Driving the green energy transition through consumer choice
The case for interoperability and open data access
The case for interoperability and open data access
Octopus and Elia are committed to driving the green energy transition for consumers, as quickly and affordably as possible. That means electrifying heat and transport, and intelligently managing all energy demand to make the most of our abundant renewable supply, when the wind is blowing and the sun is shining.
Crucially, we need a fundamental shift to centre our energy system around people. With huge increases in use of EVs, heat pumps and batteries, we have the opportunity to offer services to people which make these devices an asset to the grid, rather than a problem. We can empower and incentivise people to shift their consumption to cheapest, greenest times, and keep the electricity system balanced. For the first time, people benefit from being active participants in the system, with automatic optimisation driving down costs.
If we don’t provide opportunities for people to use the system flexibly, we’ll just have to resort to (generally dirtier) forms of generation when renewables production is low, or waste that ge-
neration when demand is low. This matching of demand to renewable generation has to be done intelligently: devices seamlessly integrated as an active part of the smart energy ecosystem. This paper outlines what needs to happen to make this a reality for everyone: open data and an ability to steer devices according to what consumers want and what the system needs.
We jointly urge regulators, governments, OEMs and the commission to explore what can be done to increase the speed and ease at which devices can be integrated, so as to create a lower cost decarbonised electricity system.
“WE CAN EMPOWER AND INCENTIVISE PEOPLE TO SHIFT THEIR CONSUMPTION TO CHEAPEST, GREENEST TIMES, AND KEEP THE ELECTRICITY SYSTEM BALANCED.”
Through the European Commission’s REPowerEU plan, Europe has strengthened its ambition to phase out fossil fuels and drive the energy transition forward. This will require an acceleration in the integration of intermittent renewable energy sources (RES) and increasing electrification of mobility and heat. These two shifts in energy production and consumption are creating challenges for system operators and driving up costs: most renewable generation is relatively inflexible, and cannot be controlled the same way that gas-fired power plants can; the electrification of transport and heating significantly increases both the volatility of demand and the total amount of electricity required to meet it. However, these changes also open up significant opportunities.
These opportunities arise from the flexibility that electric vehicles (EVs), heat pumps and other consumer devices can provide to the system. Flexibility allows energy to be stored and demand to be managed. It also allows Europe to move from its current costly approach of generation control and curtailment to intelligent demand with consumption patterns shifted to cheaper times of the day. Consumer flexibility offered by the many small devices such as EVs and heat-pumps represents some of the lowest cost sources of flexibility that a system operator can buy, so long as there is open access to data and devices can be managed intelligently. This is because consumers are buying these devices to meet their mobility and heating needs, and flexibility comes embedded within them. Adding consumer flexibility to the electricity system, and making better use of it, will reduce costs for all consumers. Furthermore, where network pricing includes a capacity charge, managing all the consumer’s devices within the home (via a home energy management system) can also minimise the consumer’s peak demand and therefore their cost of using the network. But delivering consumer flexibility needs open data and open management of consumers devices.
An energy system with open access to data and open management of devices is a consumer-centric system in which retailers and aggregators are able to offer compelling products or services to consumers, delivering what they want in exchange for managing their devices. It’s a system in which a consumer device, through its
smart operation, is able to easily respond to real-time electricity prices or network congestion signals. It is a system in which devices and products are interoperable and consumers can mix and match according to their preferences and are not limited to a closed, single-brand ecosystem of devices.
Historically, generation was “dispatchable”: power stations could be turned up or down to meet the relatively predictable demand for electricity. Adding EVs and heat pumps to the system changes the predictability of demand peaks. Moreover, RES are relatively inflexible - they can be curtailed, but not turned up, making the management of the system more challenging. The electrification of the heating and transport sectors could also add to peak electricity demand. An EV could add more than 7 - 11kW to the 1-4kW domestic peak of a household , and a heat pump could add another 3 - 5kW. If these devices are left unmanaged, the additional loads will create significant problems for the electricity network and for system operators. The smart operation of devices is therefore required.
Smart operation manages a device based on its environment and using information about congestion in the electricity network and (real-time) wholesale electricity prices. Smart operation turns the concept of “peak” on its head. If there is lots of wind during a winter evening, system operators will want as much energy consumption to occur at “peak” to avoid curtailing generation, so long as the network is unconstrained. Where constraints exist, the device (via the control of an aggregator or a supplier) should be able to delay charging until there is less congestion traffic on the network.
The traditionally independent sectors of mobility, electricity and heating are now merging, bringing benefits to consumers as this happens. For instance, in the UK, Octopus Energy is able to dynamically control when EVs charge using its Intelligent Octopus platform and customer mobile app. This results in a better, simpler driver experience, alongside lower costs and CO2 emissions for consumers as the EVs charge when renewables are plentiful and wholesale electricity prices are low.
However, creating this seamless interactivity cannot currently be achieved without substantial work, and there are a range of barriers. As a result of this friction, consumers will discover that not all their devices will be able to participate in markets, since the work required to achieve interoperability is too great for the possible benefits. They will lose out on possible revenue streams, and pay for a higher cost electricity system. In contrast to the financial services sector (see Annexe), there are not yet any requirements for OEMs to provide standard third party application programming interfaces (APIs) to access data and manage devices. Instead, each manufacturer - and sometimes each model - has a different interface, and different levels of data availability at different granularities and time delays.
Where suppliers and aggregators are able to access a manufacturer’s servers directly through third party access portals (which is the preferred solution, as this form of access is more stable), they often do not have the necessary OEM permission to manage the consumer’s device and therefore cannot provide added value to customers by better scheduling its operation. Large pools of data are often not available, for instance data related to a device performance, which would enable improved optimisation and a better customer experience and outcome. OEMs have generally focused almost exclusively on their own product in isolation, for instance the mobility aspect of the car, and less on how it interacts with the energy system that it is now an integral part of.
Some service providers find workarounds. For instance, where access via a third party interface is not available, it is sometimes possible, rather laboriously, and in a modelspecific manner, to access the car’s systems through the user interface and login credentials, and then schedule the charging and management of the car via this user interface. However, the model-specific user interface is subject to evolution and needs to be reconfigured as the OEM system is “upgraded”, this requires additional work for consumers. In a worst case scenario, the customer might lose access to benefits (such as revenue from particular markets, or information that better enables optimisation) . Given the growth in EV models (by Q4 2021, more than 170 EV models were available in the UK ), this represents a huge amount of rework and inefficiency. It reduces and delays the number of customers that can actively benefit from participating in energy markets.
Other challenges exist. Consumers may wish to connect their devices, only to be informed that there is no capacity, and they will not be able to connect to the network until the network is upgraded. These network constraints are often not visible to consumers or third parties, which means that devices cannot be used effectively to manage the constraint and support system operation. The same principle of open access to data should be applied to distribution system operator (DSO) operational data as well. A good example of a transmission system operator (TSO) opening up the relevant operational data can be found in Elia Group, which publishes data on MW injections into the Belgian DSOs .
Sometimes, when their requirements are too specific, well-intended regulations can fail to deliver their potential value. Nearly every new heat pump sold today in Europe will be labelled ‘smart grid ready’, i.e. certified as being able to receive four types of operational commands (on; off; boost; and reduce) via the internet. However, there is no requirement to provide data on the actual energy consumption of the device, the temperature readings of the system or the operational status of the device - data which is relevant for optimising the consumer experience when the device is being remotely controlled.
As the mobility, heating and energy sectors converge, OEMs are being forced to change their business models. In response, OEMs are exploring how to create additional value for customers and shareholders and how to drive innovation and improve customer experience. Two emerging defensive business models in the EV OEM world are emerging that have the potential to harm consumers.
The first approach, “reserving optionality”, arises when OEMs attempt to replicate the revenue streams that arise from post-sales parts and service businesses in the EV space. OEMs reserve optionality for themselves through the use of proprietary interfaces, making it impossible for anyone else to transact in energy markets using the device. Even if (for instance) their customers would like their EV or heat pump to provide demand side response (or allow others to do so on their behalf), proprietary interfaces create a monopoly over the consumer device.
The second approach, ‘walled gardens’, aims to create a seamless experience for customers by developing an ecosystem of assets with proprietary interoperability. This strategy creates considerable value for customers until the time they try to add non-proprietary devices to this experience, or access non-compatible products and services outside this ‘walled-garden’. In both cases, the OEM business strategy removes consumer choice and competition and stifles innovation and broader value creation. Significant benefits for the consumer, the broader system and society are therefore lost.
‘Reserving optionality’ and ‘walled gardens’: The challenges of some OEM
Regulators are already aware of the challenges of managing network monopolies - care must be taken now to avoid the creation of new monopolies in the energy space. OEMs must, at a bare minimum, open their devices to control via third parties - where this is what a consumer wants to do
Specifically, in terms of data, the European Commission is already taking forward policy and proposed legislation to enshrine the rights of consumers to access and share their data with 3rd parties, at device level. This is clear progress from the existing EU legislation for Electricity – such as the Electricity Directive - which today “stops” at the (smart) meter level in terms of access and sharing (see some examples below). It is absolutely critical that this work is taken forward, and that regulators, politicians and officials:
1. Support the development and scope of proposed EU legislation to ensure open data access is enshrined in EU legislation
This includes potentially extending the current scope, and ensuring compatibility between different pieces of legislation. Today there is a myriad of new EU legislation being proposed, but there is a risk that each piece of legislation and each sector starts developing its own (specific) rules on how to access and share the data. Therefore some guidance from the EU on how “horizontal” legislation (such as the Data Act) could be applied as well as how other relevant legislation could be applicable for specific sectors (energy) or applications will be welcome (“top down”). In addition, as mentioned below in points 3. and 4. below, involvement of leading industry stakeholders should be ensured so the legislation is fit for purpose / on time (“bottom-up”).
2. Once agreed, fully transpose and implement the proposed EU legislation onto member state statutes as quickly as possible to empower consumers to get access and share the data from their connected devices with any third-party acting on their behalf, in order to enable the development of new services and business cases linked with energy (e.g. flexibility services, smart charging/V2G services, smart building services).
3. Foster the development of industry-led cross-sector coalitions aiming to define data communication and data access interoperability standards in order to enable open access and sharing of data for energy-related services in different sectors (energy, mobility, building, etc.).
4. Speed up in the definition of specific rules for data access and data interoperability behind the meter:
Supported by relevant industrial stakeholders in order to complement or support the industry-defined standards / protocols.
5. Support innovation ecosystems and access to funding for innovative solutions:
Foster the establishment of industry-led innovation ecosystems aiming to accelerate the time to market of data-driven energy services, build capabilities and enable further access to EU/national funding to support development, integration and implementation of investment in digitalisation and new data-driven energy services.
6. Extend innovation support to DSOs and TSOs to enable them to open-up flexibility markets from not only a regulatory or legislative point of view - but also from an operational perspective. There is a first mover “disadvantage” for those companies who are the first organisation to sell consumer flexibility in a particular market - as the capabilities, processes and IT systems within DSOs and TSOs are generally designed for large scale thermal assets, not myriads of aggregated consumer devices.
OEMs can create value for their customers by putting the customer at the centre of their strategies and enhancing the driver experience or liveability of a home, working with others and innovating.
As the OEMs are only part of the energy ecosystem, to be fully consumer-centric, they need to open up their servers to third parties if their customers wish for it.
Opening up OEM servers enables both OEMs and other third parties to regulate a customer’s device load up or down, or discharge where feasible via an external controller using existing open communications and control standards.
This is the heart of the ‘smart grid ready’ concept; the Open Charge Point Protocol and other similar initiatives, and will need to evolve over time with innovation and technical developments.
New laws or changes to existing laws are not required for participants in the energy ecosystem to take action now. By working with innovators, aggregators and suppliers to open up their servers now, the more active OEMs can help shape how open data access and interoperability is advanced, and how consumer protections and benefits can progress. They will be able to develop and refine their systems in advance of any regulations and will be able to play a driving role in the energy ecosystem.
The power of learning through doing is immense. OEMs can start early, opening up their servers and developing minimum viable APIs for their products worldwide. They can work with other key players in the sector to learn what works, and build on it. This, in turn, will allow OEMs to help shape the energy revolution with the perspective of mobility or heating providers in mind. Start with what you already have, share it, and then build on it.
Octopus Energy & Elia Group invite OEMs to jointly & proactively shape the open device/appliance APIs that will unlock the consumers’ possibilities to participate in and benefit from energy services.
Octopus Energy & Elia Group will be holding a workshop during 2023 for regulators and Energy Market Participaticants - please email michael.piron@elia.be and marcia.poletti@octoenergy.com if you would be interested in attending.
Open data access will create value, increase innovation and energy system resilience, and drive down costs. Perhaps more importantly, open data access will provide consumers with a better energy experience and a better consumer experience - one in which they are in control and are empowered to take the sorts of decisions they want, for the world they want. Consumer data belongs to consumers, and they have the right to decide who can access it and how.
Open banking is a system that provides third party access to financial data through the use of APIs. Open banking in both the European Union and the UK was developed and implemented in response to competition concerns. The EU Commission in Europe and the Competition and Markets Authority (CMA) in the UK intervened to prevent discrimination against competitors who are independent of banks. In Europe, this resulted in the second Payment Services Directive (PSD2), which was published in 2015 and enacted across each Member State by 2018, which made the provision of interfaces for banks mandatory. In the UK, open banking was a remedy imposed in 2016 on the banking sector by the CMA to improve retail banking services. The remedy included a legal mandate placed on the UK’s nine largest banks to make customer data available to third party providers (TPPs) via APIs.
The opening up of data led to significant innovation and new entrants. In the UK, the number of products and services enabled by open banking rose from 18 in December 2018 to 119 in August 2021; during this time, the breadth of service offerings also increased. 64% of consumers reported that open banking applications had increased their total level of savings and 22% reported that an app they had downloaded was their first ever adult savings account. Similar impacts have been seen across Europe, with a growth of new products and services and an increase in new entrants (see ‘List of useful sources and references’ below).
Transport for London (TfL) is a local government body responsible for most of the transport network in London. In 2010, it started voluntarily releasing its own data – such as timetables, service statuses and disruptions – in an open format for anyone to use, free of charge.
By 2017, 75% of its data was available through APIs. 12,000 users had registered to use this data and over 600 apps were using its data (including journey planners, mapping tools, booking and scheduling tools and analytics engines). Opening up access to TfL’s data is estimated to have resulted in economic benefits and savings amounting to £130m, and improved societal outcomes (e.g. increased innovation, improved air quality and reduced emissions).
Enedis, the largest electricity DSO in France, has an open data platform that facilitates data exchange.
Elia Group, one of the top 5 transmission system operators in Europe, launched its Open Data Platform in 2021. The latter provides users with open access to all of its public grid data, including power generation, load, balancing, transmission and congestion data.
UK Power Networks (UKPN) launched its open data portal in October 2021. UKPN’s data portal provides people with access to one of the UK’s biggest sets of information about electricity infrastructure. It was developed in collaboration with stakeholders.
The European Commission has already articulated a clear vision regarding data in Europe: its aim is to “create a single European data space – a genuine single market for data, open to data from across the world – where personal as well as non-personal data, including sensitive business data, are secure and businesses have easy access to an almost infinite amount of high-quality industrial data, boosting growth and creating value, while minimising the human carbon and environmental footprint” . This vision builds on, and is supported by a series of directives and guidelines, including the Open Data Directive, and sector-specific legislation including laws relating to smart metering and electricity network data.
Shortly, the Commission will formally adopt the ‘Digitalisation of Energy Action Plan’. This will help develop a competitive market for digital energy services and digital energy infrastructure that is cyber-secure, efficient and sustainable. It will support energy system integration, the participation of ‘prosumers’ in the energy transition and ensure interoperability of energy data, platforms and services.
In July 2021, the Commission published its ‘Fit for 55’ package, which aligns key climate and energy legislation with its 2030 climate objective. Within this package, the proposed review of the Renewables Energy Directive (‘RED III’) includes provisions to ensure open access to real-time data from home, industrial and EV batteries at no cost to consumers and third parties acting on their behalf.
The proposed Alternative Fuels Infrastructure Regulation (‘AFIR’) mandates that all deployed publicly accessible
recharging infrastructure must be digitally connected, meaning the charging devices are capable of bidirectional communication and measuring electrical flows. However, it does not include provisions concerning the electricity data that should be accessible. It is also expected that the upcoming ‘Action Plan on the Digitalisation of the Energy Sector’ (the roadmap for which was published in July 2022) will include measures aimed at empowering consumers to access their data via new services and tools, further promoting the sharing of energy data.
Regarding cross-sectoral legislation related to digitalisation, the Commission is focusing on open access and data sharing from different angles. On the one hand, the Open Data Directive (which is already in place) aims to make public sector data available for re-use, and some high-value datasets (HVDs) to be made available for free (an Implementing Act on HVDs was passed in Jan 2023). On the other hand, the Commission’s proposed Data Governance Act (which was announced in November 2020) aims to provide a regulatory framework for the safe sharing of sensitive data held by public bodies and to regulate data sharing by private actors. The Act is to be complemented with the upcoming Data Act, which aims to increase access to and further the use of data to enable business-to-business (B2B) and business-togovernment (B2G) data sharing. Linked with open access, the proposed EU Digital Identity Regulation, which was proposed in May 2021, aims not only to enable EU citizens, residents and business to prove their identity and share electronic documents from their EU Digital Identity wallets, but also to enable easy and secure access to services – such as energy services – across Europe.
Revision of the Renewable Energy Directive (“REDIII”, currently in informal inter-institutional negotiations or “trilogues”): As a complement of the provisions in the so-called “Battery Regulation”, according to the new Article 20a(2), OEMs will need to provide access to battery data from domestic/industrial/EV batteries to users and owners, and to 3rd parties acting on their behalf.
Revision of the Alternative Fuels Infrastructure Directive (“AFIR”, currently in “trilogues”): New Art. 18 on “data provisions” requires operators of publicly accessible recharging infrastructure to make accessible certain static/dynamic data. However, there is no specific mention of energy-related data (e.g. real-time power/ energy flowing through the charging point). Additional data types and specific technical rules are to be defined at a later stage (e.g. via delegated or implementing acts).
Revision of the Energy Performance in Buildings Directive (“EPBD”, Parliament still to adopt its position): New article 14 on “data exchange” asks for owners, tenants and (building) managers to have and give access to their buildings’ system data (inc. meters and charging points). Only the main principles are advanced here. Specific rules to be developed via implementing acts.
Proposed “Data Act” (proposed regulation, Parliament and Council developing their positions): This proposed regulation establishes (new) rules on who can use and access data generated in the EU across all economic sectors. Namely, it provides measures to allow users of products (e.g. can be an EV, smart meter, etc.) and related services to gain access to the data generated by them, and to share such data with third parties. Again,
only main principles advanced here. Specific rules to be developed either via sector-legislation or dedicated implementing acts.
Action Plan on the Digitalisation of the Energy System (“DoE AP”, communication of 18 Oct): Amongst the focus areas, the European Commission (EC) announces the development of a EU-data sharing framework. It announces the aim to develop a common EU energy data space from 2024 onwards. For this, the EC will set-up a “Data for Energy” (D4E) working group – a stakeholder working group – to support the EC in developing the governance for the EU energy data space, and to define high-level use cases for energy data sharing (e.g. to support new flexibility services, smart charging/V2G services, smart building services).
In the recently proposed reform of the electricity market, the European Commission advances an enhanced framework to empower consumers and unlock flexibility. In particular, the proposed amendments to the Electricity Regulation includes a new definition of “dedicated metering devices” (attached or embedded in an asset), and allows TSOs and DSOs to use the data from such devices for observability and for the settlement of flexibility services. In addition, the proposed amendments to the Electricity Directive includes the right for final customers to have multiple service providers behind the meter.
Useful sources and references:
Open Data Handbook: https://opendatahandbook.org/guide/ en/what-is-open-data/
Open data in banking
European Open Banking Legislation: https://ec.europa.eu/ info/law/payment-services-psd-2-directive-eu-2015-2366_en
The impact of Payment Services Directive 2 on the PayTech sector development in Europe:
https://reader.elsevier.com/reader/sd/pii/S01672681203 02328?token=F52D6A3982BFA2FF64C7933990527BD 65C87225F39F2A1B3F051F4DF59F89578A4183D2E447 B8308662EF350D881D220&originRegion=eu-west-1&originCreation=20220622154508
The Open Banking Impact Report, October 2021 https:// openbanking.foleon.com/live-publications/the-openbanking-impact-report-october-2021-ug/home/
Open data in the energy sector
Energy Data Taskforce: https://es.catapult.org.uk/report/ energy-data-taskforce-report/
Energy Digitalisation Taskforce: https://es.catapult.org. uk/news/energy-digitalisation-taskforce-publishesrecommendations-for-a-digitalised-net-zero-energy-system/
Open data lessons for the energy sector - Opendatasoft Open data in transport
Assessing the value of TfL’s open data and digital partnerships: https://content.tfl.gov.uk/deloitte-report-tflopen-data.pdf
Energy Smart Appliances’ Interoperability: Analysis on Data Exchange from State-of-the-art Use Cases see https:// publications.jrc.ec.europa.eu/repository/handle/JRC130268
1. Source: https://www.elexon.co.uk/operations-settlement/profiling/ based on Domestic Profile 1, peak winter week demand is around 1kW; average single phase EV charger is around 7kW; 3 phase charger is around 11kW, with some fast chargers using up to 22kW; average Heat Pump for average house around 9 - 15kW heat, or around 3 - 5kW electricity. For Belgium the average is 3,5-4 kW. Data from Flanders: https://www.vreg.be/nl/vergelijk-uw-maandpiek-metandere-vlamingen