However, we will act to ensure that consumers are able to switch their energy supplier without their smart chargepoint losing smart functionality. Consumers’ interests are best protected when the chargepoint they install can be used with any supplier. Consumers should be able to switch supplier and retain the full smart functionality of their device. Government is concerned that chargepoints could be designed such that they are unable to work with a full range of energy suppliers. The legislation will require that chargepoints retain their smart functionality following a change of energy supplier.
Government is still exploring the options for achieving smart charging interoperability, including GB smart metering, BSI PASs 1878 and 1879, international standards and market-led approaches amongst others. The type of interoperability proposed in our consultation is just one way of delivering interoperable outcomes for consumers, and Government intends to gather further evidence on the most effective and proportionate approach to doing so as part of Phase Two.
We think that addressing interoperability in Phase Two is the most appropriate approach, to ensure any interoperability decision is in line with wider policy development underway for smart systems and load controllers (see chapter 3 for further detail). As set out above, we intend to consider additional, more detailed requirements on cyber security in Phase Two, and addressing interoperability at the same time will allow us to define these requirements in tandem. Interoperability remains a fundamental policy principle for Government’s approach to smart charging.
Our intention remains to require smart interoperability as part of our Phase Two approach, and we will continue to work with stakeholders – including through the Electric Vehicle and Energy Taskforce – to find an appropriate means of doing so. Grid stability: randomised delay function In the consultation, Government proposed that smart chargepoints must have a function that randomly delays the start time of any load control action. This randomised delay function will help reduce the risk of potential grid stability issues where large numbers of chargepoints switch on or off at the same time.
Many respondents were supportive of this approach as a way of helping maintain grid stability, particularly when recovering from power outages. However, many noted concerns around potential negative impacts on user experience and urged Government to consider a consumer override and a short maximum delay time. Government will be requiring chargepoints to implement this function, following the precedent set by smart metering and the SMETS2, and the approach outlined in PAS 1878.
To address concerns about consumer experience, chargepoints will need to have the capability of applying a remotely configurable randomised delay of up to 30 minutes, though by default they will only need to apply a delay of up to 10 minutes. In addition, the chargepoint must be configured in a way that allows the user to override this delay function. This function will not be required when a chargepoint is responding to a response DSR flexibility service (for example, grid balancing services requiring fast response times), or when a randomised delay has already been applied to the intended operation (for example, via a price signal received over the smart meter Home Area Network).
This functionality has already been successfully employed by the GB smart metering system to help mitigate grid stability risks and was also included within PAS 1878. As 16