which is an information security standard (1)
• EE Bus IoT (Internet of Things) interoperability standard (1)
• IEC 63110 (currently under development) defining a protocol for management of vehicle charging infrastructure (1)
• Open ADR which is an energy management standard (1)

Other (5) respondents made more general recommendations. A few (2) respondents stated their preference for open architectures which are international best practice. A few (2) thought that the government’s focus should be on reforming the electricity market to place a higher value on flexibility.

Question 74: What are your views on smart charging via the vehicle rather than chargepoint? How do you think government should approach regulating this area?

Many (13) respondents thought that smart charging via the chargepoint was the preferable option. Some (5) respondents thought that regulating the vehicles would introduce unnecessary complexity and would take longer to implement. A few (3) respondents thought that vehicles are manufactured world-wide and so a UK specific smart charging specification would be difficult to enforce. A few (2) thought that the chargepoint would have easier access to information about grid constraints, household electricity demand, and the other balancing services available. A few (3) respondents also said that, if the vehicle approach were to be pursued, additional regulation would be necessary, in order to ensure cyber security and mandate access to vehicle charging APIs (application programming interface). A few (3) respondents were concerned that vehicles having no fixed location would make it difficult for an aggregator to manage network congestion effectively.

However, some (5) respondents thought that smart charging via the vehicle could be preferable. A few (3) pointed out that many vehicles already possess the required technology and that this would reduce the cost of domestic chargers. A few (2) thought that smart charging through the vehicle could be used in the short term to allow smart charging without a smart meter.

Some (4) respondents thought that the requirements should be drafted to apply to either the chargepoint or the vehicle. Some (4) thought that that the ideal system would be where both the vehicle and chargepoint were smart and could work together, for example where the vehicle managed normal operation and the chargepoint managed grid protection. One respondent thought the decision should be deferred until the requirements have been fully developed.

Smart meters as the current lead option for a long-term solution Q75 Do you agree that requiring the use of smart meters for smart charging should be the lead option for phase two?

Ninety two answered: 34 agreed (including 8 local government or council organisations, 7 companies involved in smart metering and 7 individuals), 33 disagreed (including 6 chargepoint operators, 5 energy companies and 5 trade associations), 16 neither agreed nor disagreed and 9 didn’t know.

Q76 Please provide the reasons why you agree or disagree.

Some (4) agreed that smart meters should be used as the lead option because of their interoperability, their secure communication channel, and their familiarity to consumers/industry. A few (2) thought that smart meters were best placed to provide further services in the future, considering the future electrification of heat, and aggregating smart services within the home. One respondent believed that an alternative solution would take too long to develop. A few (3) respondents thought that smart meters should be used as the lead option until enough evidence is available for a viable alternative option.

Some (7) respondents thought that smart meters should be considered as an option, but that it was too early to declare them as the lead option. Some (7) respondents thought that regulating a lead option would prevent the market from developing potentially better solutions, and that regulation should be technology neutral. A few (2) thought that smart meters could be used as the lead option, but not progressed until smart metering system issues are more fully resolved.

Many (11) respondents thought that smart meters should not be an option. Some (6) raised specific technical concerns about the smart meters’ capabilities; that it could not respond quickly enough, that the DCC does not have sufficient capacity for a larger market of DSR providers, their intermittency, and that the DNOs could not access information in real-time. A few (2) also expressed concern that using the DCC would result in a system with a single point of failure. A few (3) thought that the technology had limited flexibility and using them would decrease the UK’s competitivity internationally.

Some (6) respondents thought that the smart meter system was not working well generally, and that the public and industry perception of the meters was low. A few (2) were concerned that the smart meter roll-out would take too long and delay implementation of smart charging. A few (2) suggested that the smart meter could form part of the system, but should not be the central controller.

Some respondents made suggestions of alternative approaches. A few (2) thought that smart charging straight from the chargepoints would be a better solution and others (3) felt that the regulation should focus instead on developing a market mechanism for smart energy service, and that the cyber security and interoperability could be mandated as a set of functionalities.  

Chapter 4 - AEV act powers - transmission of data relating to chargepoints - call for evidence

Question 77: What do you consider the benefits of introducing regulations under this section could be?

Many (23) respondents cited network planning and reinforcement as a benefit of introducing regulations, including the potential for there to be less need for network reinforcement as a result. Some respondents (9) thought that greater availability of consistent data will offer immediate benefits for infrastructure planning by giving greater visibility of assets and better understanding of electric vehicle (EV) charging behaviour, allowing network operators to anticipate demand. A few (2) respondents argued that smart service providers will need access to data to ensure they can enable smart charging and others (3) argued that regulating the transmission of data to network operators is critical for management of the electricity system in the future.

Some (4) respondents stated regulations under this section would benefit innovation, allowing significant benefits of the future energy system to be realised, as well as innovation in emerging business models. Some (8) respondents thought that consumers would also benefit from having greater availability of products and lower prices due to competition amongst operators.

Some (4) respondents noted the benefit of regulations in this area for data privacy reasons, saying it could ensure that only necessary data collected and shared, reducing the risk of sensitive information being breached or targeted by a cyber attacker. Some commented that legislation should initially provide guidelines on what data can be collected, who owns it and set out clear reasons for sharing data.

A few (2) respondents thought that sharing of charge point data with key actors within the UK energy system (including local authorities) could help to plan strategic charge point infrastructure deployment to encourage uptake of EVs. A few (2) respondents thought that not all Chargepoint Operators (CPOs) are giving third parties access to data. They thought this negatively impacts the consumers view of charging options, as information such as location, power availability and live status may be unavailable. Some thought that market forces have not been enough to encourage CPOs to share this data so regulation was needed.

A few (2) respondents thought that introducing regulations would create a consistent approach across manufacturers and allow all participants to plan their systems to accept and interact in a uniform way.

Question 78: What do you consider the disadvantages of introducing regulations under this section could be?

Several respondents (7) cited data privacy concerns, with a few noting that consumers may think that this is an invasion of privacy. Some respondents also mention the potential for General Data Protection Regulation (GDPR) issues. A few (2) respondents thought that the regulations would lead to complicated communications regimes and interoperability issues.

Some (7) respondents were concerned that the regulation would require companies to share commercially sensitive data, which could cause competition concerns and harm business cases. A few (3) respondents thought that the regulation would create a compliance culture, stifling innovation and making enforcement more arduous. A few (2) noted that some vehicle manufacturers may not sell their products in the UK because they don’t want to take part in these data sharing arrangements.

Some (9) respondents cited the cost of setting up and maintaining data sharing arrangements. Several said that there would be undue administrative burden on CPOs, hindering their growth and ability to help meet targets.

Question 79: Do you agree with the views on the minimum data to be made available? If not, what should or should not be included?

Eighty one answered: 53 agreed (including 9 individuals, 8 trade associations and 7 local government or council organisations), 11 disagreed (including 5 energy companies), 2 neither agreed nor disagreed and 15 didn’t know.

Many respondents made suggestions on the types of data to be made available. These included:

• events such as “cable plug in”, “cable removed” and potentially manufacturer specific events (1)
• detailed power consumption for fast frequency response (1)
• energy consumption data during the four stages in the day (1)
• geographical information should relate to the grid – using Meter Point Administration Numbers (MPAN) instead of blanket areas and postcodes, though it was noted that some manufacturers may struggle to provide location data (1)
• state of charge data, desired charge and time required (useful for live management)
• whether or not the chargepoint is smart (i.e. under the control of a smart system)
• which system is controlling the chargepoint (1)
• anonymised summary statistics e.g. half hourly energy draw at substations on each feeder (1)
• a criterion that data should be machine-readable (1)

Some (4) respondents thought that there should be further consideration given to the extent to which data is shared, what the granularity of data is, and who it is shared to. A few (2) respondents supported the ongoing requirement to provide chargepoint location, installation date and power rating. A few (3) respondents raised that EVs are only one aspect of domestic consumption and generation and therefore from a grid perspective EVs would be best managed in conjunction with the other elements. Some (4) respondents asked us to refer to the work done by the Energy Data Taskforce and the Electric Vehicle Energy Taskforce.

Many (10) respondents cautioned against mandating live consumption data or thought that it shouldn’t be shared at all. Many (11) respondents raised the issue of data protection and data privacy. Some (7) thought that data should be aggregated and must be anonymised so that individual users can not be identified, and a few (2) others thought that real-time live consumption figures should be controlled by the consumer. A few (3) respondents raised concerns about the ownership of data, with respondents asserting that this data is the property of the entity that collects it and should not be sent to network operators free of charge.

Some (6) respondents mentioned smart meters, one thought that chargepoint data should be treated the same as smart meter data. Some (4) also thought that Distribution Network Operators (DNOs) would get the necessary aggregated data through smart meter data so mandating chargepoint operators to provide live consumption data to the network would not be necessary or appropriate. A few (2) respondents thought that a DNO must not, in respect of any relevant premises, obtain any electricity consumption data (from smart meters) which relates to a period of less than one month.

Some (5) respondents expressed concern that there would be unnecessary burden on the chargepoint operators, that live/dynamic data from public chargepoint networks should be considered as commercially and operationally sensitive and that mandating sharing live consumption data would impose significant costs on the chargepoint operator. Some (4) respondents also said that the cost of monitoring at a substation level should form part of DNOs’ “business as usual” costs and not be passed onto other parties.

Question 80: What criteria do you think should be used to determine when these regulations should be introduced?

Many (14) respondents thought that the regulations needed to be introduced as soon as possible or the introduction should be accelerated, to ensure DNO’s have visibility of the network and allow consumers to benefit from a flexible system.

However, some (6) respondents expressed caution in introducing regulations too soon, a few (2) respondents mentioned the need to review and amend these regulations when necessary and a few (3) highlighted the importance of giving market actors enough time to prepare their systems to share this data.

A few (2) respondents suggested that EV saturation in the market should factor in to deciding when to introduce regulations. A few (2) respondents thought that regulations should only be introduced when there is consensus from market and adequate EV uptake for minimal market disruption.

Question 81: Please give details of any approaches to implementing these regulations that would be either helpful or unhelpful. For example, preferences for when, how and in what form the data is transferred.

Many (30) respondents provided details on approaches for implementing these regulations. Respondents raised a range of different preferences for implementing regulations, including;

• in stages (1)
• in consultation with manufacturers and operators (1)
• following a period of voluntary compliance and testing (1)
• government and Ofgem to mandate industry participation in data sharing (as per the Energy Data Taskforce recommendations) (1)
• implementation needs to be in conjunction with existing industry governance framework (1)

A few (2) respondents noted that there will be lessons learned from the development and deployment of smart metering regulation. These respondents thought that a format which mirrors and builds on smart meters would be preferable.

There was further discussion on data protection, one respondent stressed the importance of being clear why the data is collated and what it will be used for. Some (4) respondents mentioned the need for information transferred to comply with data protection regulations and ensure the anonymity of the customer.

A few (3) respondents thought that the following aspects should be regulated:

• how regularly data is provided, specifying quarterly as the preferred option
• a template for the data structure, agreed between relevant parties, such as network operators, OLEV and smart charging data providers
• an online system where such data will be uploaded and made available for access by relevant parties, such as network operators, OLEV and smart charging data providers
• the aggregation of data at Low Voltage feeder level for data privacy purposes

Question 82: What data privacy considerations do you think would be relevant and how do you think they could be resolved? For example, consumer preference.

Some (5) respondents thought that consumers would be nervous about third parties having access to data relating to their charging habits (which would include establishing periods of time where properties are occupied or unoccupied). Respondents suggested various solutions to this:

• many (12) suggested aggregating and anonymising data
• a few (2) suggested that the Network Operator should just be given data on the relevant feeder or section of cable, rather than a postcode or anything of similar granularity
• one suggested restricting geographical information to only those who need it to protect the low voltage network
• one suggested consumers being made aware that all data is protected to a greater extent than a typical mobile phone, using a virtual ID rather than a real ID
• one suggested strict regulation
• one suggested use cases to be established first to understand the data requirements in relation to products and services offered to market, the potential interactions that may occur between different use cases and the risks that may arise

Some (9) respondents thought that consumers should have a choice over whether their data is shared in line with the principals of GDPR. A few (2) respondents specified that it should be made clear that consumers own their data. Some (4) respondents argued that consumers need to understand how and why their data is being used.

A few (2) respondents mentioned consumer attitudes towards data sharing in the energy sector, noting that consumers are increasingly aware of data privacy and security related topics:

• some consumers still feel uncomfortable sharing data with their energy network company
• some worry that data is used by companies in a way that they don’t approve of or is not in their best interest
• there is a concern that smart data tells companies too much about households
• consumers think an opt-out of sharing data is important
• consumers are generally happy to share “lifestyle” data but not data that is linked to their physical safety and security. Data that felt “too sensitive” to share included things like physical location, habits and routines

Some (6) respondents thought that data privacy for smart charging could be approached in a similar or the same way as smart meters or as outlined in the Smart Energy code. A few (3) respondents argued that it is vital to ensure that systems are in place to avoid exchange of any personal data. A few (3) respondents outlined the type of data they thought needed to be considered in terms of data privacy including chargepoint location, usage and pricing.

A few (2) respondents focused on data for public chargepoints saying that consumers should be afforded as much information as possible without impinging upon the market’s ability to operate (e.g. location and availability of chargers, the functionality of the station (if it has fallen into disrepair or not), the type of station it is (alternating current / direct current), a base level indication of the pricing that each station operates at and the network of each chargepoint).

Question 83: Who should have access to this data? What processes should be in place to access the data to ensure safeguarding? Who should have access to this data?

Respondents suggested a wide range actors who they thought should have access to different types of data, including:

• Distribution Network Operators and Distribution System Operators (23)
• Electricity System Operator (8)
• Transmission Operator (4)
• local authorities and other public service providers (5)
• chargepoint operators (10)
• chargepoint manufacturer (2)
• the consumer (8)
• aggregators (3)
• researchers (2)
• energy supplier (8)
• emergency services; (1)
• Driver and Vehicle Licensing Agency (1)
• flexibility providers (2)
• available to the general public if privacy is guaranteed and data anonymised (5)
• anonymised, aggregated and made available to all market participants (7)

There was some disagreement over whether consumers must grant data access to these organisations as a condition of having a smart charger operate in smart mode, or if it can only be shared when citizens have given their specific consent. Additionally, a few (3) respondents thought it should be very clear to the user that they can ask for stored charging information (Electric Vehicle Supply Equipment and DNO) pertaining to them to be deleted (right to be forgotten).

A few (2) respondents said, in line with the recommendation 5 of the Energy Data Taskforce, this data should be available on an open source platform to any registered user and presumed open.

Question 84: Please give details of any alternative arrangements that could be used to achieve similar benefits to those outlined above.

Many (15) respondents provided further details, either on alternatives or other general comments on using powers under section 14 of the AEV act.

Some (4) respondents emphasised the need for regulation due to the failure of market-based solutions to deliver mechanisms for open data. However, respondents did not rule out market-based solutions and suggested they can help towards the seamless transmission of smart charging data. One respondent suggested utilising existing industry processes and infrastructure on data. Another suggested that data could be reduced to the most important values from the perspective of the energy management entities, such as peak instantaneous, minimum and average rather than a real time live consumption figure.

Other Comments

Some (8) respondents raised issues that they thought were not satisfactorily considered in the consultation proposals:

• V2G (2)
• wireless charging (1)
• the potential fire risks from charging (2)
• DNO emergency override (1)
• the integration of local solar PV production (1)
• the limited range of energy tariffs available to consumers (1)

A few (2) respondents were concerned that there had not been a rigorous impact assessment carried out for the proposals and another suggested that a use case analysis was undertaken to gain a better understanding of all functional requirements needed.

Some (8) respondents suggested alternative mechanisms for smart charging. A few (3) respondents stressed that any approach needs to have a strong customer focus – ensuring that consumers are sufficiently included and educated about the process. A few (3) mentioned that in order to gain consumer confidence in smart charging and EV’s, more chargepoints need to be visible.

Footnotes

1. Cables which include a built-in device that enables smart charging. ↩