Standards in the Digital Single Market: setting priorities...

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Case Id: ffd91bf6-4d01-44c9-b238-c1b0509dd9e2Date: 31/12/2015 17:33:25

Standards in the Digital Single Market: setting prioritiesand ensuring delivery

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General information on respondents

*Do you wish your contribution to be published?Please indicate clearly if you do not wish your contribution to be published.

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Submissions that are sent anonymously will neither be published nor taken into account.

The Commission may contact you in case a clarification regarding your submission is needed. Ifyou do not wish to be contacted, please state this clearly in your reply.

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* I'm responding as:

An individual in my personal capacityThe representative of an organisation/company/institution

*What is your name?

Ashley

*What is your surname?

Pocock

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+447875112854

*Please enter your email address:

[email protected]

Please enter your telephone number:

*Please enter the name of your institution/organisation/business:

EDF Energy

* Is your organisation registered in the Transparency Register of the European Commission andthe European Parliament?

YesNo

*Please indicate your organisation's registration number in the Transparency Register.

39966101835-69

*Please enter the address of your organisation:

40 Grosvenor Place, London

*My institution/organisation/business operates in:

United Kingdom

*What is the primary place of establishment of the entity you represent?

Great Britain

*Please indicate your main field of business activity and the field of activity related to theconsultation's topic (if not identical to the overall business activity).

Smart Energy

*Please select the description that applies to your organisation.

Enterprise (not SME)

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P/M20

Is your organisation active in ICT standardisation?YesNo

*Please indicate the Standard Setting Organisations in which you are active:

BSI, CENELEC, CEN, IEC,

And if possible:

- The approximate number of person-months devoted to standardisation related activities.

- The percentage this means to the total of your resources.

Questions

II.1 Questions on general framework and problem statement

It is of particular interest to understand if the standards currently under development effectivelymatch interoperability and successfully creating a Digital Single Market. In addition, it isespecially interesting to identify those actions in standards development that could act as asolution for wider industry and public needs, not limited to the specific technologies that havebeen standardized.

Please indicate whether you agree to the following statements and explain your answerbriefly.

Q1.1 - Do you share the Commission's analysis in Part 2 of?this document

YESPARTLYNONO OPINION

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http://ec.europa.eu/information_society/newsroom/image/document/2015-39/analysis_10888.pdf

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*Please explain:

One major issue is that there are many standards which have the same or

similar objectives. It is important to avoid redundancies and overlaps

in standards in order to increase their applicability and adoption. In

addition we observe that many current standards do not encourage

interoperability as they are too generic in content. In respect to the

context of 'data exchange standardisation', ie., data models and

protocols, additional work is needed on 'profiling/use case definition'

to ensure interoperability. It is also worth commenting that the

heterogeneous implementation of standards create an obstacle to the

effective implementation of interoperability.

Q1.2 - ICT is assuming a greater role in sectors of the economy which were not previouslysignificant users of ICT. How do you see for the economy, in particularthe role of ICT standardsbeyond the ICT sector?

Very ImportantImportantModest importanceNot importantNo opinion

*Your comment, indicating a specific sector:

Energy; the need for ICT standards is becoming critical in emerging

areas, such as Smart Metering, Smart Grid, Home and Building Energy

management, Internet of Energy, etc..

Q1.3 - Do you agree that setting priorities for ICT standards at EU level, accompanied by cleartime-tables, could help standard-setting organisations in better organising their work andsupport the Digital Single Market?

YESPARTLYNONO OPINION

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*Please explain why:

There needs to be convergence between EU and International standards

setting strategies to avoid competing standards and conflict between

user communities over their preferences. There is also a need for

consideration for the individual needs of member states, particularly

where unique requirements exist or historical norms have been

established and will take time to change. It is vital that the EU

considers the rapidity of change within ICT sector and the difficulty

for standards to keep pace with this speed of change. It is also

important that 'open standards' are prioritised where possible to

introduce agility and adaptability to maintain their relevance to

emerging technologies, needs and wants.

Q1.4. - What other steps should be considered to ensure that any such prioritisation wouldenjoy broad support of key stakeholders?

It seems necessary to explore European coordination and positions at the

international level and to examine European priorities. to enjoy broad

support of key stakeholders at EU level, the role of the EU commission

is crucial to ensure the consensus between member states based upon

common needs and strategy. New standards development should focus on

needs and gaps not covered in existing standards, either at EU or

International level.

Q1.5 - What would be the most effective instrument at EU level to ensure that any suchprioritisation is taken up by relevant standard-setting organisations? (please select and rank upto 3 instruments)

1 2 3

A Commission Communication

A Commission Recommendation

Standardization requests issued to EU standard-setting organisations andincluded in the Annual Union Work Programme for Europeanstandardisation

Regulation

Priorities stated in the Rolling Plan for ICT Standardisation

No opinion

None of them

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Your comment:

It is evident that the uniform adoption of common standards across the

EU is poor, and as member states increase their commitment to opening up

competitive markets, this will need to change. Voluntary adoption is

unlikely to achieve the desired outcome, and therefore the only

mechanism which will drive change in a reasonable time to benefit

individual markets and consumers is regulation.

Q1.6 - What would be the impact of a priority ICT standards plan defined at the level of the EUon Europe's effort ?to pursue leadership in global standard-setting

POSITIVENEUTRALNEGATIVENO OPINION

*Please explain:

A "priority ICT plan defined at the level of EU" would be effective and

positive if it: 1. takes into account the unique needs of individual

member states, 2. considers international efforts on similar subjects,

3. highlights European that justify the need for a EU standard related

to an existing international standard, 4. addresses gaps that are not

covered in existing standards, 5. takes into account all stakeholder

needs and constraints, 6. ICT standards should contribute to the

de-carbonisation of society.

Q1.7 - What would be the impact of a priority ICT standards plan defined at the level of the EUon the ability of European companies ?to capture new global market opportunities

POSITIVENEUTRALNEGATIVENO OPINION

*Please explain:

There is strong evidence that EU ICT standards are already having an

effect on global competitiveness of EU businesses, and the opening up of

new markets, eg., Smart Grid, Internet of Things, Cybersecurity.

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Q1.8 - Besides establishing a priority ICT standards plan, what other measures could theCommission (or other EU institutions) take to ensure that standardisation plays its role inachieving a Digital Single Market?

It is important that the EU Commission and the Governments of Member

States embed priority Standards within Policy development and Regulatory

Incentives, if they are to be adopted and successfully implemented.

Q1.9 - How should standard-setting organisations best respond to the increasing speed oftechnological development and the integration of technologies in business processes across allindustrial sectors?

A - Regarding the adaptation of existing standards tonew developments:

At least 2 conditions have to be assured: 1. All stakeholders (vendors,

industrialists, regulators, end users, etc.), have to be involved in the

development of the standard, 2. the standards have to be generic enough,

and 'open', to be applicable in the different member states which may

have their own specific needs and constraints.

B - Regarding the introduction of new standards for new:technologies/products

IN addition to the conditions listed in Q1.9-A, it is essential to

ensure coordination between and within stadardisation bodies, both

European and International, to avoid multiple standards covering the

same need, and then creating redundancies, overlaps and conflicts.

Q1.10 - How do you see the involvement of European ICT Standardization experts ininternational standardisation organisations (ITU, ISO, IEC) and global standard settingorganizations (i.e. IEEE, IETF, OASIS, W3C, ECMA international)?

A - The :SCOPE (or LEVEL?) of involvementIs appropriateShould be increasedShould be decreasedNo opinion

Please explain:

It depends on member states, some of whom are strongly involved, whilst

others appear absent from standardisation activities. A European

coordination is needed at the International level. For now, the

leadership on ICT standardisation is held by the USA.

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B - The :QUALITY of involvementIs appropriateShould be improvedNo opinion

Please explain:

To attain consensus and to be able to respond in a timely manner to

rapidly changing market needs and to reflect latest technology,

applications, and use cases, across a complex set of markets in an

effective manner, a more agile approach to standardisation is needed.

This approach needs to anticipate and formulate open and usable

standards ahead of the market and accelerate their development and

readiness for introduction, testing, support and adoption.

II.2 Questions on priority domains for standardisation in the Digital SingleMarket

In this section, the Commission invites survey participants to express opinions and ideas onsetting priorities for ICT standardisation.

The Commission has identified 10 domains set out below, as well as a set of sub-domainswithin each domain. Please note that domains and subdomains are interrelated and thatoverlaps are possible and desirable in particular with respect to synergies between differentsectors. Some domains are horizontal and may benefit a large number of sectorialapplications; some other domains are more sectorial and were identified as areas where ICTstandardisation would bring important benefits.

First check whether the list of domains is complete and relevant. If the list is consideredincomplete, please complement it with additional domains that you consider priority.

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Q2.1 - Please identify and rank the domains (up to 5) and subsequently subdomains (up to 3per domain) within each domain that you consider a priority. If specific domains or subdomainsare missing please add them.at most 5 answered row(s)

1 2 3 4 5

Domain 1: 5G communications

Domain 2: Cloud computing

Domain 3: Cybersecurity

Domain 4: Data driven services and applications

Domain 5: Digitisation of European Industry

Domain 6: eHealth and aging

Domain 7: Intelligent Transport Systems (ITS)

Domain 8: Internet of Things

Domain 9: Smart Cities

Domain 10: Smart and Efficient Energy Use

Others

Domain 2: Cloud computingat most 3 answered row(s)

1 2 3

Application portability

As a service solutions (IaaS, PaaS, SaaS)

Cloud networking infrastructures

Cloud platforms

Moving non-personal data between service providers

Service Level Agreements (SLAs)

Process Computation Integrity

Others

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Domain 3: Cybersecurity

at most 3 answered row(s)

1 2 3

Cyber security design requirements

Process standard for incident reporting

Process standard for cyber risk management

Process standard for vulnerability disclosure

Technical standards for encryption

Technical standards for public key infrastructure

Technical standard for security and privacy by design

Others

Domain 4: Data driven services and applications


1 2 3

APIs for simplified data sharing and reuse between data-driven servicesand applications

Big Data technologies (such as interoperability of Big Data technologies insoftware stacks)

Data licensing conditions

Data related processes (such as data collection, data curation, datamanagement)

Data representation formats (such as XML)

Data service protocols

Entity identifiers for the sector

Metadata schemata

Others

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Domain 8: Internet of Things


1 2 3

Advanced Manufacturing / M2M

Building and Home automation

Energy / Environment monitoring

Medical and health care systems

Reference architectures and related standardised interfaces

Smart cities and communities

Smart living environment for ageing well

Smart farming and food security

Transportation (including ITS, C2C, C2I, automated driving)

Wearables

Others

Domain 10: Smart and Efficient Energy Use


1 2 3

BIM – Building Information Modelling

Building automation and smart appliances

Electrical vehicles integration with smart grid and home managementsystems

Energy efficiency indicators

Heating/Cooling networks including heat supply from waste

Interconnection of electricity, gas and heating networks

Interfaces to Storage systems

Lighting

Power electronics

Smart grids, smart metering

Others

Please answer to Q2.2 to Q2.6 . In your answer pleasefor each of the domains selectedspecify if applicable the subdomains that you have selected.

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*Q2.2 - For the and the subdomains which you have selected,Domain 2: Cloud computingplease explain briefly how the criteria indicated in Box I apply to them.

:We copy the criteria for your convenience

Link to DSM objectives and other EU policies

Competitiveness of the European industry

Clear and achievable targets

Evidence of market relevance and stakeholders needs

Domains where standard setting has direct benefits for consumers

The standardisation of the "Cloud Computing quality of Service"

(performance, security, incident reporting, interoperability, etc..)(

and of the standardisation of distribution of responsibilities between

providers and users is essential to meet the criteria above.

Q2.3 - The Priority ICT standards plan should lead to the production of technical specifications,standards or architectures where there is a need/gap, but could also propose any other type ofstandardisation action such as landscape analysis, gap finding, roadmaps or, ecosystembuilding that could contribute to ensure that standardisation plays its role in achieving a DigitalSingle Market. Please explain if a standardisation need/gap exists in the Domain 2: Cloud

and sub-domains which you have selected.. Please also indicate within whichcomputing time-frame such need could be addressed. Please limit to a maximum of five needs/gaps perdomain or sub-domain:

In addition to the requirements presented in the previous question, the

standardisation of cloud computing should be more homogeneous to allow a

service to be adapted to the needs of the user of the proposed service,

by the cloud computing provider.

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Q2.4 - Among those below, which action could be a priority in the Domain 2: Cloud computingand the subdomains which you have selected? Please rank the list below and explain yourchoice.

1 2 3 4 5 6 7 8 9

• Mandating EuropeanStandardisation Organisations(ESOs) for fast delivery ofstandards/technicalspecifications.

• Foster cooperation amongstandards developmentorganisations for ICT priorities

• Support Research & Innovationprojects to contribute tostandardisation

• Community Building

• Support creation ofpublic-private partnerships - PPP

• Increase strategic coordinationof ICT standardisation at EUlevel.

• Ensure consistent application ofexisting standards

• Accelerate the identification ofICT technical specifications mostcommonly used for theirreference in public procurement

• Other

• No opinion

*Please explain:

Cloud computing is one of the fastest developing ICT sectors, and it is

important that standards are not an after-thought and do not trail

behind continuously developing and evolving cloud technologies and

services. It is also important that in order to reduce development

time, existing standards are fully utilised as part of a suite of Cloud

eco-system standards and gaps are addressed by the collaborative rapid

prototyping of new standards.

*

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Q2.5 - Please indicate any other standardisation initiatives which would help achieving theDigital Single Market in the and the subdomains which you haveDomain 2: Cloud computingselected, and who in the standardisation landscape would be best placed to lead on theseinitiatives:

Landscape mapping, cohesive standards, predictive analysis of emerging

needs, convergence with de-facto specifications if appropriate,

anticipation of next best standards.

Q2.6 - Would your organisation be prepared to invest resources in standard-setting to achievethe priority standards within the proposed time-frames?

Please answer this question only if you are responding as the representative of an

organisation/company/institution.

YESYES, provided some conditions are metNONo opinion

*Please explain your choice and specify conditions:

Where standards are; relevant to market need, benefit consumers,

unlikely to become obsolete before wide-scale adoption, recognise

local conditions and constraints, and are effective.

*

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*Q2.2 - For the and the subdomains which you have selected,Domain 3: Cybersecurityplease explain briefly how the criteria indicated in Box I apply to them.







Cybersecurity is an horizontal domain which applies to many sectors,

some of which are critical. Ensuring the security of ICT

infrastructures of such sectors is compulsory to meet all criteria

listed above. Vital areas where cybersecurity plays a fundamental role

is in the protection of National Infrastructure, notably Smart Metering,

Regional and National Gas and Electricity Distribution Networks/Grids

and the protection of personal data and privacy.

Q2.3 - The Priority ICT standards plan should lead to the production of technical specifications,standards or architectures where there is a need/gap, but could also propose any other type ofstandardisation action such as landscape analysis, gap finding, roadmaps or, ecosystembuilding that could contribute to ensure that standardisation plays its role in achieving a DigitalSingle Market. Please explain if a standardisation need/gap exists in the Domain 3:

and the subdomains which you have selected. Please also indicate within which Cybersecuritytime-frame such need could be addressed. Please limit to a maximum of five needs/gaps perdomain or sub-domain:

As there is a large number of cybersecurity standards (published or

under development), the first priority action should be the

establishment of a 'landscape analysis' of cybersecurity standards at EU

and International levels. Such "landscape analysis" would allow the

identification of overlaps between standards as well as gaps, and then

would help to define the priority ICT standards plan. These efforts have

to be then pushed to the SDO at the international level; For example,

the technical report produced by the mandate M/490 on Smart grids

security has not been promoted into concrete actions, such as a new

international standard project.

*

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Q2.4 - Among those below, which action could be a priority in the anDomain 3: Cybersecurityd the subdomains which you have selected? Please rank the list below and explain your choice.

1 2 3 4 5 6 7 8 9









• Other

• No opinion

*Please explain:

Cybersecurity must adapt quickly to support the fast moving ICT sectors

and those seeking to breach current security practices, and it is

important that related cybersecurity standards are ahead of those

technologies and services which create the vulnerability. it is vital

that cybersecurity standards reflect the need for 'security by design'

to be embedded into the design culture from education and skills

development through research to development and build. It is also

important that in order to reduce development time, existing standards

are fully utilised as part of a suite of Secure Environments, platforms,

devices and applications.

*

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Q2.5 - Please indicate any other standardisation initiatives which would help achieving theDigital Single Market in the and the subdomains which you haveDomain 3: Cybersecurityselected, and who in the standardisation landscape would be best placed to lead on theseinitiatives:

Landscape mapping, cohesive standards, predictive analysis of emerging

needs, convergence with de-facto specifications if appropriate,

anticipation of next best standards.








local conditions and constraints, and are effective. Cyber-security is

fast becoming a central theme for the energy sector, where 'security of

Supply' is threatened, and Consumers are being put at risk of losing

their privacy whilst protection of their data is in question. Energy is

critical to the well being and stability of any member state, and

Cybersecurity attacks are rising and constitute a real threat to public

and economic confidence.

*

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*Q2.2 - For the and the subdomains whichDomain 4: Data driven services and applicationsyou have selected, please explain briefly how the criteria indicated in Box I apply to them.







There is a rising demand for the access to and for analytics associated

with a vast and growing source of static and dynamic data. Failure to

exploit this opportunity leads to poor customer service and ultimately a

loss of competitiveness. Standards are needed to support new types of

sensors and sensor arrays, accessibility to existing data inventories

and catalogues, and to ensure interoperability across all of these

information sources and related hubs. New ad-hoc standards, such as

Hypercat' are being developed to link across open data platforms, and

communications protocols including Zigbee are emerging to assist in M2M

applications alongside Cellular Networks. This is a complex and

challenging arena and will continue to diversify unless standards are

applied.

Q2.3 - The Priority ICT standards plan should lead to the production of technical specifications,standards or architectures where there is a need/gap, but could also propose any other type ofstandardisation action such as landscape analysis, gap finding, roadmaps or, ecosystembuilding that could contribute to ensure that standardisation plays its role in achieving a DigitalSingle Market. Please explain if a standardisation need/gap exists in the Domain 4: Data

and the subdomains which you have selected. Please alsodriven services and applicationsindicate within which time-frame such need could be addressed. Please limit to a maximum offive needs/gaps per domain or sub-domain:

This is a rapidly developing domain, and a 'landscape analysis' of

current market developments is needed, followed by an assessment of what

new standards are needed at EU and International levels. Such "landscape

analysis" would allow the identification of emerging ad-hoc standards as

well as gaps, and then would help to define the priority ICT standards

plan. Smart Metering, Appliances, Home and Building Automation,

Infrastructure, Health, Transport etc., all form part of the advent of

new service and applications in need of ICT standardisation.

*

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Q2.4 - Among those below, which action could be a priority in the Domain 4: Data driven and the subdomains which you have selected? Please rank the listservices and applications

below and explain your choice.

1 2 3 4 5 6 7 8 9









• Other

• No opinion

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*Please explain:

Data driven services and applications is already an area where rapidly

moving participants exploiting new uses and sources of data are being

proliferated, making it very difficult to understand the extent and

exposure the lack of standards is creating. Fastrack research is needed

to comprehend the challenge and shape thinking on standards in this

domain, together with trying to understand the balance between

constraint and innovation. This domain is in the forefront of a highly

vibrant and competitive market, and communities of users, developers,

retailers, academics etc., will be needed to formulate a structured

approach that allows the sector to flourish but applies controls in the

right areas.

Q2.5 - Please indicate any other standardisation initiatives which would help achieving theDigital Single Market in the and theDomain 4: Data driven services and applicationssubdomains which you have selected, and who in the standardisation landscape would be bestplaced to lead on these initiatives:

Hypercat is one such initiative that is seeking to gain EU/International

Standardisation based upon the need to provide open data access across

multiple market domains and hubs. Another is the creation of National

Infrastructure to allowed shared access to Smart Energy data from homes

and Buildings by multiple parties.








local conditions and constraints, and are effective. Data driven

services and applications are reaching a tipping point beyond which it

will become very difficult to legislate and apply controls to how data

is obtained, managed, handled and monetised, putting the market at risk

of instability and the consumer at risk of loss of provenance and

legitimacy over their own data.

*

*

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*Q2.2 - For the and the subdomains which you have selected,Domain 8: Internet of Thingsplease explain briefly how the criteria indicated in Box I apply to them.







Internet of things is the new area with important potential of value

creation, and applicable

in many sectors; and we believe that the criteria above apply to this

domain.

Q2.3 - The Priority ICT standards plan should lead to the production of technical specifications,standards or architectures where there is a need/gap, but could also propose any other type ofstandardisation action such as landscape analysis, gap finding, roadmaps or, ecosystembuilding that could contribute to ensure that standardisation plays its role in achieving a DigitalSingle Market. Please explain if a standardisation need/gap exists in the Domain 8: Internet of

and the subdomains which you have selected. Please also indicate within whichThingstime-frame such need could be addressed. Please limit to a maximum of five needs/gaps perdomain or sub-domain:

*

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Q2.4 - Among those below, which action could be a priority in the Domain 8: Internet ofand the subdomains which you have selected? Please rank the list below and explain Things

your choice.

1 2 3 4 5 6 7 8 9









• Other

• No opinion

*Please explain:

'Internet of things' is an enabler for 'Data driver Services and

applications' and so inherently these domains are intimately linked.

However 'Internet' standards are well established, so the need here is

to make sure that they are fit for the new purposing of this open

operating environment and ecosystem to a vastly expanded horizon of use

cases and in particular M2M applications. There are increasing risks

associated with effecting critical controls using this infrastructure,

security, data protection and privacy, monetisation policies, etc.,

etc..

*

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Q2.5 - Please indicate any other standardisation initiatives which would help achieving theDigital Single Market in the and the subdomains which you haveDomain 8: Internet of Thingsselected, and who in the standardisation landscape would be best placed to lead on theseinitiatives:

There are many overlapping standards initiatives which have been

established or are in the process of establishment across the internet

ecosystem, however these do not necessarily consider the consequences of

interaction across a host of new application areas with vast arrays of

sensors, controls and multi-party interactions.








local conditions and constraints, and are effective. IoT is a

developing reality for the Energy sector, and by default is the basis

for a number of emerging initiatives, including Smart metering,

Generation Plant monitoring and management, Integrated Energy Systems,

etc.. It is important that the sector fully understands the

implications of IoT and the need for and adoption of related standards.

*

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*Q2.2 - For the and the subdomains which youDomain 10: Smart and Efficient Energy Usehave selected, please explain briefly how the criteria indicated in Box I apply to them.







The domains and subdomains selected cover the gaps in the Smart and

Efficient Energy

use. There are strong links between this domain, Cloud Computing,

Cybersecurity, Data driven service and applications and IoT, and these

criteria are needed to ensure that all domains are bound together in a

manner which achieves an effective and efficient operating environment

based upon strong standards. .

Q2.3 - The Priority ICT standards plan should lead to the production of technical specifications,standards or architectures where there is a need/gap, but could also propose any other type ofstandardisation action such as landscape analysis, gap finding, roadmaps or, ecosystembuilding that could contribute to ensure that standardisation plays its role in achieving a DigitalSingle Market. Please explain if a standardisation need/gap exists in the Domain 10: Smart

and the subdomains which you have selected. Please also indicateand Efficient Energy Usewithin which time-frame such need could be addressed. Please limit to a maximum of fiveneeds/gaps per domain or sub-domain:

Smart and Efficient Energy use is a developing domain, and there is a

lack of relavent EU/International standards as demonstrated by the GB

Smart metering and Customer Access Device requirements and supporting

National Infrastructure specifications. Little if any standards exist

although work has been underway as part of M/490 and Technical

Committees, however these may have been superseded by events in a

variety of member states, and need review.

*

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Q2.4 - Among those below, which action could be a priority in the Domain 10: Smart and and the subdomains which you have selected? Please rank the list belowEfficient Energy Use

and explain your choice.

1 2 3 4 5 6 7 8 9









• Other

• No opinion

*Please explain:

Smart and Efficient Energy use has already moved ahead of applicable

standards and is utilising proprietary commercial specifications to

allow rapid progress towards deployment to meet EU Directives. Examples

of this are 'Linky' in France and SMETS in GB. At this stage it is

necessary to work collaboratively between innovators and public bodies

to 'catch-up' with de-facto standards, ensuring that compatibility

between 'standards' and 'specifications' is key to avoid obsolescence.

*

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Q2.5 - Please indicate any other standardisation initiatives which would help achieving theDigital Single Market in the and the subdomainsDomain 10: Smart and Efficient Energy Usewhich you have selected, and who in the standardisation landscape would be best placed tolead on these initiatives:

Zigbee, DLMS, GBZ, ad-hoc Interoperability rules, XML are all being used

as part of integrated solutions which require these specifications to

evolve to meet emerging requirements, and there is little

standardisation applied to assuring consistent replication across mass

National, European and Global Markets.








local conditions and constraints, and are effective. It is vital that

progress towards the implementation of smart metering and associated

energy efficiency technologies and services is not negatively affected

by the application of standards, as this will create a conflict between

the EU Energy Efficiency Directive which requires certain members states

to complete rollout by end 2020. It is inevitable that standards will

need to be developed, but it is likely that this will be on a

retrospective and backwards compatible basis, however will benefit

future generations of technology, applications services and use cases.

II.3 Other Comments

Other comments:

Background Documentsanalysis.pdf (/eusurvey/files/f2d6718c-7e07-4955-9505-c94113bbbe0f)

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https://ec.europa.eu/eusurvey/files/f2d6718c-7e07-4955-9505-c94113bbbe0f

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Standards in the Digital Single Market: setting priorities...

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