towards interoperability within the eu for electricity and ... · european data format and...

44
March 2019 Final Report Towards Interoperability within the EU for Electricity and Gas Data Access & Exchange European Smart Grids Task Force Expert Group 1 – Standards and Interoperability Working Group on Data Format & Procedures

Upload: others

Post on 28-Jun-2020

3 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

March 2019

Final Report

Towards

Interoperability within

the EU for Electricity

and Gas

Data Access & Exchange

European Smart Grids Task Force Expert Group 1 – Standards and Interoperability Working Group on Data Format & Procedures

Page 2: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

2

Acknowledgments

This report was prepared by the Working Group on Data Format and Procedures under the Expert

Group 1 (EG1, 'Standards and Interoperability for Smart Grids Deployment') of the European

Smart Grids Task Force and is a product of intensive work and discussions during 2017-2018

amongst EG1 stakeholders. Special thanks are due to all the experts (see Annex B.5) who contrib-

uted in the course of this work and especially to the extended Editorial Team.

DISCLAIMER

This document is the result of the consensus reached among experts of the Expert Group for

'Standards and Interoperability for Smart Grids Deployment (EG1) within the European Smart

Grids Task Force.

This document does not represent the opinion of the European Commission. Neither the European

Commission, nor any person acting on the behalf of the European Commission, is responsible for

the use that may be made of the information arising from this document.

Page 3: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

3

Final Report

Towards Interoperability within the EU

for Electricity and Gas Data Access & Exchange

based on the findings of the EG1 Working Group

“Electricity and Gas Data Format and Procedures”

Smart Grids Task Force

Expert Group 1 – Standards and Interoperability

Working Group on Data Format & Procedures

Date: March 2019

Page 4: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

4

Content

Executive Summary ..................................................................................................................5 1. Background .............................................................................................................................................. 5

2. Key findings and recommendations ........................................................................................................ 7

Main report: findings from the EG1 investigation on this topic ................................................ 16 1. Introduction ........................................................................................................................................... 16

2. Approach ............................................................................................................................................... 17

3. Interoperability of energy services, data access and data exchange .................................................... 19

3.1. Group focus ................................................................................................................................... 19

3.2. High level legislative options for policy makers ............................................................................ 20

3.2.1. Achieving comparability for interoperable energy services ...................................................... 22

4. National practices regarding data access and exchange & room for convergence .............................. 24

4.1. Findings regarding the Billing Process ........................................................................................... 24

4.1.1. Introduction & purpose ......................................................................................................... 24

4.1.2. Different existing models ...................................................................................................... 24

4.1.2.1. Billing model in France .................................................................................................. 24

4.1.2.2. Billing model in Austria .................................................................................................. 25

4.1.2.3. Billing model in the Netherlands ................................................................................... 27

4.1.3. Conclusions and recommendations on billing process ......................................................... 28

4.2. Findings regarding the Change of Supplier Process ...................................................................... 31

4.2.1. Introduction & purpose ......................................................................................................... 31

4.2.2. Required characteristics for the approach ............................................................................ 31

4.2.2.1. Use of a reference process model that is representative ............................................. 31

4.2.2.2. Requirements for the reference core process model ................................................... 32

4.2.2.3. Use of a role model........................................................................................................ 32

4.2.2.4. Use of a reference information model .......................................................................... 32

4.2.3. Conclusions and recommendations on change of supplier process ..................................... 32

4.3. Findings regarding Processes supporting New and Emerging Services ........................................ 33

4.3.1. Introduction & purpose ......................................................................................................... 33

4.3.2. Emerging information and role models ................................................................................. 34

4.3.3. Roles and responsibilities ...................................................................................................... 34

4.3.4. Business Use Cases ................................................................................................................ 36

4.3.5. Data models for data exchange ............................................................................................. 37

4.3.6. Conclusions and recommendations on processes supporting new and emerging services . 39

Annex .................................................................................................................................... 41 A. Supportive Technical Documentation ................................................................................................... 41

B. Smart Grids Task Force Expert Group 1 – modus operandi .................................................................. 41

B.1. Terms of Reference & Roadmap ................................................................................................... 41

B.2. Group membership ....................................................................................................................... 41

B.3. Working methods .......................................................................................................................... 42

B.4. Meetings ........................................................................................................................................ 42

B.5. Participation in the Working Group .............................................................................................. 43

Page 5: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

5

Executive Summary

1. Background

Note: for the purpose of this report, the terms ‘interoperability’ and ‘convergence’ should be understood

as follows:

‘Interoperability’ is “the ability of two or more devices to exchange information and use that

information for correct cooperation to perform the required functions [IEC61850-2010]”1. In other

words, two or more systems are interoperable, if they are able to perform cooperatively a specific

function by using information that is exchanged.

‘Convergence’ of two or more different systems is the gradual process of changing and developing

similar characteristics in order to become interoperable.

The Steering Committee of the Smart Grids Task Force decided, at its meeting of 17/02/2017, to establish

a Working Group on Electricity and Gas Data Format and Procedures (hereafter "the Group"). That was to

help the Commission prepare the ground for potential secondary legislation, in the context of the recast

Electricity Directive under the Clean Energy Package2, regarding access to data within the European Union

(EU). The original Commission proposal was referring to determining in secondary legislation "a common

European data format and non-discriminatory and transparent procedures" for access to data, which was

then evolved, following the negotiations with the Council and the European Parliament, into "interopera-

bility requirements and non-discriminatory and transparent and procedures" for access to data3. The de-

velopments in the negotiations3 and the evolution in scope regarding this area were closely monitored

and accordingly reflected in the work of EG1, in line with its Terms of Reference4. As a result, the Group

directed its investigation into the issue of converging arrangements in the EU Member States for data

access and exchange for facilitating the full interoperability of energy services5 within the EU.

The Group was asked to map national practices in the EU for data6 access and exchange, for both electrici-

ty and gas, and to reflect on available options or potential steps for making them interoperable. Its deliv-

1 [IEC61850-2010]: IEC 61850, Communication networks and systems for power utility automation, 2010; as quoted

in the EG1 first interim report December 2017. 2 Clean Energy Package: https://ec.europa.eu/energy/en/news/commission-proposes-new-rules-consumer-centred-

clean-energy-transition ; most relevant to this work is the recast of the Electricity Directive COM/2016/0864/final/2 and its Articles 23 and 24 (the co-legislators, the Council and the European Parliament reached political agreement the 19/12/2018). 3 See latest publicly available 4-column document showing the original Commission proposal and the compromise

text –Article 24 for access to data; https://data.consilium.europa.eu/doc/document/ST-7506-2018-REV-7/en/pdf 4 EG1 Terms of Reference of the Working Group on Data Format and Procedures – see section 3.3 on impact from

the negotiation of the respective legislation; https://ec.europa.eu/energy/sites/ener/files/documents/tor_eg1_wg_on_data_format_procedures.pdf 5 EG1 members would like to recall that there are other issues that can help deliver interoperability of energy ser-

vices but are not in the scope of this work. For instance, removing obstacles when it comes to arrangements for suppliers to offer their services in other countries, e.g. the obligation in some countries to install local affiliates be-fore offering energy products to customers. 6 The data concerned is that referenced in the respective legislation:

Page 6: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

6

erable was meant to be a set of recommendations to advise the Commission on the scope and coverage

of a potential EU secondary legislation on interoperability requirements and procedures for access and

exchange of data within the EU.

While performing this task, the Group underlined on several occasions the importance of establishing an

optimum balance between realising the benefits of interoperability and retaining flexibility. This is to be

done whilst limiting the additional costs of reaching and maintaining interoperability that will have to be

borne by the consumer, and continuing to accommodate specific requirements of individual Member

States.

As aforementioned, the work focused on the issue of interoperability and on the respective requirements;

it considered first the semantics (understanding of the information that needs to be ac-

cessed/exchanged)7, and relied upon a business-use case approach. Two main clusters of processes were

investigated with reference to data – namely: two traditional processes, Billing and Change of Supplier, as

well as novel processes supporting new and Emerging Services. These were mapped in a number of EU

countries using a common template, where possible, in an attempt to 'normalise' the descriptions and

facilitate their comparability, for instance in terms of procedures, format, and role models8 relevant to

those processes. The ultimate aim was to identify, after having completed the mapping of relevant na-

tional practices, commonalities, differences, and scope for interoperability.

Throughout the investigation, it was made apparent that, on the way to interoperability of the respective

national practices, what is to be sought is ultimately a reference core process model9 where national prac-

tices could largely fit in, while measures should be taken to allow for national or regional specificities and

customisation. Such a ‘framework’ that can serve as the basis for developing interoperability would in-

clude a core process model using an information model10 (information and semantics) along with a role

model8, and would determine a number of transition pathways to interoperability building on existing

national set-ups and practices. This should guide the Commission, and those national experts to be in-

volved, in the drafting of the secondary legislation, and in weighing the respective policy options and de-

ciding on the interoperability requirements and procedures for access to data and exchange, in line with

Article 24 of the recast Electricity Directive3. In this quest, a number of already available data/information

management models, role models, or ontologies, such as CIM11, HEMRM12, SAREF13, etc. could be already

(i) in the Third Energy Package (Annex I.1(h)): "(ensure that customers) have at their disposal their consumption data, and shall be able to, by explicit agreement and free of charge, give any registered supply undertaking access to its metering data. …; "

(ii) in the recast Electricity Directive COM(2016) 864 final/2 (Article 23(1)): "…For the purpose of this Directive, data shall include metering and consumption data as well as data required for consumer switching... " 7As opposed to syntactic issues which include technical aspects (e.g. formats, technologies used).

8 ‘Role model’, for the purpose of this report, means a model representing core functions/responsibilities in the

energy sector and their interdependence. 9 ‘(Reference Core) Process model’, for the purpose of this report, means a representation of harmonised process-

es for information exchange within the energy sector so that these processes may be implemented as such or as the basis for a customised version according to regional/national business needs. 10

‘(Reference) Information Model’, for the purpose of this report, means a representation of concepts and the rela-tionships, constraints, rules, and operations to specify data semantics for the energy sector. 11

CIM- Common Information Model, https://www.iec.ch/smartgrid/standards/ 12

HEMRM - Harmonised Electricity Market Role Model (by ENTSO-E, EFET, ebIX), https://docstore.entsoe.eu/Documents/EDI/Library/HRM/Harmonised_Role_Model_2018-01.pdf 13

SAREF - Smarty Appliances REFerence ontology.

Page 7: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

7

considered, but whatever model is to be proposed at the end, it has to be inclusive, technology-neutral,

cost-effective and should not favour a specific ICT solution.

Based on these considerations, and in appreciation of the complexity of the task, the Group carried out its

work. This report presents the Group’s reflection, key findings, and a list of recommendations on how

best to proceed with the arrangements for data access and exchange within the EU in order to facilitate

the interoperability of energy services.

2. Key findings and recommendations

There follows a list of key messages from this investigation and of respective recommendations framed as

a result of this work. These should help guide the Commission, and the national experts who could be

involved in the secondary legislation process of drafting the interoperability requirements and procedures

for data access and exchange in Member States, building upon national practices and with a view to facili-

tate the interoperability of energy services across the EU.

MESSAGES

Emphasis should be given to convergence over time, as opposed to short-term obligation to har-

monise, while respecting and building upon established national structures and practices. A very

important prerequisite is to achieve comparability through the adoption of reference models and

other means described in this report.

Distribution of responsibilities to actors, technological basis and degree of centralisation or de-

centralisation often vary between national markets for substantial reasons; so, a controlled tran-

sition towards interoperable markets should be achieved by focusing on high-level Business Re-

quirements, leaving these implementation details to the Member States.

Enabling interoperability to help new services to emerge brings specific requirements with it, be-

yond the adoption of existing standards14. It consists of defining generic Business Use Cases with

adapted roles in order to enable proper implementation of energy data download and share ser-

vices, including customer consent, revocation of consumer consent and service termination.

Emphasis shall be given to ensure that a stable conformity assessment framework is established

at European level in order to support the implementation of the generic Business Use Cases most

of them derived from the European legislation or specific Member States’ needs.

14

Source of mapping of available standards: TNO, ESMIG, DNV-GL study “Digitalising the energy sector: ensuring interoperability for enabling demand side flexibility”, 2018 (Study reference: SMART 2016/0082); https://ec.europa.eu/digital-single-market/en/news/digitalising-energy-sector-ensuring-interoperability-enabling-demand-side-flexibility

Page 8: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

8

RECOMMENDATIONS for follow-up work towards convergence of national practices and poten-

tially reaching full interoperability at European level

Recommendation # 0

On the way to interoperability of national practices for accessing and exchanging data, all relevant

stakeholders must get involved, discuss and negotiate.

Comment:

Our research has confirmed that reference models are not static, as national differences or new use

cases bring forward their shortcomings and the need for their evolution. Therefore, provisions for their

further development, if they are to be utilised, should be put in place. It must be guaranteed that the

bodies maintaining and further developing these models are legitimised by a well-defined and trans-

parent stakeholder involvement and review process.

This is especially important - for instance - in the case of a common Role Model, as the responsibilities

and assignments defined there can have considerable impact on market scenarios and Business Mod-

els and are therefore suited to be of interest for, and influenced by, diverse stakeholder groups. There-

fore, a proper representation of stakeholders’ interests in the selection and maintenance of a reference

model must be ensured.

Convergence is the result of discussing the present national versions of these processes in comparison

to the reference models, trying to understand the differences and the reasons for these differences and

then trying to agree on solutions to reduce or eliminate where possible these differences. The only way

to do this is to sit together with representatives from various regional / national implementations for

these processes and listen to and talk with each other with an open mind.15

Recommendation # 1

Building on available role models8, adopt and use a common European role model.

Comment:

A Role Model for the electricity and gas markets aims at facilitating dialogue between different actors

from different countries through the designation of a single name for each role and domain that are

prevalent within the electricity and gas markets. Based on the business requirements (regulations,

directives, etc.), it is important that the different parties of the involved process (change of supplier,

billing and new services) adopt and use a common Role Model.

The common role model represents responsibilities in electricity and gas markets and in operation of

the system with a focus on information exchange. This is even more important as the clustering of

responsibilities differs from country to country.

Therefore, use one role model that covers the different roles in the energy market for all relevant mar-

ket players and that fits with the integrated energy system that is in place.

15

Core International Reference models can be improved to support new requirements if these requirements are relevant for international use.

Page 9: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

9

Currently available European role models for the energy sector to be used as a starting point:

(i) Harmonized Electricity Market Role Model12 (this role model is not carried out within a standards

organisation): this role model may be extended to enable gas system description and to include GDPR16

related roles.

(ii) Harmonised Gas Market Role Model17

Recommendation # 2

To facilitate interoperability adopt and use a common information model10 for semantics, for exam-

ple consider building on the available IEC CIM model.

Comment:

An Information Model aims to represent concepts, related objects, constraints, rules and relationships

for a chosen domain. It is a powerful tool to specify commonly adopted semantics for data exchange

between actors of the energy domain and describe the precise meaning of energy related terms.

Based on the business requirements, it is important that parties involved in data exchange adopt and

use a common Information Model to represent information. As a second step, in order to reach full

interoperability, message structures and formats (syntactic level) will have to be aligned.

The energy system is more and more interconnected in terms of data exchanges between DSOs, TSOs

and market participants. The electricity market and system operation are also increasingly interlinked.

To maintain the unity required for the recognition of the integrated nature of the energy system and

also allow for necessary differences between the wholesale market and the retail market, it is im-

portant to adopt and use a common information model for semantic.

Existing international information model:

- IEC CIM (Common Information Model for electrical systems) and Data exchange for meter reading

DLMS/COSEM https://www.iec.ch/smartgrid/standards/

In the case of gas:

- standard EDIGAS; https://easee-gas.eu/edig-s

Recommendation # 3

Adopt and use a core process model9, which should allow for national specificities and stay open for

further interoperability over time.

Comment:

It might be easier to first reach interoperability within the EU for new, emerging services (e.g. "down-

load and share my data", "consumer consent" and "consent revocation") rather than traditional ser-

16

GDPR - General Data Protection Regulation (EU) 2016/679. 17

EASEE-gas related work on a harmonised market role model: https://easee-gas.eu/uploads/kcFinder/files/Harmonised%20GRM%20Document_FINAL_2018-05-30.pdf

Page 10: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

10

vices, given that the new, emerging services are not yet in place.

Many of the traditional retail processes, like change of supplier and billing, are already implemented

for many years (15 years or more) in the EU Member States. Many parties, including commercial sup-

pliers, TSOs and DSOs, have invested a large amount of money into the IT development of these ser-

vices over the years. In most EU Member States the traditional processes are more or less mature at

the moment. Meaning that in principle only small adjustments on these processes are being applied.

Large changes require new larger investments. If these changes must be applied in a short period of

time they cannot be absorbed in the normal maintenance process any more, but an expensive dedicat-

ed project is required to change the involved system, which would come with additional cost resulting

in increased costs for consumers.

A recent analysis of the different energy market models used in Europe18 shows that, it is possible to

‘group’ some EU Member States that have similar market models. The group of Member States in a

market model type can be different for different types of services (i.e. change of supplier, billing, mov-

ing etc.). For example, a Member State can be in a group of Member States for change of supplier but

in a different group of Member States for the billing market model type. Therefore, the reference pro-

cess model that can serve as the basis for developing interoperability should be flexible to allow for

national specificities. This enables countries to take smaller steps to reach further interoperability with

other EU Member States.

Recommendation # 4

Business requirements shall be the basis for interoperability and must remain technology-neutral.

Comment:

When setting business requirements in a Europe-wide context, these should be formulated in a tech-

nology- and technical-architecture-neutral way. That is without pre-empting implementation details

that should be left to Member States to define in order to fit national or regional environments and

respective technical solutions. Business Use Case methodology 19 is a suitable approach for this.

Business Use Cases should also use terms and terminology of the common role model and common

information model for coherence.

Focus should be on the Business Layer20; implementation details to the Function Layer20 and below

should be left to Member States. The question of whether to use a centralised or decentralised data

management model is considered part of these lower levels and no preference shall be expressed in

European legislation - Interoperability can be established in and between both approaches.

18

ASSET HORIZON 2020 project – Study no.4: “Format and procedures for electricity (and gas) data access and ex-change in Member States”, by the Tractebel Consortium, March 2018; https://asset.te-ded.com/home/advanced-system-studies/cluster-7/format-and-procedures-for-electricity-and-gas-data-access-and-exchange-in-member-states/ 19

IEC 62559 standard series and IEC 62913-1 Generic Business Requirements Methodology. 20 See SGAM – CEN/CENELEC/ETSI Smart Grids Architecture Model; https://ec.europa.eu/energy/sites/ener/files/documents/xpert_group1_reference_architecture.pdf

Page 11: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

11

Recommendation # 5

Adopt and use available European standards as a basis to improve interoperability.

Comment:

Examples of available energy information and exchange standards, (non-exhaustive list):

IEC CIM profile and DLMS/COSEM https://www.iec.ch/smartgrid/standards/

Canonical CIM is contained in IEC IS 61968-11 (Distribution extensions to CIM). Profiles addressing metering and customers are available in IEC IS 61968-9 and IEC IS 61968-8,

respectively (mapping of 61968-9 to DLMS/COSEM in another series: IEC TS 62056-6-9) Implementation profile for data exchange is specified in IEC IS 61968-100.

All are international standards (with multiple editions). All are IEC CIM. All have been developed and

maintained by international experts in the domain. Whenever gaps are found in the standards, there is

an existing process to fill the gap with new requirements.

When the proposed interoperability solution is making use of available reference models, appropriate

measures must be taken to ensure that access to these, or to supporting documentation, or software,

and thereafter to their updates, is done in an easy and transparent way, and at a reasonable cost, or

potentially free-of-charge. This is particularly important for new entrants.

To facilitate this, national competent authorities could be the ones helping with the costs. For instance,

purchasing or subsiding the purchase of the reference material and of the required licenses to cover

the national needs, or in the case of standards acquiring the respective material and translating them

into national technical specifications that could be made publicly available. This will ensure that there

are no excessive costs prohibiting small players and micro-enterprises from entering the market, and

offering alternatives and novel services.

Recommendation # 6

Monitor the gap between each national practice and the reference core model. Consider means for

maintaining this at European level.

Comment:

Once reference core models have been adopted (one harmonised role model, one common information

model and one core process model), their adaptation will take place in several stages and the pace will

differ from country to country based on the diversity of national context. It will be necessary to monitor

how the national practices of EU Member States compare with these reference models.

- This would give good insight into how the national implementation of energy market infor-

mation exchange compares with the reference models.

- When this monitoring is maintained, another valuable insight is created by assessing if and

how national models can be made interoperable and potentially evolve towards international

models.

The situation for the different Use Cases can vary, therefore the mapping should be monitored per Use

Case.

Page 12: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

12

It is also a possibility to create and maintain - with national support - a European repository of map-

ping of the national practices with respect to the reference models (again with all stakeholders repre-

sented properly).

Member States will retain their national specificities but they will respond to interoperability require-

ments and try to converge with the requirements placed by a European core process model. These

requirements will be a minimum, but sufficient to guarantee interoperability between the countries. Of

course, the adaptation of the model will be done in several stages and the paces will differ from coun-

try to country based on the diversity of national context. An implementation maturity model can be

used here as an instrument to help assess, benchmark and determine the maturity of the implementa-

tion process. There are already a number of maturity models available - also for the use in the context

of Smart Grids21.

Recommendation # 7

Specify information exchange in terms of exchange between harmonised roles.

Comment:

To allow for regional / national variations in processes related to information exchange and to provide

flexibility in future developments, it is important to specify information exchange between roles in-

stead of between actors. An actor in a process basically represents a legal entity (company or person).

An actor can perform a cluster of roles depending on regulation or change in commercial decisions.

When information exchange within the energy sector in all countries is specified in terms of the same,

harmonised roles, the consequences of such differences or changes remain very limited: it basically

comes down to a difference or change in the clustering of roles, but the actual specification of the in-

formation exchange within the context of a business process remains the same.

Therefore, it is important to consider using one role model that covers the different roles in the energy

market for all relevant market players and that fits with the integrated energy system that is in place.

Recommendation # 8

Bear in mind that legal aspects in national markets can be a limiting factor to full interoperability.

Comment:

For each market party, in each Member State, the roles, responsibilities and requirements are deter-

mined by the rules and regulation. The IT implementation of - for example - the change of supplier and

billing procedures are a translation of the national rules and regulation. Since the rules and regulation

are different in each Member State, legal aspects can be a limiting factor to reach full interoperability.

An example is the Nordic process to reach harmonisation of the energy markets. The process of har-

21 See Supportive Technical Documentation that accompanies this report, section on interoperability Governance,

“Possible Metrics and Means to assess degree of Convergence”.

Page 13: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

13

monisation of the Nordic energy markets started in 2005 and is still ongoing. In December 2017 a re-

port was published of a study on the IT and regulatory status of the Nordic energy market22. It was

concluded that one of the most difficult barriers for full harmonisation of the energy markets are the

regulatory barriers. This is also true for reaching full interoperability.

Recommendation # 9

Aiming for interoperability should not be conditional to a cost/benefit analysis. However, how to

reach it and maintain it (in terms of context and timing) could be analysed and optimised through

Cost/Benefit Analyses and Risks/Opportunities Assessments.

Comment:

Reaching and maintaining interoperability is a final goal to achieve, at a date yet to be defined. How-

ever, optimised convergence steps/timeline towards full interoperability at this date should be defined

by each Member State.

Since the start of the liberalisation of the energy markets in Europe, market parties and network oper-

ators have been making significant investments and efforts to comply with national market rules in

each of the energy markets they operate in. The scale of the operation, the maturity of the market and

the complexity-inherent data exchange systems, resulted in different magnitudes of investments by the

different market parties and network operators. The range of the (operational) costs and associated

benefits of operating in different national markets differ from national market to national market and

from market party to market party.

It is also important to bear in mind that all the costs - low or high - will be paid directly or indirectly by

current or future end-customers: through regulated tariffs defined by the National Regulatory Authori-

ty and law and through price increases by the non-regulated parties.

Therefore, we recommend to carry out a cost/benefit analysis with a risk/opportunity assessment for

each Member State to define the relevant timeline and pace of convergence steps.

Recommendation # 10

Bear in mind that reaching and maintaining interoperability is a step-by-step exercise requiring a

roadmap that needs to be duly monitored and accordingly adapted.

Comment:

As the preliminary investigation of Billing showed, to achieve an interoperable European market mod-

el, a core market model might be necessary, but would involve, when traditional processes are con-

cerned, more regulatory intervention into developed and long established national structures. This

might raise concerns regarding subsidiarity, cost effectiveness, would imply greater risk, effort and

22

Harmonisation in the Nordics markets is discussed in this recent publication: "Nordic data hubs in electricity sys-tem: Differences and similarities", 2017; http://norden.diva-portal.org/smash/record.jsf?pid=diva2%3A1164963&dswid=1156

Page 14: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

14

stronger resistance, and could require an extended transition or implementation period.

The reason for why we suggest such a softer approach is that we consider national market design,

standardisation and digitalisation/automation levels to be far apart today. We expect much less re-

sistance, as the European principle of subsidiarity is retained. The roadmap for a governance frame-

work could be to first architect a baseline, clearly showing the detailed model in each country and its

positioning in a reference architecture (e.g. SGAM20), as well as mappings to a common information

model, then establish a “preliminary and not mandatory” European core process model as a Vision.

Then establish a dynamic framework that allows for each country to reach interoperability over time in

a controlled, flexible way respecting local optima, already-done investments and cost effectiveness.

PROCESS-SPECIFIC RECOMMENDATIONS – a non-exhaustive list based of the findings of this investiga-tion; their description can be found in the related processes’ sections in this report along with some pro-posals for role models and Business Use Cases.

On Emerging Services

Recommendation # 11

New emerging business use cases related to emerging services should be described using the meth-

odology followed in the report.

Four business use cases have already been described and are available in the accompanying docu-

ment21 as basis for implementation: “download my data”, “share my data”, “revoke consent” and

“terminate service”.

Recommendation # 12

Existing role models should be extended to take into account new roles and the diversity of imple-

mentations enabling new services.

Recommendation # 13

If an external service is cancelled, the Consent Registry responsible needs to be informed to handle

future activities. Service termination must propagate termination of consent previously given by the

consumer.

Recommendation # 14

If a consent is revoked by the consumer, all concerned service providers and third parties must be

informed immediately to handle future activities.

Page 15: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

15

On Billing – referring to data exchanged between actors in the energy sector and not the end bill

Recommendation # 15

As billing is closely related to the legal aspects of the national markets, convergence - to the extent

possible - of legal aspects is important for furthering interoperability.

Recommendation # 16

The reference model should encompass different models for billing taking into account significant

national characteristics.

Recommendation # 17

Building billing interoperability should not restrain an organisation's competitive communication

possibilities nor undermine the dynamic innovative trends (digitalisation / new service develop-

ments).

Page 16: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

16

Main report: findings from the EG1 investigation on this topic

1. Introduction

Customers are entitled, in line with the current legislation23, to receive free of charge their electricity and

gas consumption data, and allow access to it to any registered undertaking or a third party of their choice.

It is the task of the national regulatory authority to facilitate this through an easily understandable and

harmonised framework for the respective data24. These provisions are meant to ease customers' access

and understanding of their own consumption, and also use of this information to compare offers from

energy suppliers or other service providers – including different tariff options. Moreover, the introduction

of smart meters, further enriches this data25 and could help create broader value propositions for con-

sumers beyond energy supply.

To facilitate this, and ensure that the required data access and data exchanges among eligible parties

happen via trusted mechanisms, in a transparent and non-discriminatory manner, standardised national

arrangements need to be in place. These should cover a semantic model of the data to be exchanged, the

content of data, potentially the format in which data is provided to parties, and the systems and proce-

dures, including communications protocols used for the control, access and exchange of this data in line

with the EU General Data Protection Regulation16. Convergence of such arrangements within the EU could

facilitate the interoperability of national and cross-border services and products, in the interest of the

European internal energy market and of its consumers.

This Group investigated how best to move forward towards converging of national practices in the EU

regarding data26 access and exchange, for both electricity and gas.

The outcome of its work is a set of recommendations, framed following consensus amongst its members,

on the scope and coverage of a potential specific EU secondary legislation that will set up the require-

ments and the procedures for such arrangements on data access and exchange and facilitate reaching and

maintaining full interoperability of energy services within the EU (in accordance with Article 24 of the

recast Electricity Directive).

23

Directive 2009/72/EC and Directive 2009/73/EC; point Annex I.1(h). 24

Article 37(p) of the Electricity Directive, Article 41(q) of the Gas Directive. 25

Cf. also Articles 9(2) and 10(2) of Directive 2012/27/EU (the Energy Efficiency Directive). 26

The data concerned is that referenced in the respective legislation:

(i) in the Third Energy Package (Annex I.1(h)): "(ensure that customers) have at their disposal their consumption data, and shall be able to, by explicit agreement and free of charge, give any registered supply undertaking access to its metering data. …; "

(ii) in the recast Electricity Directive COM(2016) 864 final/2 (Article 23(1)): "…For the purpose of this

Directive, data shall include metering and consumption data as well as data required for consumer switching... "

Page 17: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

17

2. Approach

The Group agreed, when drawing its terms of reference (ToR)4, during its first phase of activities to map

national practices in the EU regarding data access and exchange and then identify commonalities, differ-

ences and room for convergence, and consequently how to bridge the gaps focusing on reaching and

maintaining interoperability (see roadmap in Annex B.1). In doing so, there was an attempt to also inform

the investigation with some first thoughts on cost and benefit drivers for such an operation (see docu-

ment accompanying this report). It is noted that, the Group remained informed throughout its investiga-

tion on changes, as a result of the legislative negotiations, in the relevant article for access to data (under

the recast Electricity Directive), and accordingly adjusted its work to accommodate the new require-

ments. That was a point already foreseen in its ToR.

The work proceeded in line with this agreement. Furthermore, the Group reached consensus on the de-

tailed strategy that it followed in order to speed up the progress and tackle this complex task. In detail, in

this investigation, it was agreed to:

i. Consider both traditional and new and emerging processes27, for electricity and gas, and launch

parallel working streams to address them, to allow time to deal with difficulties/obstacles in col-

lecting and analysing data and to accordingly refine the convergence strategy and investigation

based on best practices and lessons learnt (see e.g. Nordics' experience with harmonisation22)

○ Traditional processes: starting first with Change of Supplier, and then Billing;

○ New & Emerging services: (i) "Download my consumption/generation data"; (ii) "Giving

access to my (consumption/generation) data to third parties (historical data)"; (iii) "Giving

access to my (consumption/generation) data to third parties (near-real time data)”.

ii. For each one of these processes, identify:

○ roles and procedures (e.g. role model).

○ type of information exchanged (semantic model, identifiers, etc.).

○ data formats used (XML, CSV, …)

○ data exchange technology used (HTTP, FTP, Platforms, security, data privacy, perfor-

mance, validation, authentication, non-repudiation, …)

i. Draft a common, basic, template to be used, where possible, for the description of processes and

ease benchmarking

○ run it at first instance for few countries (mainly those for which members had better ac-

cess to information) to get indications on common features and differences, and later

confirm these based on a wider sampling;

○ in the light of the above proceed with the investigation on the potential for convergence

of national arrangements.

At the same time, the Group agreed to comment and give feedback to the ASSET external study18

launched by the Commission on national practices for electricity and gas data access and exchange. The

27

For the purpose of this document processes are understood to be implemented via procedures.

Page 18: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

18

findings of this study, particularly regarding elements on data management arrangements and role mod-

els for these processes, also provided input to the Group's work.

Page 19: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

19

3. Interoperability of energy services, data access and data exchange

EG1 and its ad-hoc interoperability subgroup investigated general concepts for reaching and maintaining

interoperability between national European energy markets, taking into account existing developments

and proven-in-use structures. The Group appreciated that interoperability differs from harmonisation

which goes much further but could be retained only as a long-term vision (Figure 2).

3.1. Group focus

According to most available definitions, interoperability can be understood in different levels (see SGAM20

Domain/Zone/Interoperability Layer concept in the figure below).

Figure 1 Interoperability Layers in the Smart Grid Architecture Model

This Group focuses on "semantic28" first and then "syntactic29" level of interoperability, i.e., so as to not

only to be able to interchange packets of information30 , but primarily to understand the information con-

28

Semantic interoperability - understanding of the concepts contained in the message data structures 29

Syntactic interoperability – understanding of data structure in message exchanged between systems 30

This relates to the so-called "communication layer" of interoperability that links to protocols and specific mecha-nisms for exchange of information in the context of the underlying use case, function or service and related infor-mation objects or data models – reference: CEN-CLC-ETSI Smart Grid Coordination Group M/490: " Smart Grid Ref-erence Architecture"

Page 20: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

20

tained in those packets31. Nevertheless, when new participants enter a market, all layers (technical, busi-

ness process, etc.) must be considered. As SGAM B 2.1 states, “the quality of interoperability can be

measured by the integration effort”. Accordingly, the group studied:

Use case (to give the context for the information to be exchanged)

Role model (tasks, roles and responsibilities)

Semantics (meaning of the information exchanged)

As mentioned earlier, analysing single Use Cases for each Member State and bringing them in line, is a

very complex task, so the Group decided to focus on three Use Cases (what we also call later on ‘process-

es’) and demonstrate the approach herewith. These Use Cases are:

Billing

Change of Supplier

Emerging Services / starting with “download” or “share” “My Energy Data”

The first two cover processes that have evolved differently in each Member State since market liberalisa-

tion, creating and establishing players, business models, domain data and distribution of responsibilities.

The latter is a bit different, as it covers a process that is to be rolled out anew. Therefore, this could al-

ready be established with the requirement of reaching and maintaining Interoperability “in mind”.

3.2. High level legislative options for policy makers

As the investigation of the first two Use Cases – Billing and Change of Supplier – showed, to achieve a

converged European market model, integration and a unified market model may be necessary, but it

would involve more regulatory intervention into developed and long established national structures. This

might raise concerns regarding subsidiarity, cost-effectiveness, and would certainly imply greater risk,

much effort and stronger resistance and could require an extended transition or implementation period.

Therefore, a smarter, more flexible, yet more controllable approach is favoured, sketched in Figure 2 be-

low.

31

Reference: European Interoperability Framework (COM(2017) 134 final; Annex 2 - http://eur-lex.europa.eu/resource.html?uri=cellar:2c2f2554-0faf-11e7-8a35-01aa75ed71a1.0017.02/DOC_3&format=PDF]; "The semantic interoperability ensures that the precise format and meaning of exchanged data and information is preserved and understood throughout exchanges between parties, in other words ‘what is sent is what is under-stood’. In the European Interoperability Framework for public services, semantic interoperability covers both seman-tic and syntactic aspects: (a) The semantic aspect refers to the meaning of data elements and the relationship be-tween them. It includes developing vocabularies and schemata to describe data exchanges, and ensures that data elements are understood in the same way by all communicating parties; (b) The syntactic aspect refers to describing the exact format of the information to be exchanged in terms of grammar and format".

Page 21: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

21

Figure 2 Effects of Interoperability with Convergence versus full Harmonisation

The figure shows the differences between Status Quo, Convergence over time (favoured) and fully Har-

monised Market Models from the viewpoints of Actors, Processes and Data Exchange. Please note that

there would also be other areas affected, such as data models, legal aspects or regulatory control.

● Status Quo column shows national structures that have evolved to their full plurality since the

start of liberalisation.

● Convergence column shows an approach, where national market models use common reference

models and map their roles, responsibilities and information exchanged to that, achieving compa-

rability as a first and very important step. Similar national market models can group themselves

into functional “clusters” and work together to evolve and integrate. Nevertheless, in the medium

term each member state would be allowed to keep national specificities, tolerating that these

might not be interoperable then. Where possible, a “Core Model” might exist showing the things

that are reflected by all national market models. Therefore, we expect far less resistance, a lower

level of risk, a good degree of interoperability and a level of effort that pays off. What is expected

for the future, assuming the approach being implemented, are convergence effects from specific

to generic, as there are clear economic drivers to re-use structures – may it be technical solutions

or e.g. ICT solutions for clusters – and not emphasize unilateral solutions. If there are good rea-

sons for the latter, the philosophy would allow to do so, but there are incentives at least against

markets drifting apart further. As convergence effects need convergence targets, these core and

cluster models might be defined as such and with that goal in mind. The approach is also very

controllable and could be tested and improved over time, which could be the responsibility of a

governance structure or regulatory authority.

● Fully Harmonised column, represents markets with a significant number of identical features,

shows the effects of a centrally prescribed market model, conflicting with national and local de-

velopments. Actors might lose their raison-d’être, business models might vanish, carefully

Page 22: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

22

planned investments might strand. That alone is likely to cause strong resistance, and it will be

very hard to win this argument in those countries with heavy impact. Such an approach would – if

feasible, at the end of the day – provide, by default, the highest level of Interoperability and the

lowest integration cost for players entering new markets. The Group considers that this should be

retained as a longer-term vision, yet for short- and mid-term suggests a more flexible approach.

The Group recommends going step-by-step and over time, which means that there will be the need for a

responsible authority and the use of a structured Enterprise Architecture Methodology.

3.2.1. Achieving comparability for interoperable energy services

As comparability of national environments is key, regardless of which convergence or harmonisation ap-

proach is to be taken, an investigation of available methodologies and models that can be used has been

undertaken. The basic elements for demonstrating the approach were

● M/490 SGAM - the Smart Grids Architecture Model20

● ENTSO-E/ebIX/EFET - Harmonised Electricity Market Role Model12

● IEC CIM - Common Information Model for Electricity11

It is noted that for the areas where these reference models are relevant, a number of alternatives exist

but no preference is expressed within this report. This will need to be carefully chosen when the respec-

tive implementation acts are drafted and it must also be ensured that all stakeholder interests are repre-

sented properly in the selected governance bodies.

Figure 3 Mapping of national use cases to a Reference Core Information Model, for example using IEC CIM

Page 23: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

23

As stated in the respective recommendations, a Reference Core Information Model could be defined at

European level and all national use cases should be mapped against this reference point. National institu-

tions could then be tasked with mapping their national structures to that model, clearly stating the gaps

and its shortcomings. All findings and developments should be published and improved iteratively over

time. This will lead to national comparable “Market Profiles” and better accessibility. It is important that

all follow the same methodology and that “Bridge” and “National Information Model” parts are stored

and accessible at a single repository. For more information and details about the suggested methodolo-

gies, please refer to the accompanying Supportive Technical Documentation, under the Interoperability

Deliverables21.

Page 24: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

24

4. National practices regarding data access and exchange & room for con-

vergence

4.1. Findings regarding the Billing Process

4.1.1. Introduction & purpose

Customers spend a significant part of their income on energy, therefore the energy bill is important to

customers. The billing process is one of the most important processes for energy suppliers. Much of the

supplier's interaction with the customer is through the billing process or related to the billing process.

Many questions a supplier receives from its customers are based on the bill the customer has received.

Usually the national legislation and regulation of a member state has rules for what information, must be

presented on the bill including taxes and levies. Especially the taxes and levies are usually strict and often

have complex rules. Usually a supplier only gets a licence when it is able to follow these rules strictly.

The basis for the supplier's energy bill is the energy consumption of the customer. The energy a customer

has consumed is metered with a traditional or a smart meter. In many member states the DSO is the party

responsible for measuring the energy consumption. The billing process of the supplier usually starts with

the collection of the customers consumption data, which depends on the meter reading schedule of the

DSO or the supplier asks the customer to provide a meter reading (self-meter reading).

4.1.2. Different existing models

4.1.2.1. Billing model in France

In France, billing household customers is done integrated by the suppliers. However, for electricity,

household customers may also have a contract with the DSO and the supplier separately. And then the

customer has two separate bills. In practice, very few customers choose this second model. Since the

supplier is the main contact point for the customer, the DSO has very little contact with the customer.

The minimum requirements for billing and billing information are defined within a legal framework. The

supplier is obliged to regularly send the energy bill to the customer, at least every year based on the actu-

al consumption. If the customer chooses to pay monthly a fixed amount, he will receive an annual bill

including the differences between the price for the actual consumption and the amount paid. Suppliers

have to provide billing information at least twice per year to every customer and quarterly if the customer

have opted for electronic billing or upon request. If the customer has a smart meter, monthly billing in-

formation is made available by the supplier.

The network costs assigned to the individual customer comprise a fixed part and a variable part based on

the customer’s consumption. If the customer has a smart meter he receives a bill with the network costs

based on his actual consumption. Normally the customer receives one bill from the supplier that includes

the network costs that are defined by the National Regulatory Authority (NRA).

The supplier collects the network costs including all the taxes but does not bear the risk of collecting the

network costs. There is a compensation by the DSO for the supplier for these costs with the rules of the

Re-Payment processes. The supplier also collects the taxes in the energy context and pays these taxes to

the DSO and to the tax authorities.

Page 25: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

25

The customer can choose from different price models: fixed price, time of use (on-peak vs off-peak hours,

week day vs week-end…), critical peak pricing. Binding clauses between the suppliers and household cus-

tomers are not legitimate therefore the price model can be changed any time for this type of customer.

Most customers choose to have the yearly bill estimated and divided by 12 in order to pay a fixed amount

per month for their energy cost.

Figure 4 Schematic interaction for integrated billing-smart meter in France

An example of a bill in France can be found in the Supporting Document accompanying this report.

4.1.2.2. Billing model in Austria

In Austria there are two billing models possible. All customers can get one bill from the supplier and one

bill from the DSO or they can decide to get only one bill from the supplier. The supplier offers the models

and the customer can choose from the offered models in the contracting phase.

In the “one bill” scenario the bill received from the supplier includes the network charges. The network

charges are based on tariffs defined by system charges ordinance. The supplier doesn’t have to calculate

the network cost – it has to use the network charges exactly from the bill of the DSO for the bill to the

customer.

The DSO calculates the grid invoice for each metering point in the specific network area based on the

consumption and further parameters. The supplier has to pay the DSO before the due Date which is de-

termined by the DSO. The supplier collects the network costs including the Value Added Taxes (VAT) and

Page 26: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

26

pays these costs to the DSO. The supplier does not bear the risk of collecting all the network costs. There

is a compensation for the supplier for these costs with the rules of the Re-Payment process. In this pro-

cess it is possible for the supplier to get money back from the DSO in case of insolvency or default pay-

ment of the customer and to change the debt collection for explicit claims to the DSO. The supplier also

collects the taxes in the energy context and pays the taxes which are relevant for the grid usage to the

DSO – the DSO pays these taxes to the tax authorities. Other taxes could also be collected by the supplier.

In Austria the DSOs created the data exchange system called EDA (“Energiewirtschaftlicher

Datenaustausch”). A supplier must be registered at EDA or at a party which offers a compatible service

before he can execute all data exchange processes in context of billing. At the registration the legal entity

must be known. For the switching processes there is an additional central hub which is connected to the

EDA-world.

A customer has a contract with the supplier and with the DSO (dual point). Since, in the “one bill” scenar-

io, the supplier is in some cases the main contact point for the customer the supplier can also handle the

network bill. The DSO has also contact details of the customer.

The customer can choose from different price models. The tariff can be changed every time when the

customer has no binding clause agreed with the supplier. A binding clause in a contract between the sup-

plier and a household customer only holds for one year maximum.

Most customers pay the estimated annual amount in equal parts by dividing the annual payment at fixed

intervals over a fixed period of time.

Recently it became also possible to choose a time of use tariff. This tariff requires a smart meter. With this

product, the energy price can change per hour (or per 15 minutes). There are also time of use tariffs for

the network (defined by the regulator).

Figure 5 Schematic for integrated billing-smart meter in Austria

Page 27: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

27

An example of a bill in Austria can be found in the Supporting Document accompanying this report.

4.1.2.3. Billing model in the Netherlands

In the Netherlands the supplier centric model is implemented. Household customers get one bill from the

supplier which includes the network costs and the supplier handles all the customer questions about the

bill. The network charges are based on a capacity tariff. This makes it easier for the supplier to calculate

the network cost. The network costs are simply the tariff per day multiplied by the days the supplier is

active on a connection.

The DSO specifies at the end of the month for each supplier how much the supplier has to pay for all his

customers in the specific network area and issues an invoice for that. There are strict rules regarding

when these costs have to be paid by the supplier to the DSO. The supplier collects the network costs in-

cluding the Value Added Taxes (VAT) and pays these costs to the DSO. The supplier bears the risk of col-

lecting all the network costs. There is no compensation of the supplier for this. The supplier also collects

the energy taxes and pays these taxes to the tax authorities.

In the Netherlands, the DSOs created a datahub that includes all metering points. Change of Supplier is

handled by the datahub. The network costs the suppliers have to pay to the DSO are based on the data in

the datahub. At each metering point a tariff code for the grid costs is specified in the master data. This

way the supplier can calculate the network charges are for each connection.

A supplier must be registered at the datahub before he can execute a switch. At the registration the legal

entity must be known. A customer has a contract with the supplier and with the DSO. Since the supplier is

the main contact point for the customer the supplier handles also the network contract. The DSO has no

contact details of the customers.

The customer can choose different billing models. The majority of the customers choose a yearly fixed

tariff per kWh. It is also possible to have a fixed tariff for two or three years. This gives more certainty to

the customers. Normally the yearly consumption of the customer is estimated and divided by 12. This

results in a fixed amount the customer has to pay per month.

For electricity, the energy is measured by the electricity meter but for gas the energy is calculated based

on the measured consumed m3 gas multiplied by a factor to calculate the amount of energy.

Recently it became also possible for electricity to choose a time of use tariff; this requires a smart meter.

With this product, the tariff can change per hour (or per 15 minutes).

Page 28: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

28

Figure 6 Schematic for integrated billing-smart meter in the Netherlands

An example of a bill in the Netherlands can be found in the Supporting Document accompanying this re-

port.

4.1.3. Conclusions and recommendations on billing process

In many Member States the customer's energy bill is a combined bill which includes the cost of the sup-

plied energy and the grid costs (supplier centric model). When the customer has one supplier for electrici-

ty and for gas he usually receives one integrated energy bill (including the costs for electricity and gas). It

is possible that the network operator for electricity is another than the network operator for gas. In this

situation, the customer deals with three legal entities: the supplier, the electricity network operator and

the gas network operator. The contractual relationship between the customer and the network operators

and the contractual relationship between the customer and the supplier also depends on the legal

framework. The rules in the legal framework also determine to a large extent how bad payment excep-

tions are dealt with. Especially the bad payment exceptions can create much of the complexity of the

information exchange between the DSO and the supplier. This is usually member state specific.

The barriers for a supplier to be active in another member state heavily depend on the similarities of the

legal frameworks in the countries it is operating in. The information exchange is secondary to that.

Page 29: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

29

Recommendation # 15

As billing is closely related to the legal aspects of the national markets, convergence - to the extent

possible - of legal aspects is important for furthering interoperability.

Comment:

As already mentioned earlier (recommendation #8) interoperability needs to be supported by the con-

vergence of the legal aspects of the national market models. This is even more relevant for billing.

Since the cost for energy is a substantial part of the total cost for living for a lot of customers, the rules

and regulation around billing have also links with the prevention of energy poverty and other social

aspects. The rules and regulations around billing also have close links to the energy taxation of the

Member States. It is not desired to harmonise the taxation rules of the Member States. Therefore,

especially for billing full interoperability can’t be reached.

Also mentioned in recommendation #3 the reference model should be able to accommodate national

specificities. This is also especially relevant for the billing processes in the different Member States.

This allows Member States to have different energy taxation rules. The categorisation and description

of the billing services in the reference model can make it easier for some market parties to enter the

energy market of another Member State. It makes it easier, for those market parties, to assess the

details of the market rules and regulation of that Member State. However, different taxation rules

usually require suppliers to be a legal entity and have a physical presence in that specific Member

State. Therefore, the IT interoperability is only a small part of the costs and efforts for market parties

to enter the market of another Member State. Indeed, full interoperability on data access and data

exchange may facilitate entering another Member State market for a supplier but is not sufficient. This

was illustrated, with reference to the investigation of harmonisation of processes, in a study on the IT

and on the regulatory status of the Nordic energy market22. It was concluded that one of the most

difficult barriers for full harmonisation of the energy markets are the regulatory barriers. This is also

true for reaching full interoperability.

Recommendation # 16

The reference model should encompass different models for billing taking into account significant

national characteristics.

Comment:

After investigation of some of the billing processes of different Member States some significant differ-

ences are found. The most significant national characteristics found are:

- The number of contracts between the customer and the supplier and the customer and the

DSO (1 or 2 contracts).

- Basis for the grid tariff. Based on used consumption and fixed tariffs or based on the capacity

of the connection.

- Who bears the payment risk of the grid costs?

- Is billing of the grid cost by the supplier mandatory or optional?

Therefore, the reference model should be able to encompass different types of billing models.

Page 30: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

30

Recommendation # 17

Building billing interoperability should not restrain an organisation's competitive communication

possibilities nor undermine the dynamic innovative trends (digitalisation / new service develop-

ments).

Comment:

Billing is an important communication channel for suppliers to their customers. A bill should be accu-

rate, easy to read and understand, and provide the information that the customer needs to make in-

formed decisions on his/her payment options, consumption, tariff and supplier. This is also true from a

competitive point of view. Bills are a way for suppliers to distinguish themselves from other suppliers.

This way it becomes a competitive communication possibility. Strict harmonisation rules on bill layout,

components and frequency diminishes the possibilities for suppliers to distinguish themselves from

other suppliers. Therefore, undue harmonisation is not advisable in billing models, components, or

frequency.

New dynamic innovations are already happening. A bill could be sent electronically to a customer or

via an app on the customer’s smartphone. These are examples of new innovative trends through digi-

talisation. This also opens the opportunity for new services to the customer. Therefore, interoperability

should not undermine the dynamic innovative trends.

Page 31: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

31

4.2. Findings regarding the Change of Supplier Process

4.2.1. Introduction & purpose

In line with the overall task of the expert group (…to try to find ways of improving interoperability in data

exchange in the energy sector, without having to impose standards….), the subgroup looking into the

Change of Supplier process ventured into the possibilities of using a common reference model for the

data exchange processes as a way to further interoperability while leaving room for some (region-

al/national) variations.

The assumption is, that such a reference core process model9 will be the result of harmonisation reached

by (a representation of) all stakeholders involved.

Additional benefits expected from the use of a reference core process model are:

For new users such a model provides a set of accumulated knowledge and experience (lessons

learned);

For authorities, such as the European Commission and regulators, such a model provides a tool

for the periodic monitoring of convergence achieved.

On these assumptions the subgroup has decided to test this approach by doing a survey on this basis. We

have selected the “Change of Supplier” process, since we expected that this process would most likely

have a high degree of similarity across the member states and since it is a relatively simple process. We

have selected the ebIX® model12 for the business requirements for this process since it fulfils the criteria

we have set (see paragraph 4.2.2) and it is used already for some time in the intended way as a reference

core process model, though be it for a limited set of member states and, initially, for the electricity sector

only. However, in countries with a liberalised retail gas market, the “Change of Supplier” process is also

used for the gas sector.

As a first step the subgroup has drafted a template based on the ebIX® model. With this template we de-

cided to do a trial to verify the approach and asked a small set of member countries to respond. From the

responses it became clear, that we had to simplify the template even further and limit the options for free

format responses to allow for realistic comparisons between responses. As a result, it is fair to say, that

the template represented a reference core process model and that we basically asked to indicate where

the national implementation was similar and where it was not and in case of difference, to describe this

difference. The template has been distributed by CEER (Council of European Energy Regulators) to its

members in July 2018. Till October 2018, twenty responses were received.

4.2.2. Required characteristics for the approach

4.2.2.1. Use of a reference process model that is representative

Use of a core reference model presupposes that such a model is available and that it is representative.

Therefore, it is required to have a platform where stakeholders find each other and discuss the required

characteristics of the model in order to come to an agreement.

For the survey conducted the subgroup has used the business requirements for the process “Change of

Supplier” as drafted by ebIX®. These business requirements are the harmonised result of discussion be-

tween various national representations (though be it, for the time being, limited to electricity).

Page 32: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

32

4.2.2.2. Requirements for the reference core process model

The selected core reference model should be drafted on the basis of input by the business stakeholders

and reflect their harmonised requirements. Where possible the reference core process model should be

drafted on the basis of open international standards.

The selected reference core process model should be open for regional/national customization and

should be technology neutral.

4.2.2.3. Use of a role model

Since regional/national regulations may vary, a reference core process model shall support these various

options the best way possible. A role model defines core responsibilities in a business sector. Companies

perform one or more of these roles. The clustering of roles per company depends on the region-

al/national regulation and on commercial business decisions. Specifying information exchange as ex-

change between roles therefore allows the reference core process model to support variations in regula-

tion.

The reference core process model for “Change of Supplier” used in the survey is based on roles to define

the information exchange.

4.2.2.4. Use of a reference information model

The focus for this report is on semantic interoperability. This interoperability is not only required between

parties in the sector, but also over the various processes for which information exchange is needed. For

example: the meaning of the object “Metering Point” shall be the same wherever this object is used.

Therefore, the use of one common information model as a reference will greatly help to align the mean-

ing of all definitions used in business requirements for processes and data in the sector, regardless by

whom or by which organization the business requirements will be drafted.

The data to be exchanged in the reference core process model for “Change of Supplier” used in the sur-

vey, has been mapped to basic IEC CIM (as a reference information model).

4.2.3. Conclusions and recommendations on change of supplier process

The purpose for the subgroup was to verify the feasibility of the use of a reference core process model9

for regional/national implementations with the possibility for regional/national customisations, as a

means to further interoperability. And if possible to establish some conditions under which this could

work.

On the basis of the results of the survey, we think that working with a reference core process model is

feasible and can help to further interoperability while allowing regional/national customisation. The re-

quirements for this approach as defined in paragraph 4.2.2 can be regarded as recommendations. Addi-

tionally, what has been stated in paragraph 4.2.2.1 applies not only to the reference core process model,

but to the supporting models as well. So, additional recommendations state that in the selection and

maintenance of all supporting models (such as role model and reference information model) all relevant

stakeholders shall be represented.

Page 33: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

33

4.3. Findings regarding Processes supporting New and Emerging Services

4.3.1. Introduction & purpose

The evolution of electricity and gas systems, enabled by innovation and digitalisation, in a global move

towards energy transition, is large and fast. The intensity of this transformation is especially visible at

systems consumption and generation endpoints: new applications related to Smart Homes, Smart Build-

ings, EV charging, smart offers from suppliers, aggregators, etc. Besides, the environment is becoming

more complex with new applicable obligations (e.g. GDPR16), new business models (e.g. blockchains

based, cross-sector applications like insurance). On top of this, new societal and organisational concepts

are developing: Citizens Energy Communities, MyData movement32, etc.

To amplify the development at an EU-wide perimeter of those new services, which rely highly on data

sharing, interoperability and convergence of data formats and procedures are considered as key enablers.

Various third parties are already expressing great interest in itemised consumption data and are seeking

to position themselves in this market by developing or improving services targeting different categories of

end consumers. These groups can include (non-exhaustive list):

● Traditional stakeholders and energy management experts, for example, who believe itemised

consumption data will be useful for improving existing tools and support measures.

● Stakeholders in the digital realm, who seek to position themselves in this new market and incor-

porate consumption tracking in other services: many app developers and start-ups are already in-

terested in the energy consumption data of their current or future users.

● In the context of smart cities, new platforms may be developed to offer services to citizens, in-

cluding some energy consumption monitoring tools

In addition, numerous stakeholders have a key role to play in adding value to energy consumption data by

processing them in a specific manner and, in particular, intersecting them with other data. There are in

fact many ways to use these data, and enriching this type of data should make it possible to develop var-

ied and reliable services to meet the divergent expectations of the various categories of end consumers.

As by definition, emerging services are not all already known and defined; only common parts of the pro-

cedures study that would be needed to enable customers to share their data were considered in this sec-

tion. The functional use cases “download my data” and “share my data”, as described in the EG1 “My

Energy Data” report (2016)33, were reused as an adequate basis for that purpose.

The importance of the General Data Protection Regulation (GDPR16) and, more precisely, the consent of

the end-consumer regarding the transfer of data to other parties have been integrated, in particular the

consent management: in order for end customers to access a full range of services adapted to their back-

grounds and expectations, it is important for all parties to have access to energy data, with informed con-

sent from the customer.

32

See the Declaration of MyData Principles: https://mydata.org/declaration/ 33

EG1 interim report, My Energy Data, November 2016;

https://ec.europa.eu/energy/sites/ener/files/documents/report_final_eg1_my_energy_data_15_november_2016.pdf

Page 34: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

34

Restriction: the scope of the analysis and the recommendations does not cover the direct real-time data

access from the meter, as this issue was already explored by EG1 [Standards and interoperability, 2015]34.

4.3.2. Emerging information and role models

The workgroup established a first analysis based on EG1 My Energy Data (MED) and Tractebel reports18,

completed by inputs brought by EG1 members e.g. Alliander (NL), EDA (AT), Enedis (FR), GRDF (FR).

All studied implementations show differences at a system level, whether centralised or decentralised, but

they can all fit in generic Business Use Case descriptions, which were used consistently with the interop-

erability approach. These specifications cover electricity and gas metering data, or can be easily adapted

to cover both.

Concerning data models, data format and semantic comparison show the coexistence of several data

formats: ebIX, EDA, EDIFACT, IEC Common Information Model (CIM)11, IEC DLMS/COSEM35. Emerging con-

cepts like the overarching ontology SAREF4energy were also analysed36.

4.3.3. Roles and responsibilities

Beyond the already existing pre-defined roles that are involved in already described use cases37, new

roles had to be considered to describe consent collection and management, consistently with GDPR, and

to take into account intermediation roles in national environments that require them (e.g. for countries

working with centralised data hubs). The description of these different roles and responsibility attribu-

tions, which are encountered among Member States, were based on existing models such as the Harmo-

nised Electricity Market Role Model12.

Among already predefined roles, the following were reused:

- The customer is referred to as the “Party connected to the grid”,

- The 1st party (mostly the DSO) as the “Metered Data Responsible”,

- The 2nd party (mostly the energy supplier) as the “Balance Supplier”,

- The 3rd party (which provides the energy data based service) as “Energy Service Company”.

Following that, new roles were defined and used to reflect GDPR provisions38 or to take into account the

various energy system organisation’ choices among Member States:

34

EG1 report, Interoperability, standards and functionalities applied in the large scale roll out of smart metering

and supporting documents: Survey results and Individual country responses, October 2015; https://ec.europa.eu/energy/sites/ener/files/documents/EG1_Final%20Report_SM%20Interop%20Standards%20Function.pdf 35

It has to be pointed-out that IEC CIM and DLMS-COSEM are recognized as key Smart grid standards by IEC TR

63097 “Smart Grid Standardization Roadmap” , and that they have been harmonized through IEC 62056-6-9 “Map-ping between the Common Information Model message profiles (IEC 61968-9) and DLMS/COSEM (IEC 62056) data models and protocols”. 36

https://www.etsi.org/technologies/smart-appliances . See also http://ontology.tno.nl/saref/ 37

see EG1 My Energy Data report for role description, based on GDPR roles & SGTF / Harmonised role models. 38

My Energy Data Role Model from SGTF – EG1 – My Energy Data interim report November 2016.

Page 35: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

35

- The “Consent Registry Responsible”, which collects, operates and deletes customer consents,

- The “Identity Service Provider”, which offers an authentication service to identify the customer,

- The “Access Rights Manager”, which offers an authorisation service to grant a customer the rights to

access data functionalities related to a given metering point,

- The “Metered Data Dispatcher”, which sends metered data to the authorized third party and to the con-

sumer.

The complete set of roles that are needed for the “new emerging services” Business Uses Cases definition

is then:

Party Connected

to the Grid (*)

A party, also described as the “customer”, that contracts for the right to con-

sume or produce electricity and gas at an Accounting Point

Balance Supplier

(*)

A party that markets the difference between actual metered energy consump-

tion and the energy bought with firm energy contracts by the Party Connected

to the Grid. In addition, the Balance Supplier markets any difference with the

firm energy contract (of the Party Connected to the Grid) and the metered

production.

Is also referred to as “second party” in the document.

There is only one Balance Supplier for each Accounting Point.

Energy Service

Company (*)

A party offering energy-related services to the Party Connected to Grid, but not

directly active in the energy value chain or the physical infrastructure itself. The

Energy Service Company (ESCO) may provide insight services as well as energy

management services.

Additional information: is also referred to as “third party” in the document.

Consent Registry

Responsible

A party responsible for the management of the customer consent registry. He

receives consents and revocation notifications from authorised parties, stores

and operates the consent registry, revokes and deletes consents, and notifies

the execution of requests to concerned parties.

Identity Service

Provider

A party offering an authentication service for parties to identify the customer.

Right Access

Manager

A party responsible for establishing and checking the link between a customer

and a given metering point on request of involved parties. It guarantees that

the customer is authorised to use “data access”, “data sharing” and “consent

management” functionalities related to a metering point.

Metered Data

Dispatcher

A party responsible to send metered data to the customer and to authorised

parties.

(*) Roles already defined in the Harmonized Electricity Market Role Model.

Page 36: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

36

4.3.4. Business Use Cases

Four generic Business Use Cases were defined after having established several examples of customer

journeys that may be encountered in the already existing implementations of the use cases “download

my data” and “share my data”. A specific procedure for “consent revocation” was needed and defined as

a specific use case, as well as the “service termination” which requires consent revocation.

Download my data:

This Business Use Case describes how the customer (“Party Connected to the Grid”) can request data

related to his metering point and how the Metering Data Dispatcher sends metered data (consumption

and/or production) back to the customer in a formalised and standardised way. This allows the customer

to make use of (commercial) tools and services to present and analyse the data.

Share my data:

This Business Use Case describes how an agreement between the customer and a second/third party can

be found in order for the customer to benefit from new services after giving access to his/her personal

energy data to the second/third party.

Revoke consent:

This Business Use Case describes the journey a customer should take to revoke his/her consent given to a

second/third party to access his/her personal energy data.

Terminate service:

In addition to “Revoke consent”, this Business Use Case considers the journey of a customer who does not

want to benefit from the service any more. In this case, it is assumed that the customer implicitly expects

the data collection and the data access to stop.

In this phase of business use case description, the following issues were identified:

● The link between customer and metering point(s) must be precise and up to date for all described

business use cases to be efficient, in particular the information of customers move out should be

propagated to concerned parties without delay to avoid undue data access or deny.

● The link between a customer and a Metering Point is key for the reliable functioning of data ac-

cess and consent management. In some cases the link is not obvious, e.g. to which person(s) from

a family or friends living in the same house should the link be done? Should the link be done with

the landlord and the occupants or both? An additional insight could clarify these questions.

● The propagation of service termination to data providers has not been standardised. This situa-

tion leads to still active data access grants whereas the service is not used anymore: the customer

expects the data access to be automatically stopped, but the service provider is still authorised to

access customer’s data. Hence the loop should be properly closed and the consent registry re-

sponsible should be informed of service termination, in order to de-activate consent and related

grants. For this reason it is recommended to implement this information exchange in “share my

data” and related “service termination” business use cases.

● The customer is mostly free to revoke his consent at any time, regardless of the consequences for

the third-party service. Because this situation may disturb the contractual relationship with the

Page 37: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

37

service provider, it is recommended to implement an information exchange between the consent

registry responsible and the service provider so that the latter can be automatically informed of a

consent revocation, and the first can confirm the acknowledgement of that notification.

4.3.5. Data models for data exchange

What are the minimum requirements to make targeted data interoperable, enable a cost-effective way

to link with and convert to all existing models and pave the way to reach and maintain interoperability?

The existing material from the EG1 report “My Energy Data” and Tractebel report on energy data18 has

been used to identify a core data information model that could be used as semantic pivotal meta-model

for interoperability. More data standards are existing that cover the data for the concerning Use Cases.

Two categories have been identified to download and share data: Master Data and Metering Data. CIM

data elements related to them are given here as an example.39

Master Data, related to the customer:

- Consumer identifier

CIM equivalent: MyEnergyData_MarketDocument/MarketParticipant/mRID

- Metering point identifier

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/MarketEvaluationPoint/mRID

- Optional: customer information, location information (customer, metering point)

CIM equivalent: MyEnergyDa-

ta_MarketDocument/TimeSeries/MarketEvaluationPoint/UsagePointLocation/geoInfoReference

Meter Data, related to the consumption/generation:

- Metering point identifier

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/MarketEvaluationPoint/mRID

- Type of energy (electricity, gas)

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/product

- Metering period

CIM equivalent: MyEnergyData_MarketDocument/Time_Period/timeInterval

- Metering interval

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/Series_Period/timeInterval

- Unit of measure

39

“Download My Data” has been standardised by IEC TC57 WG16 using 62325-351 contextual Model. Compatibility between Meter related classes (EUMED-Metering) and 62325-451-10 (EUMED-Market) will have to be studied.

Page 38: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

38

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/Measure_Unit/name

- Energy quantity (time series)

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/Series_Period/Point/Quantity/quantity

- Optional: quality indicators

CIM equivalent: MyEnergyData_MarketDocument/TimeSeries/Series_Period/Point/Quantity/quality

In the Business Use Case “share my data”, the consent is required by the Metered Data Dispatcher for

GDPR compliance, so that it can give access to the specified energy data for a 2nd/3rd Party.

The 2nd/3rd Party which offers a service based on energy data is itself a data processor, as it uses customer

energy data for service delivery. It needs therefore to also collect itself an explicit consent from the cus-

tomer for its specific purpose(s).

For the Metered Data Dispatcher, the minimum data required for a “data access” consent is:

- Customer identifier

- Metering point identifier

- 2nd/3rd Party identifier to which consent is given

- List of data to which access has been consented - related to meter data and master data

- Validity (starting, ending)

- Optional: storage and utilization conditions (time limitation). The reason why this is optional is, that

the Consent Registry Responsible probably should not have insight into what the data is used for.

Please bear in mind that the Purposeness principle of GDPR must be respected.

In this phase of minimum core data model definition, three issues were identified:

● Locational information: a generic shared ontology would be welcomed. It should clarify the dis-

tinction between metering point, delivering point and customer location, as these terms may lead

to a confusion when it comes to locational information. Besides, there are usually consistent na-

tional representations to design a postal address, but no European standard is available to charac-

terise an address in the same way.

● Time series: there are several syntactic solutions to describe time series (timestamps, interval

blocks, …) and many other meta data to characterize it. Which metadata may be considered as

minimum requirements (e.g.: timestamp, quality, …)

● Metering data: the workgroup concentrated on consumption/generation data. May other physi-

cal values also be measured and shared: power peak, reactive power, voltage, … ?

To conclude on data models, the adoption of one single reference ontology as an interoperable data

model is very welcome, so that each data format may be translated to the reference model.

Page 39: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

39

4.3.6. Conclusions and recommendations on processes supporting new and emerging

services

The recommendations that are applicable for Member States are following:

1. Clearly identify and define all required roles to describe general business use cases and allow all pos-

sible implementations at system level.

There is an existing Role Model on European level available to start new business use cases description:

the Harmonised Electricity Market Role Model40.

In the context of emerging services, this existing role model needs to be adapted in order to fit with gas,

and new roles will be needed next to existing ones in order to enable:

· A party responsible for customer identification and authentication

· A party responsible for guaranteeing the rights for a customer related to a Metering point

· A party responsible for the Consent Registry, which manages consents (storage, revocation)

· A party responsible for sending metered data to authorized third party

It is important to clearly identify the customer (“Party connected to the Grid”) and to establish an unam-

biguous link between him/her and the metering point used for energy supply/generation. The identity

and the link should be verified during the contracting phase and checked again when receiving data ac-

cess requests, as they will prevent undue data accesses (e.g. after a customer move).

Recommendation # 12

Existing role models should be extended to take into account new roles and the diversity of imple-

mentations enabling new services.

2. Describe Business Use Cases and do not forget to consider the proper completion of the use cases

Business Use Cases are described in the appendix and available as basic models on European level. These

descriptions should enable a wide range of implementations which encompass all existing and future sys-

tem configurations, with respect to GDPR. In the future, new business use cases related to emerging ser-

vices may also be described using the same methodology).

Recommendation # 11

New emerging business use cases related to emerging services should be described using the meth-

odology followed in the report.

Four business use cases have already been described and are available in the accompanying docu-

ment21 as basis for implementation: “download my data”, “share my data”, “revoke consent” and

“terminate service”.

40

In many countries the Harmonised Role Model is used in the downstream/retail part of the market for both elec-tricity and for gas.

Page 40: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

40

The proper completion of Business Use Cases is particularly important for the efficiency of the implemen-

tations:

when a customer revokes a consent for data sharing or terminates a service basing on her/his energy data

access, both Consent registry responsible and the 2nd/3rd Party which provides the service should inform

themselves respectively of the service/data sharing ending. If they don’t, they are likely to face unwanted

situations such as, for the 2nd /3rd Party, having technical access to a person's data who is no longer a cli-

ent of its services, or trying to deliver a service while the customer has already cut access to his/her ener-

gy data.

Recommendation # 13

If an external service is cancelled, the Consent Registry responsible needs to be informed to handle

future activities. Service termination must propagate termination of consent previously given by the

consumer.

Recommendation # 14

If a consent is revoked by the consumer, all concerned service providers and third parties must be

informed immediately to handle future activities.

3. Use a Common Information Model and carefully address practical issues, on all levels; no matter how

small they might seem, they could hamper convergence.

There are international reference models for information exchange: EDIFACT, ebIX, IEC CIM, IEC

DLMS/COSEM, Edigas-XML. They can be used to define data formats applicable for information exchang-

es. The existing international Common Information Model, defined by the IEC, is one available standard

for information exchange41 for electricity systems; it can be reused and adapted to fit for purpose, like the

inclusion of gas data.

The fast growth of emerging services will be possible when data formats will be based on a common “ref-

erence ontology” which will define univocally a core minimum list of reference terms covering master

data (information related to the customer), metering data (information related to the consump-

tion/generation) and consent data (information on the consent for data sharing).

Reference data relates to common standardised representations: units, time, and address. There is cur-

rently no European standard to characterise an address: a generic shared ontology would be welcomed.

This ontology should also be able to integrate the separate notions of “metering point” and “delivery

point” – which can both differ in locational terms from the customer location.

41

Committee Draft document 57-62425-351-10-CD1 (IEC 2018).

Page 41: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

41

Annex

A. Supportive Technical Documentation

Technical information supporting the findings presented here as well as the respective deliverables pro-

duced by the Working Group can be found in a separate document accompanying this report.

B. Smart Grids Task Force Expert Group 1 – modus operandi

B.1. Terms of Reference & Roadmap

The Group's Terms of Reference (ToR), defining amongst others the scope and structure of its work, were

timely drafted, submitted (the 30/06/2017), and finally validated by the Steering Committee. This final,

approved version has been made available online on the dedicated web site of the Smart Grids Task

Force4. Moreover, the Group developed a roadmap, as one of its first outputs, with key milestones and

deliverables foreseen throughout its mandate.

Figure A1 – Roadmap for this Working Group

After the initial slow start, and following on the momentum built at the end of last year, the Group mem-

bers were extensively more involved in the respective tasks mainly through the ad-hoc subgroups (“in-

teroperability”; “billing”; “change of supplier”; “emerging services”) that were formed to progress with

the work. These informal structures gave the opportunity to also pull further expertise from the associa-

tions represented in the Group, and further advance with the work. Instrumental to the successful com-

pletion of this exercise have been few key contributors, the subgroup leaders, and the coordinating ef-

forts of the Editorial Team.

B.2. Group membership

The external experts– main representatives and their alternates – who were members of this Group and

their affiliation, can be seen below. Changes in the original composition notified to the Steering Commit-

Page 42: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

42

tee with the ToR are also indicated. The listed members in this Group have been nominated by the organ-

isations participating in the Smart Grids Task Force Steering Committee, and undertook their work by

means of their own resources.

B.3. Working methods

The Group, as already agreed in its ToR, proceeded with the work, as well as with its specific deliverables

based on consensus among all actors involved.

In order to progress with the work, as mentioned earlier, the Group decided to take a practical step and

form four ad-hoc working teams (subgroups) that were asked to investigate in depth the relevant issues in

three processes – change of supplier, billing, support to new and emerging services – and the horizontal

issue of interoperability. It was agreed that the subgroups' findings would need to be approved by the

whole assembly of EG1 to be considered as valid outcomes.

The Group reported on its overall progress to the Smart Grids Task Force Steering Committee, through

two interim reports, in addition to this final report.

The work and the drafting of the respective deliverables with inputs from Group members was coordinat-

ed, since its establishment, by an Editorial Team (ET) of five who were assisted by a few key contributors

and the European Commission. The Editorial Team was set up at the kick off meeting, in line with the

agreed ToR, and consisted of members from the following organisations: CEER, Eurelectric, ENTSO-E,

ESMIG and ebIX (see list of experts below).

B.4. Meetings

Since the establishment of the Group, and its kick off meeting the 24/05/2017, seven more physical meet-

ings with the whole assembly were held in Brussels, chaired, and organised by the European Commission,

at its premises. These were two meetings in 2017, the 22/09/2017 and the 07/12/2017, four more held in

2018, the 19/03/2018, 18/06/2018, 02/10/2018 and 10/12/2018, and a final one the 18/02/2019. At the

same time, the ET and the subgroup teams were engaged in regular, mostly weekly, teleconference, and

also dedicated face-to-face meetings, to progress with the work and coordinate actions.

During the first reporting period, members of the ET participated, on Commission's request, in the pro-

gress meeting of a related external study on data that the Commission has previously launched and find-

ings of which could potentially be of interest to this Group.

Page 43: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

43

B.5. Participation in the Working Group

Working Group"Electricity and Gas Data Format & Procedures", chair: European Commission

EC

DG ENER

Manuel Sánchez Jiménez Constantina Filiou Niels Ladefoged Mario Dionisio Michela Marasco

DG CNECT Patricia Arsene

DG GROW Zsuzsanna Dakai

DG JRC

Ioulia Papaioannou Nikoleta Andreadou Igor Nai Fovino

DG JUST Georgios Kiriazis

DG RTD

until Q3 2018:

Patrick van Hove(*)

INEA Mariana Stantcheva

Association Expert Alternate

Nomination of one expert and one alternate

(1) No alternate (2) Multiple functional

player (3) Covering also the

role of supplier (4) 2 experts and 2

alternates (5) EC ask BEUC case by

case, according with the issue to discuss

(*) Changes in composition since last notification to the Steering Committee

CEER Christelle Heng – FR NRA (*) Deniz Erdem – DE NRA

CEDEC(1) (2) Christian Richter – vku (DE) -

EDSO (1) Jean-François Montagne -Enedis -

Eurelectric (1) (3)

DSO issues: Paul de Wit – Alliander Supply issues: until Q2 2018: Kajsa Lilius – Öresundskraft (*)

-

GEODE (1) Franz Fischer – Energie AG -

ENTSO-E (4) Olivier Aine – ENTSO-E Fabio Oliveira – ENTSO-E(*)

Norela Constantinescu –ENTSO-E Kalle Kukk – ELERING (*)

Orgalime/T&D Jean-Luc Roy – GE (*) Sigrid Linher – ORGALIME

ESMIG Miguel Gaspar – SAP Willem Strabbing –ESMIG

ANEC/BEUC (5) Neil Avery – ANEC Francesca Carrettoni, – ANEC (*)

SmartEn [(*)

former SEDC] Chris King – Siemens Digital Grid Layla Sawyer – SmartEn (*)

ENTSO-G (4) Marin Zwetkow – ENTSOG Jef de Keyser – ENTSOG

Eurogas (1) Julien Quainon – DSO GRDF

MARCOGAZ Jos Dehaeseleer – Marcogaz Henk Koorenhof – Gasunie

ebIX Kees Sparreboom – TenneT Vlatka Cordes - Westnetz

CEN/CENELEC (*)

Eric Lambert (*) John Cowburn (*)

Page 44: Towards Interoperability within the EU for Electricity and ... · European data format and non-discriminatory and transparent procedures" for access to data, which was then evolved,

44

Association Editorial Team (ET) composition

CEER Christelle Heng

Eurelectric Paul de Wit

ENTSO-E Olivier Aine

ESMIG Miguel Gaspar

ebIX Kees Sparreboom

Key contributors assisting the ET

EDSO Jeff Montagne

GEODE Franz Fischer; Georg Hartner

CEN-CENELEC Eric Lambert

Ad-hoc Subgroup Subgroup leader (Association)

Change of Supplier Kees Sparreboom (ebIX)

Billing Paul de Wit (Eurelectric)

New & Emerging Services Jeff Montagne (EDSO)

Interoperability since 05/2018 Georg Hartner (GEODE); earlier Olivier Aine (ENTSO-E)