Energy UK Cover Letter on Delivering a Smart and Secure Electricity System - Interoperability and Cyber Security of Energy Smart Appliances and Remote Load Control - Input and high-level comments

Sep 15, 2026

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Cover letter from Energy UK to the Delivering a Smart and Secure Electricity System consultation, providing high-level comments to support a marked response form. The letter welcomes government engagement and urges recognition of two priorities: managing complexity and rapid change in emerging energy service agent markets, and adopting an options-based regulatory approach that avoids obstructing the evolution of demand side response functionality. It also requests appropriate industry lead times, referencing lessons from the 2021 Electric Vehicle Smart Chargepoints Regulations. The letter seeks continued collaboration on technical delivery options and reiterates support for a smart, secure system enabling consumer value and Net Zero transition.

LanguageEnglish

CategoryLetters

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Pages2

Reading Time1 min

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Energy UK Cover Letter on Delivering a Smart and Secure Electricity System: Interoperability and Cyber Security of Energy Smart Appliances and Remote Load Control

Welcome and high-level purpose

Key considerations: complexity and options-based regulation

Key considerations: appropriate industry lead times

Next engagement and continued collaboration

Reaffirmation of Net Zero and consumer benefit

Sent via email [to](to SSESconsultation@beis.gov.uk)[ ](to SSESconsultation@beis.gov.uk)[SSESconsultation@beis.gov.uk](to SSESconsultation@beis.gov.uk) 28 September 2022 Energy UK Cover Letter on Delivering a Smart and Secure Electricity System: The Interoperability and Cyber Security of Energy Smart Appliances and Remote Load Control I am writing on behalf of Energy UK to input into the Delivering a Smart and Secure Electricity System consultation. This cover letter provides high level comments on the overall consultation to supplement our marked response form. Energy UK is the trade association for the energy industry with over 100 members , from established FTSE 100 companies right through to new, growing suppliers, generators and service providers across energy, transport, heat and technology. We represent the majority of the energy sector excluding networks and upstream oil and gas. Our members are highly active in the electric vehicle (EV) , low carbon heating and smart metering space. They offer EV tariffs, smart charging , leasing and selling of EVs , installing and operating chargepoints in homes, businesses and in the public domain. They also provide home heating services to customers, comprising a range of products including electric heating technologies, radiators, hot water tanks, microgeneration and batteries. We firmly welcome this consultation and are encouraged that government is actively looking to engage industry on the topic given the intricacies of smart systems. Overall, Energy UK strongly urge government to acknowledge two key considerations which will help ensure that industry can truly deliver the best possible outcomes for consumers and the energy system, in both the short and medium terms. • Complexity and speed of change in ESA markets: ESA markets are nascent and not homogenous, yet also highly innovative, complex and fast changing. The breadth of demand side response (DSR) applicability itself, its definition and the reality of the service are not yet fully known and will change to realise full potential. Within this context, overly prescriptive mandation of standards , burdensome compliance requirements or stringent governance arrangements may risk obstructing the evolution of the best deliverable functionality of DSR in each technology. We therefore support an ‘options-based’ approach to regulation that is equal to the associated risks , and urge government to work closely with industry in defining and evolving these options. Any governance arrangements should similarly include suitably fast and cost-efficient mechanisms by which they can evolve. • Appropriate lead times for industry to deliver: We urge government to also learn from the experience of implementing the Electric Vehicle Smart Chargepoints Regulations 2021 when establishing lead times for industry to deliver additional requirements. ESA markets are a composite network of multiple traditional and non-traditional actors, with complex interactions, transactions and existing relationships at play. Due to this complexity, lead time for industry to deliver requirements only begins, at its very earliest, with sight of draft regulation. There is a need to balance pace of delivery to ensure consumer benefit and protection, with industry’s ability to develop the best possible products and services for these consumers. We look forward to the next stage of engagement regarding technical design of delivery options, which many of our answers to this consultation’s questions are contingent upon. We are therefore eager to continue collaborating with government as policy and requirements develop over the coming months , and suggest that further consultations take the form of smaller pieces split, for instance, by technology or timeline. We are also willing to support any informal government effort to explore means of engagement prior to formal consultation via ourselves and our membership. Finally, we wish to reiterate our support

FAQs

What is the purpose of this Energy UK cover letter in the consultation?

Energy UK submits high-level comments for the Delivering a Smart and Secure Electricity System consultation to supplement its marked response form.

Which two key considerations does Energy UK ask the government to acknowledge?

Energy UK emphasizes (1) complexity and speed of change in ESA markets and supports an options-based regulatory approach, and (2) appropriate lead times so industry can deliver effectively while protecting consumers.

What does Energy UK propose for future engagement with government?

Energy UK looks forward to collaboration on technical design of delivery options and suggests additional consultations be split into smaller pieces, such as by technology or timeline, with openness to informal engagement prior to formal consultation.

Sep 15, 2026

Upload by Mabel