Gemserv recognises the benefits of the proposed developments to existing load control functionality, specifically that they:
- Provide a more refined means of controlling load which retains an appropriate level of security;
- Are a relatively minor incremental change to the Smart metering technical specifications;
- Are expected to be limited to a Data Service Provider (DSP) only change;
- Leverage off the substantial investments already made in the Smart metering infrastructure;
- Encourage solutions that are interoperable after change of Supplier rather than the proliferation of proprietary solutions;
- Are not mandatory and therefore do not ‘lock-in’ any particular technical or commercial operating model, supporting true innovation and a diverse range of possible load control services; and
- Provide sufficiently broad functionality to support a range of developments across the energy market, including Electric Vehicle (EV) charging, optimisation of on-site electricity storage and heating, along with any other innovative products or services which require more a higher degree of load control than is currently available.
We do not consider that the incorporation of these changes into Devices should be mandated at this time. The mandating of this functionality into Devices may become necessary in the future when evidence becomes available to consider the following points:
- Whether the timing is right in terms of seeing how the market will develop versus allowing a proliferation of sub-optimal solutions; and
- Whether EV charging solutions, and other uses, will conflict with these developments.
Because we do not consider mandating the changes to be appropriate at this time, we agree that implementation using a new version of the SMETS2 which would be valid alongside existing versions is appropriate. However, we have concerns around the proliferation of technical specifications such as SMETS, the DCC User Interface Specification (DUIS) and the Great Britain Companion Specification (GBCS) because a range of concurrent specifications increases complexity for Users and risks undermining interoperability.
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