Power Plus Communications response:

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1 Page 1 of 12 Power Plus Communications response: Second Consultation on possible national rollout scenarios for the smart metering cost benefit analysis January 2011 Power PLUS Communications AG Am Exerzierplatz D Mannheim Germany Contact details for consultation response David Pitcher Business Development Manager d.pitcher@ppc-ag.de Number of pages: 12

2 Page 2 of 12 Table of contents 1 Power Plus Communications Introduction ESB requirements Technical Information Technology description Relevant standards Coverage Security Enhanced Smart Grid support Commercial Information Operational models Responses to CER questions Comments on the ESB DLC trials...12

3 Page 3 of 12 1 Power Plus Communications 1.1 Introduction Power Plus Communications (PPC) is Europe's leading supplier of broadband powerline communication (BPL) systems for smart grids. By using existing power networks and converting them into IP based real time communications platforms PPC creates instant, cost effective smart energy networks. The technology is currently used in several smart metering and smart grid projects in Europe. The largest single installation is in Mannheim, Germany, covering an entire city with 325,000 inhabitants. In Mannheim the BPL network provides the communication infrastructure for the smart grid beacon project of the German Federal Ministry of Economics called MOMA. Additionally several smart metering or smart grid trial projects in Germany Switzerland, Poland, Netherlands, France, and Saudi Arabia are using this technology. 1.2 ESB requirements Our BPL system currently has the functionality for the WAN communications layer of the smart metering system detailed in CER/10/082 and can; Facilitate two-way communication with the backend smart metering infrastructure. (for all types of electricity, gas, heat and water meters) Facilitate the collection of both on-demand (real time) and cyclical data (for any time interval) from the meter Facilitate remote operation of the meter to de-energise and re-energise the customer (subject to safety arrangements). Facilitate remote re-configuration and upgrades of meter Our BPL system currently meets the requirements and expectations for the future DLC technology specified in the ESB DLC trials.

4 Page 4 of 12 2 Technical Information 2.1 Technology description Broadband Powerline (BPL) uses the existing power grid to provide a communication infrastructure for smart metering and smart grid. The primary advantage of a BPL system is that it can easily reach any location which is covered by the power grid. Therefore, it provides the ideal and in most cases the most cost efficient solution for smart metering communications. Additionally, in its standard configuration it provides sufficient bandwidth for additional smart grid applications. The use of the internet protocol as a standard communication protocol allows easy integration in any existing backbone structure such as fiber optic or broadband networks. The BPL system of PPC uses OFDM modulation with more than 1000 individual carriers in a frequency range from 1.6 to 30MHz. This assures a very robust and highly-capable communication infrastructure. The system is developed to support the IEEE1901 Standard for Broadband over Power Line Networks (access systems). In its current configuration the available shared bandwidth is 5 to 10 Mbps for every head end (which typically serves one low voltage network segment providing energy to 200 premises/households). This bandwidth is sufficient to support on-demand meter readings in real time and simultaneous cyclical messages being sent by several meters concurrently. For example to send or receive messages to/from 200 meters simultaneously would require 1.6 Mbps (assuming a message size of 544 bytes) which is well within the current capability of the technology. The minimum possible small message latency of the BPL system is in the range of milliseconds. 2.2 Relevant standards PPCs smart grid communication system is compliant with the following standards: RFC791 Internet Protocol RFC 2460 Internet Protocol, Version 6 (IPv6) EIA-232 EIA-485 IEEE802.3 Ethernet IEEE Low Rate WPAN IEEE1901 Standard for Broadband over Power Line Networks: Medium Access Control and Physical Layer Specifications EN13757 Communication system for meters and remote reading of meters Part 1 Data exchange Part 2 Physical and Link layer, twisted pair baseband (M-bus) Part 3 Dedicated Application layer (M-bus) Part 4 Wireless meter readout IEC Electricity metering -

5 Page 5 of 12 Part 21 Data exchange for meter reading, tariff and load control Part 42 Physical layer services and procedures for connection-oriented asynchronous data exchange Part 46 Data link layer using HDLC protocol Part 53 COSEM application layer Part 61 Object identification system (OBIS) Part 62 Interface classes EN Telecontrol equipment and systems. Transmission protocols Part 1 Transmission frame formats Part 2 Link transmission procedures Part 3 Specification for general structure of application data Part 4 Definition and coding of application information elements Part 5 Basic application functions EN Information technology equipment. Immunity characteristics. EN 55024: A1: A2: Information technology equipment. Immunity characteristics. EN 55022: Information technology equipment -Radio disturbance characteristics EN : Power line communication apparatus and system used in low-voltage Part 2-1: Residential, commercial and industrial environment Immunity requirement EN : Electromagnetic compatibility (EMC) Part 3-2-: Limits for harmonic currents emissions EN : A1: A2: Electromagnetic compatibility (EMC) Part 3-3: Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems EN 50178: Electronic equipment for use in power installations EN : Information technology equipment. Safety. General requirements EN : Information technology equipment. Safety. General requirements The BPL system is certified to comply with the following standards EN Information technology equipment. Immunity characteristics. Limits and methods of measurement EN 55024: A1: A2: Information technology equipment. Immunity characteristics. Limits and methods of measurement EN 55022: Information technology equipment -Radio disturbance characteristics Limits and methods of measurement EN : Power line communication apparatus and system used in low-voltage installations in the frequency range 1,6 MHz to 30 MHz Part 2-1: Residential, commercial and industrial environment Immunity requirement EN : Electromagnetic compatibility (EMC) Part 3-2-: Limits Limits for harmonic currents emissions (equipment input current 16 A per phase) EN : A1: A2: Electromagnetic compatibility (EMC) Part 3-3: Limits Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems, for equipment with rated current 16 A per phase and not subject to conditional connection EN 50178: Electronic equipment for use in power installations EN50178:1997 EN : Information technology equipment. Safety. General requirements EN : Information technology equipment. Safety. General requirements

6 Page 6 of Coverage From a technical perspective, 100% coverage across Ireland is possible as our system uses the energy network for communication and will be within reach of all smart meters including gas, water and heat meters. However, from an economic perspective communications in highly rural areas can be better served by other communications media such as GPRS i.e. where the number of repeaters which need to be installed to reach a single property outweigh the costs of using other communications media. The BPL system has its biggest advantages in urban and suburban areas (i.e. villages, towns and cities) environments where there is a requirement to connect a large number of meters in a relatively small area and 100% coverage is achievable. 2.4 Security Integrity and confidentiality of metering data poses the main threat to an end to end smart metering system. A breach of data integrity will result in erroneous data being transmitted with consequences for billing and power grid safety. The disruption of confidentiality of metering data will result in privacy concerns of the affected customers and thus hamper user acceptance of smart metering in general. The risk posed by these threats to the utility results from the widespread roll-out of the smart metering system. To establish a true end-to-end metering system, security has to be established. This requires that only the meter and the Data Storage entity possess the necessary cryptographic secrets (keys, certificates ) and the meter itself encrypts and digitally signs the data transmitted. Both wireless metering standards wireless M-bus and ZigBee Smart Energy provide the necessary security features which are based on state-of- the-art, standardized encryption algorithms. Ideally, the WAN communications module simply passes on the secured data received by the smart meter to the data storage entity and vice versa. This scenario would provide a solution to the risks mentioned above with standardized metering protocols. In the case of the BPL system, which is Internet Protocol (IP) based, additional measures based on tried and standardized techniques can be applied, including TLS, VPNs, X.509 certificates and Radius authentication. These techniques are used today to secure networks and sensitive internet applications including online banking. It is assumed that the data storage entity can be secured by state-of-the-art network security technology. This includes the security of the communications interface via an application level firewall with deep packet inspection. The data storage entity interface to the metering infrastructure should not be directly accessible via internet. VPN tunnels to central nodes in the smart metering infrastructure can create a private metering network.

7 Page 7 of 12 Authentication mechanisms for incoming communications can foil attacks from unauthenticated nodes. It is expected that the usual mechanisms for system protection should be applied to the communications system: ACLs for data access after strong authentication, cryptographic security for data storage, limited physical access to the hardware. 2.5 Enhanced Smart Grid support Our BPL system is being used in smart grid applications such as substation monitoring, control of distribution generators, street lightning, charging stations for electric vehicles and others. There would be no or marginal additional capital costs in enabling additional smart grid functionality. Prioritisation and VLAN segregation is also supported, which enables easy integration of smart grid applications which require an independent logical network structure. The following list of additional services could also be provided by a BPL WAN network: Water meter readings Substation monitoring Voltage optimisation for DNOs DNO network monitoring Controlling decentralised generation e.g. CHP, heatpumps, electric vehicle charging stations and other future smart grid applications Sub metering in apartment blocks Assisted living Home security services Real-time customer information portals providing energy related information (in addition to or instead of the in-home display) Demand response for residential and commercial customers

8 Page 8 of 12 3 Commercial Information 3.1 Operational models The BPL system is currently used in different operational models in either regulated or competitive environments. The system can be operated by the DNO (ESB Networks) or by third parties if preferred. In Mannheim an independent smart grid communication network operator (Vype GmbH) provides competitive communication services to the DNO (for substation monitoring), energy suppliers (for billing purposes) and other smart grid parties. Figure 1: Mannheim Smart Grid operational model 1 MVV Verkehr (public transport) Service Contract: Data transfer for CCTV and Data transfer for monitoring of ticket vending machines 2 24/7 Metering (Meter Operator) Service Contract: Data transfer for remote metering (regulated billing purposes only) and provision of dedicated data interfaces for the connection of smart meters 3 MVV (Energy Supplier) Service Contract: Communication service for advanced real-time metering customer portal 4 Other Retailer/ Energy Supplier Service Contract: Communication service for advanced real-time metering customer portal 5 24/7 Netz (DNO) Service Contract: Substation monitoring and distribution automation and provision of dedicated ports for SCADA and RTUs

9 Page 9 of 12 4 Responses to CER questions Question Yes No Comments Section Objectives Q1. Respondents are proposed objectives of the National Smart Meter Programme outlined in Section 2. Are you in favour of the proposals? Outline reasons for agreement or YES We are in favour of the proposals but would advocate real-time communications capability as a separate proposed objective or underpinning the existing objectives Without the option for real-time communications the delivery of the existing objectives will be weakened and may lead to customer disappointment. Section Ownership, Display and Provision of Information Q2. Respondents are YES proposed working assumptions outlined in Section 3 relating to data ownership, display and provision. Are you in favour of the proposals? Outline reasons for agreement or Installing a communications system at the current time which allows real time data transfer is future proof. The current assumption that all types of data collection will be half hourly as a minimum restricts the potential to take advantage of the evolving smart grid. We propose that customers should be able to access real time data for electricity, gas, heat and water on modern communication devices e.g. computers, laptops, tablets, smart phones and displays via cost effective web portals. Suppliers and other parties who have a legitimate reason to access half hourly data should continue to do so and should only be able to access to real time data with customer permission. With a BPL system there is no additional communications infrastructure cost to facilitate real-time, two way communications for electricity, gas, heat and water.

10 Page 10 of 12 Section Smart Metering System Functionality Q3. Respondents are YES proposed working assumptions outlined in Section 4.2 in relation to the smart metering functionality requirements. Are you in favour of the proposals? Outline reasons for agreement or Q4. Respondents are proposed working assumptions outlined in Section in relation to the Wide Area Network (WAN) functionality and technology. Are you in favour of the proposals? Outline reasons for agreement or YES The meter specification is not critical for a BPL communications solution as functionality can reside in the communications (rather than the meter) infrastructure if required.. We agree that an IP based communications solution provides price and other information to the home. We note that items 1, 2 and 13 of the electricity meter specification could reside within the meter or the back end infrastructure, depending on which proves to be the most cost effective scenario We support the functionality outlined in section We agree that the lowest total cost of ownership is with a powerline communication system. Results from a project in Leverkusen indicate significantly higher reliability levels (99%) for our powerline system compared to the system trialled by ESB. Q5. Respondents are proposed working assumptions outlined in Section in relation to the Wide Area Network (WAN) provision and management model. Are you in favour of the proposals? Outline reasons for agreement or Q6. Respondents are proposed working assumptions outlined in YES YES We support either ESB Networks or a third party providing a common infrastructure for both gas and electricity communications. Due to the fact that the BPL technology uses the existing power networks we see ESB Networks as being an ideal partner under either option. We are in favour of the proposals and have used short range wireless interfaces such as Zigbee or wireless Mbus in our projects but are equally capable of using any of the other

11 Page 11 of 12 Section in relation to the Home Area Network (HAN). Are you in favour of the proposals? Outline reasons for agreement or Section Implementation Q7. Respondents are YES proposed working assumptions outlined in Section 5 relating to the implementation approach and timelines. Are you in favour of the proposals? Outline reasons for agreement or HAN technologies detailed. BPL technology would work with either Scenario 1 or 2 and we have no preferences We believe the proposed programme implementation timelines are realistic

12 Page 12 of 12 5 Comments on the ESB DLC trials A DLC trial was conducted where 1,200 customers in Mid-West Ireland were given smart meters which used the power line going into their home (Distribution Line Carrier) as the communications technology. The system was based on what is used in a number of European smart metering deployments and the implementation used by ESB Networks generally complied with open IEC standards. Where DLC meets the performance and functional requirements it is generally seen as the system with the lowest total cost of ownership, however outside of towns and cities its implementation cost is prohibitive. The experience of the DLC trial in terms of the technology was that the technology was adequate for monthly cyclical collection of the data and on demand requests where the performance levels were not onerous. However when used to collect profile and other data from the meters on a daily basis it was difficult or impossible to achieve reliability levels greater than 90% on any of the 11 substations used in the trial. ESB Networks concluded that this was due to narrow bandwidth, the small number of available channels and limited intelligence in the protocols. In particular it was difficult to achieve good performance on noisy networks. However, ESB Networks notes that there is significant ongoing work by major utilities in France and Spain in the development and piloting of the next generation of DLC which is set to address the issues identified in the trial. ESB Networks is of the view that should this work be successful, the fact that DLC is an open standards technology which uses exclusive utility spectrum and still probably has the lowest total cost of ownership will likely mean that next generation DLC is a leading option for customers in cities and towns in line with most of Europe. We agree that a DLC and other powerline technologies will have the lowest total cost of ownership We believe that cost may not be prohibitive outside or towns and cities. For example in villages where there are multiple homes within relatively close proximity connected to one substation cost will not be prohibitive. Clearly individual isolated premises may be better served by an alternative communications system. System availability levels in excess of 99% using our BPL system were recorded by German Utility EVL on a project in Leverkusen between 1 st June and 19 th August Noise on these networks is not a problem due to the fact that the BPL system uses multiple carriers (approx. 1000). Table 1 System Reliability Wired M-Bus area Theoretical number of data sets Processed data sets % Electricity (15 min) 1,059,180 1,056, Gas (1h) 148, , Water (1h) 171, , Total 1,379,220 1,375,