Gemserv welcomes the opportunity to respond to this consultation on the draft technical specifications proposed to support the implementation of Smart Metering System Proportional Load Control Functionality.
We are an expert provider of professional services in a world driven by data and technology. Our response draws heavily from our unique insights and experience gained from delivering technical governance services to support the Smart Energy Code.
We recognise the potential benefits of the proposed developments to existing load control functionality and support the policy intent on the basis that the proposal is focussed on making Smart metering better suited to providing more precise variable load-control, rather than using regulation to mandate a specific approach to achieve broad policy objectives.
However, we would like to highlight that the proposed approach does not seem to provide the Load Controller with visibility of the status of devices ‘behind the meter’ (e.g. an electric vehicle charging point) or, critically, any control algorithm embedded within such devices, along with any features which are programmable by consumers.
Furthermore, we consider that the incorporation of the proposed functionality into Devices should remain discretionary until evidence becomes available to demonstrate whether up-take is likely to be significant. We encourage BEIS to monitor market penetration of the proposed functionality, with focus on whether any interoperability issues arise which would require incorporation of the proposed functionality into Devices to become mandatory in order to support market-wide developments.
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