24. February 2022 By Stephen Lorenzen, Georg Benhöfer and Lars Zimmermann
A milestone in the digitalisation of the energy transition? The third gateway is here
The smart meter rollout has been causing some ambivalence in the energy sector for many years – a lot of hustle, a lot of work and, at the same time, a lot of standing still. If you believe the words of Arne Schönborn, President of the German Federal Office for Information Security (Bundesamt für Sicherheit in der Informationstechnik, BSI), a milestone in the digitalisation of the energy transition has now been reached. In this blog post, we explain what this milestone is and what it means for the smart meter rollout seven years after the publication of the German Act on the Digitalisation of the Energy Transition (Gesetz zur Digitalisierung der Energiewende, GDEW).
What’s the background?
The German Act on the Digitalisation of the Energy Transition (GDEW), which includes the German Metering Point Operation Act (Messstellenbetriebsgesetz, MsbG), was published in 2016. The MsbG is intended to create binding conditions for the secure use of smart metering systems in compliance with data protection law. The smart metering system consists of at least one modern measuring device (also referred to colloquially as a smart meter) and the smart meter gateway (SMGW). The SMGW is intended to serve as a central communication interface for all metered consumption – from the consumer to authorised market participants. Using such smart metering systems is important for the energy transition. This is because while conventional power plants can adjust themselves to us consumers, wind and solar power plants pay less attention to our consumption behaviour. Accordingly, there must be a shift from consumption-oriented generation to generation-oriented consumption to make the energy transition a success. Digital intelligence systems, such as smart metering systems, play a key role in giving companies the technical capacity to react flexibly when energy is generated.
The MsbG thus created the legal basis for the rollout of smart metering systems seven years ago – with the technical basis being formed by data security specifications (among other things), and the organisational basis being formed by the metering point operators’ obligation to set up this exact digital infrastructure.
The legislator has put the BSI in charge of developing requirements for the smart metering system. This includes requirements for reliable product components (an SMGW with an integrated security module), secure operation of the SMGW’s IT systems (administration) and requirements for a reliable communication infrastructure (smart metering public key infrastructure). The BSI defines the technical standards for these requirements. They are intended to guarantee the highest level of data protection, data security and interoperability, making them the basic prerequisite for reliability and acceptance. Competitive and regulatory conditions mean that three gateways that meet the BSI’s requirements are needed for the pronouncement and launch of the smart meter rollout. With that in mind, the certification of the three gateways that has now taken place is a milestone that had to be reached.
The goal was to achieve an installation rate of ten per cent by 2023. The decision reached by the Higher Administrative Court (Oberverwaltungsgericht, OVG) of North Rhine-Westphalia in March 2021 jeopardised this goal. This urgent decision gave notice that the BSI’s general ruling on the smart meter rollout would be suspended. This meant that metering point operators were temporarily no longer obligated to install smart metering systems. The reason for this was the changes BSI made to the devices’ minimum requirements. After the adjustment, these no longer met the requirements of the MsbG. In response, the legislator – in close coordination with the unions – got busy working out adjustments to the German Metering Point Operation Act (MsbG). The resulting amendment to the MsbG entered into force on 27 July 2021. The changes are mostly to do with the exemption period, the establishment of systematic approaches, the legitimation of gradual rollouts and the evaluation of the current state of the art. You can find more information about this in our blog post on Clarity for the smart meter rollout.
So what happened recently?
A few weeks ago, the BSI reissued the required certificates for the three necessary smart meter gateway manufacturers. These now fulfil the MsbG’s interoperability requirements, which was the main point of contention in the court ruling reached by the OVG of North Rhine-Westphalia.
The three manufacturers are EMH Metering, Theben AG and PPC AG.
BSI President Arne Schönborn said: ‘The interoperability of the gateways could now also be formally confirmed by an independent testing body during the conformity assessment procedures. We have thus reached an important milestone in the digitalisation of the energy transition, on the basis of which an accelerated rollout of smart metering systems can be driven forward’.
And what happens now?
The metering point operators must continue with the rollout in accordance with MsbG from now on. For 2022, it’s advisable (as regards smart meter rollouts) for metering point operators to realise the obligatory installations in such a way that the ten per cent rollout quota set for 2023 can be met by the target date.
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