ESNA responds to the questionnaire issued by the Radio Spectrum Committee of the European Commission

 

Chairman of ESNA’s standards working group, Teus de Zwart, responds to the public consultation on the Use of spectrum for more efficient energy production and distribution, issued by the Radio Spectrum Committee of the European Commission

In his letter to the committee Teus de Zwart expressed our appreciation of this initiative. He explained that we share the committee’s opinion:

  • That support is needed from communities and public parties to promote the deployment of Smart Grid applications.
  • That the market of new applications and appliances is emerging and that it demands effort from all stakeholders, who are connected and using the energy infrastructure for their businesses and related processes.

ESNA, as initiator and promoter of the Open Smart Grid Protocol (OSGP), is happy to cooperate by giving input to this questionnaire. We are convinced that the important success factor in the deployment of Smart Grid Technology will be the cooperation and integration between the different disciplines of Power, ICT and telecommunication in parallel with the optimisation in the use of different energy sources.

As ESNA we co-operate in the development of international standardisation to support the deployment of new technologies and competitive solutions.

 

 

Teun de Zwart’s reply to the Committee

 

Questions for the public consultation on the use of Spectrum for more efficient energy production and distribution

 

The below questions are grouped in four categories:

      A) smart grid system and services related questions;
      B) communications / data transfer related questions;
       C)
spectrum and interoperability related questions;
       D)
wireless technologies related questions;

Please note that all the responses will be made public, unless a contributor is clearly stating that certain parts of the inputs are to be regarded confidential. It is also to be noted that there is no need to provide an answer to each and every question.

 

 

A) Smart Grid system and services

1. What are the specific security and resilience requirements for ICT infrastructures and services within smart grid systems, if any? See NIST report about Cyber Security (http://www.nist.gov/smartgrid/index.cfm) and the work done by IEC SG3 (Roadmap Smart Grids (http://www.iec.ch/smartgrid/roadmap) and the Working Group Information Security of CLC Smart Grid Coordination Group

 

2. Which services would you regard as "mission-critical" in the context of smart energy grids, and why? What justification, if any, is there for designating dedicated or exclusive spectrum for a specific service? Interaction with customers about demand, local generation and storage in relation with dynamic pricing. Furthermore advanced (distant) monitoring and control by Prosumers, consumers who produce part of their own demand or distributed generation, will be a requirement.

 

3. Which kind of ICT infrastructure (powerline communications / PLC, cable, optical fiber, wireless network, point-to-point wireless connections, mesh network, or a combination of some of these) would be the most suitable to support the critical services in smart grids from your point of view, and why? PLC because it can be low cost, high reliable and with high availability operating under the responsibility of the network operator who is doing the operation and maintenance of the electricity network. PLC is using the assets of those networks. Furthermore PLC is a secure way of information transfer because it is less sensitive for hacking

 

4. How big a portion of the "mission-critical" communications in smart grids can be handled via fixed connections (e.g. with help of PLC, cable, optical fiber) at the moment / in the medium term / in the long term? The PLC can be used totally for the communication and control requirements and needs of "making the Energy System" Smart. Communication and control needs can be extended step by step and there is not really a technical limit regarding medium and long-term flexibility

 

5. Who can provide, operate and manage the necessary ICT infrastructure/platform supporting the critical services – utilities, telecom operators, third parties or …? It should be the network operator, providing this network and services not on a commercial base but in the role of legally responsible party under the electricity acts and regulation. Just to support the deployment of Smart Grid applications in distribution networks and user interfaces.

 

6. What kind of new generic services (tele-control, real time monitoring and management, …) do you expect to emerge with the roll-out of the Smart grid, and what are the expected ICT requirements for such new generic services? We see a high need for interface management between different parties to secure Safety, Information Security and interoperability between systems interconnected. Furthermore the world is changing in the sense that the interfacing parties will be able to take action/decisions themselves.

 

7. Have you encountered problems or risks potentially hindering the deployment of smart grids, for example linked to network and information security or data privacy? The risk is that many parties look at the projects as normal engineering and construction projects. This is the danger because innovation is involved and standards are not available in the amount that is needed; so a project can get a bad image due to new features and modified working processes, faults happen and more time to implement is needed and financially budgets have to be increased.

 

 

B) Communications / data transfer

8. What are the specific data transfer related (or communications related in general) requirements for the "mission-critical" applications in terms of resiliency, latency, data security/privacy, coverage, and (data) bandwidth?

 

9. Based on the above requirements, which communication needs could not be handled by commercial telecommunication networks (e.g. from resiliency, latency, coverage, data speed/amount, data security/privacy points of view)? Why? Because of the high rates of reliability it should be wise to keep the telecom facilities that are needed to manage the networks in one hand and exclusive for the transmission of data and information related to managing the networks. Other telecom networks are used for commercial services, so therefore do not mix supporting of the market with the actual commercial use of the networks.

 

10. In view of the previous question, where would fully owned or fully controlled networks / data connections by utilities be a necessity, and where would it be sufficient to have partly owned, or shared, infrastructure for the purposes of wired and/or wireless communications? Fully owned for monitoring, controlling and protecting the networks - real-time day-to-day operation. Partly owned, for transmission of maintenance information, customer information, etc.

 

11. What are the synergies between utilities companies and telecom operators in case a shared infrastructure is used? Operating and maintaining high reliable infrastructures, but how to deal with commercial issues and competition?

 

 

C) Spectrum and interoperability

12. Do you see any regulatory or other barriers, in particular in the area of spectrum that would hinder co-investment so as to benefit from the synergies (see Question 11); if you do, what are they? RF is used by all kind of parties and stakeholders how to involve them in investing in the system?


13. Is there a need for interoperability of certain services or other areas in the context of smart energy grids at European level; what would such services or other areas be? Ask transmission System Operators.

 

14. For which services and why would harmonized conditions for the use of spectrum on a shared basis at EU level be needed for the utilities' purposes? Which other spectrum user would you consider to be a good partner for sharing and why? RF is not preferred by most utilities. It would be a waste of spectrum to dedicate frequencies specifically for this when many utilities prefer other communication mobile (RF) network providers.


15. What would the economic, social and environmental impact be if the use of spectrum on a shared basis was harmonized at European level for the use by the utilities sector in case of:

a. smart grid applications
b. smart metering applications?

In both cases, it really would not have a significant impact whether or not there was spectrum harmonized at the European level. The most important part related to the harmonization is the types of services and functionality related to those applications. There does not need to be interoperability of these applications across Europe. So how the applications will vary across Europe will vary depending upon many factors including geography, building types, costs, preferences, etc. In order to ensure that consumers receive the most cost effective solutions, utilities must have the freedom and flexibility to choose the best technology for their needs. So it would not make sense to dedicate specific spectrum across Europe since in many situations it will not be even used.

 

16. Which spectrum ranges would be the most suitable ones for the use of spectrum on a shared basis by different smart grid services in the medium / long term? We do not believe that dedicated spectrum should be allocated for this. There are various options available today to utilize existing RF spectrum via various public networks and this ensures that utilities can obtain cost competitive pricing from multiple network providers rather than only using dedicated spectrum with no competition.

 

 

D) Wireless technologies

17. Regarding the use of wireless technologies at different spectrum ranges for transmission of remote readings (distant smart meter locations) or for connections to distant locations of renewable power sources, what are the main technical requirements from the following points of view: coverage, resilience/connection reliability, latency, connection security (privacy of 'sensitive' data), connection bandwidth? The main requirements are reliability and security.

 

18. Which kind of wireless technologies and networks would be the most suitable ones for smart grid purposes in the medium / long term? (technology and network topology examples: GSM, UMTS, LTE, LTE Advanced, private mobile radio (PMR) network, Short-range devices, mesh networks / blended networks,…). The most suitable ones are technologies used for multiple customer types and multiple services in order to ensure the most cost effective solution. So this includes GSM, UMTS, LTE, EVDO and similar evolving technologies.

 

19. Do you see a PMR type of network implemented on a shared platform basis - where a (fixed and wireless) network infrastructure could be used for communications and data transfer purposes by several sectors, e.g. by transport, 'blue light users' and utilities - to be a potential solution? The most cost effective type of platform is not to use a private network but to leverage the competition public network offerings.

 

20. How could such a shared PMR network concept fulfill the requirements of "mission-critical" services in terms of resiliency, coverage, data security/privacy and (data) bandwidth? While PMR could fulfill these requirements, it will not be the most cost effective solution and it is not in the best long term interests of either utilities or customers.

 

 

And finally:

21. Would you have any additional relevant comments for the purposes of this public consultation? We advocate the use of existing RF networks and spectrum rather than allocating additional spectrum specifically for these applications. By using public networks, customers are ensured a cost competitive environment rather than receiving services via a dedicated network with captive customers.

 

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