Executive Summary
Energy UK supports the proposal for Elexon to take responsibility for the enduring governance mechanism. To ensure this governance is delivered effectively, Energy UK highlights the following key positions:
- A key concern throughout the whole consultation is the need for genuine alignment of governance groups with similar functions across industry codes. At present, there is a risk that the REC, SEC and BSC could each establish similar security and technical working groups, each operating to a narrow remit without strategic coordination. To avoid siloed workstreams, active and strategic cross-code coordination is needed.
- Licensed suppliers, load controllers, and wider aggregators (including those who may operate without a licence) are separate entities with unique perspectives and obligations. These should have distinct representation within the groups.
- Representation of different device types is also needed, given the wide scope of appliances within the Smart mandate. For example, some load controllers and/or manufacturers may specialise in heat pumps and/or EVs and will have different expertise and priorities.