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The confusing thing is that it seems simple to just disable the smart functionality, and this should then cause any charge point to fall back to being a dumb one, as is the case at the moment. However the wording also seems to suggest that the user should not be able to do this, in this part of the new law:

View attachment 153135
Where a "relevant person" is the user.
It says this only applies where there is a risk to health and safety though. Not sure how that would apply to the default charging hours, maybe if there is a limited supply and it has to be scheduled when other things are not turned on or something.

Seems like the random delay is the intended fallback option when there is no connection available and the time is unknown.
 

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It says this only applies where there is a risk to health and safety though. Not sure how that would apply to the default charging hours, maybe if there is a limited supply and it has to be scheduled when other things are not turned on or something.

Seems like the random delay is the intended fallback option when there is no connection available and the time is unknown.

The snag is there's no definition as to when there is a risk to health and safety in the act, AFAICS. If I had to guess then I'd say this could be interpreted in different ways. Say you have a normal new build supply, with a 100 A fuse and a normal maximum demand rating of 15 kVA*, then the DNO could well argue that exceeding 15 kVA was a safety risk, as it could result in overload of their local network, with resultant overheating of PMTs, cables etc.


*I know the numbers seem odd here, but 15 kVA is the DNO assumed max load for a 100 A supply as far as their calculation of LV grid load is concerned. A 100 A fused supply can safely handle ~23 kW/kVA for short periods, but is assumed to be no more than15 kVA normally.
 

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As I read the regulations, a smart charge point must support the facility for remote overrides (what it calls DSR -- demand side response -- services) but the use of this is governed by an optional DSR agreement. No DSR agreement means no remote overrides. Perhaps some suppliers will offer favourable terms to entice customers to buy their charge points with a DSR agreement but a typical sale would not need one.

Perhaps it is the thin end of the wedge but, on its own, it is quite weak.

Edit: also, I am not entirely sure it bans sales of dumb home charge points. There is a get-out clause for what it calls 'non-smart cables', which might cover the simplest charge points. Like a lot of this pig's ear though, it is quite unclear what it means.
 

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There is a get-out clause for what it calls 'non-smart cables', which might cover the simplest charge points. Like a lot of this pig's ear though, it is quite unclear what it means.
I assume that these are things such as a "granny" lead and the 13A plug that is used to connect a Twizy. Both require suitably protected circuits for regular use but neither could support anything like DSR.
 

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It's the lack of clarity in this law that bugs me, TBH. Laws need to be clear and unambiguous, and this seems to be anything but.

If they want to be able to control and regulate vehicle charging, so that the grid can stay in better balance, or even to improve the profitability of energy suppliers, then the law needs to be clear as to how this is going to work, what the means of secure communication with the controlling network is, who runs that controlling network, who has regulatory oversight of it, what penalties might apply if the law is breached, etc. etc.

Reading the regulations it seems as if the plan is to create a control network that operates like the one for smart meters. This makes sense, and the obvious way to integrate charge points into that network would be to use the HCALCS protocol that already exists and was designed specifically to allow smart meters to control consumer equipment for things like DSR. It would be straightforward to just require that all charge points have Zigbee comms and follow the HCALCS spec, yet that doesn't seem to be mentioned, AFAICS. It does make me wonder why they went to the trouble of designing and specifying a means of allowing DSR control from smart meters, yet are now seemingly ignoring that.

For those unfamiliar with HCALCS, there are details here, and they refer specifically to using it with charge points: https://assets.publishing.service.g...Demand_Side_Response_leaflet_-_DR_-_FINAL.PDF
 

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I assume that these are things such as a "granny" lead and the 13A plug that is used to connect a Twizy. Both require suitably protected circuits for regular use but neither could support anything like DSR.
In theory, a future revision could. The granny 'brick' could support a wireless internet connection. I don't know any that work this way currently though.

But say you fitted a Veridian Classic, for example. It has no internet connection so it's like a typical granny lead in that respect. Is that a 'non-smart cable'?

What about a commando socket with EV reg compliant earthing -- if I use it with an Ohme, or perhaps something similar but dumber, is that OK?

Possibly the most alarming bits of this legislation are the sections called 'Power of entry without warrant' and (you guessed it) 'Power of entry with warrant', which allows the authorities to enter premises, including by force, to check that the dog's dinner has been correctly interpreted.

In reality, I would expect charge point makers to sigh, then implement the mess as best they can, with an eye on their competitors to make sure they are keeping up with the pack, and expect that everyone on the enforcement side will have better things to do than split hairs.

Kind regards
- Garry
 

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The granny 'brick' could support a wireless internet connection. I don't know any that work this way currently though.
The Ohme cable and the vanilla Chinese "granny" cable that it is based upon contain a wireless internet connection. But this would need considerable customisation to connect to a Smart meter via the HAN on ZigBee like a HCALCS.
 

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In reality, I would expect charge point makers to sigh, then implement the mess as best they can, with an eye on their competitors to make sure they are keeping up with the pack, and expect that everyone on the enforcement side will have better things to do than split hairs.

Given that there is near-zero enforcement of the wiring regs and related law, like Part P, I doubt that there will be any enforcement of this new law, ever.

As you say, it's the charge point manufacturers who are faced with a potentially serious problem, in that they have to interpret this mess and design new charge points, get them tested, approved and into volume production by next June. Clearly some companies that are just importing charge points made elsewhere and re-badging them may well have more of a problem with this, it depends on whether the overseas OEMs will change a standard design to make it comply with these UK-specific requirements.

The impact of that could be positive, in that generally the UK designed charge points tend to be better designed and built than some of the imported ones, but it could also lead to charge points being more expensive, as ultimately it's the consumer that has to pay for the requirements in this new law. I think I might just buy some spare components before they cease to be available, so I can make sure that our charge points remain serviceable for years to come. Might also see a surge in interest in projects like Open EVSE.
 

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it could also lead to charge points being more expensive, as ultimately it's the consumer that has to pay for the requirements in this new law. I think I might just buy some spare components before they cease to be available, so I can make sure that our charge points remain serviceable for years to come. Might also see a surge in interest in projects like Open EVSE.
^^^^THIS^^^^^
And that is just considering the cost of the charge point, not any potential downside to the user of DSR controls.
 

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^^^^THIS^^^^^
And that is just considering the cost of the charge point, not any potential downside to the user of DSR controls.

We have a couple of charge point designers/manufacturers here, be interesting to get their take on this. I have a feeling that Indra charge points are already either compliant, or close to being compliant, not sure about the state of play with Viridian.
 

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It's the lack of clarity in this law that bugs me, TBH. Laws need to be clear and unambiguous, and this seems to be anything but.

If they want to be able to control and regulate vehicle charging, so that the grid can stay in better balance, or even to improve the profitability of energy suppliers, then the law needs to be clear as to how this is going to work, what the means of secure communication with the controlling network is, who runs that controlling network, who has regulatory oversight of it, what penalties might apply if the law is breached, etc. etc.
I quite agree, but in reality the UK Government doesn't have a solution on the shelf which it can mandate. The smart metering system was a strong candidate but the roll-out has been slow and despite the early plans for it to support smart devices like smart EV charging, it hasn't yet got beyond the trial stages, again the progress is really lacking, it hasn't got the foundations in place necessary to mandate the use of smart metering.

It's also dabbling in smart device standards, with PAS 1878 and 1879 but this is still really early days, it isn't yet anywhere near an established eco-system of products and services. Again, it couldn't mandate this.

So it ends up doing what it can, requiring something 'smart' but not being able to state what in any detail.

It would be straightforward to just require that all charge points have Zigbee comms and follow the HCALCS spec, yet that doesn't seem to be mentioned, AFAICS. It does make me wonder why they went to the trouble of designing and specifying a means of allowing DSR control from smart meters, yet are now seemingly ignoring that.
I'd suggest because smart metering is one set of companies, the meter manufacturers, the energy companies and the DCC, with lots of very detailed requirements, testing and compliance requirements and high costs, operating a closed system with lots of limitations on what parties can do. Whereas the EV charger manufacturers are a completely different set of companies, without access to the smart metering network, who aren't familiar with the tech and can't do all the steps necessary to connect, commission and control devices, so they have to invent their own IOT based systems, completely separate from the smart metering system.
 

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I'd suggest because smart metering is one set of companies, the meter manufacturers, the energy companies and the DCC, with lots of very detailed requirements, testing and compliance requirements and high costs, operating a closed system with lots of limitations on what parties can do. Whereas the EV charger manufacturers are a completely different set of companies, without access to the smart metering network, who aren't familiar with the tech and can't do all the steps necessary to connect, commission and control devices, so they have to invent their own IOT based systems, completely separate from the smart metering system.
Perhaps, but the HCALCS spec is pretty easy to comply with and there are already some HCALCS devices around. The advantages of using this is that the integration with smart metering, the DCC and the DNOs is already there, as smart meters can already communicate DSR commands from the DNOs to HCALCS using the Zigbee network (the HAN) that can be used to drive the in-home display. The government has even being working on this approach since 2019: Electric vehicle smart charging: smart meter demonstration project
 

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Perhaps, but the HCALCS spec is pretty easy to comply with and there are already some HCALCS devices around. The advantages of using this is that the integration with smart metering, the DCC and the DNOs is already there, as smart meters can already communicate DSR commands from the DNOs to HCALCS using the Zigbee network (the HAN) that can be used to drive the in-home display. The government has even being working on this approach since 2019: Electric vehicle smart charging: smart meter demonstration project
Well it's actually even easier than that, most smart meters have an ALCS relay already built-in, a couple of amp 230VAC relay, typically used to control the coil of a contactor. It could be used to provide a simple switched 230VAC control signal, to automate an EV charger to operate off-peak following an EV tariff and/or do some ad-hoc stuff.

But where it all falls down is around access to the meter, to use the ALCS relay you need the supplier and meter operator to provide access to the connections which are behind the covers. If you go down the HCALCs route, you need the supplier to connect and commission the HCALCS to the HAN. But then you need the supplier to push the calendar schedule which controls the switching. All of these are outside the control of an EV charger point manufacturer or installer.

Personally I think it's a very good solution to provide simple EV charging control linked to TOU tariffs, but it relies on the supplier doing a number of tasks to allow an EV charger to be connected up, and currently none of them offer this.
 

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Surely this is an excellent use for the ALCS equipment already built in to the meters.

One option could be to only power the controlled circuit during the off peak part of the tariff. The problem with that is that there is no manual override so you could be stuck being unable to charge the car in the middle of the day. Another option is to power the circuit permanently via the ALCS but disengage it if the frequency drops. Due to the way smart meters work, that wouldn’t be an automatic response but could it be configured to allow DNOs to switch off EVs in the event that they need to shed load?
 

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Surely this is an excellent use for the ALCS equipment already built in to the meters.
Yes you would think so, automatically link the charger to the time of use tariff and update the times as you switch between tariffs and suppliers.

One option could be to only power the controlled circuit during the off peak part of the tariff. The problem with that is that there is no manual override so you could be stuck being unable to charge the car in the middle of the day. Another option is to power the circuit permanently via the ALCS but disengage it if the frequency drops.
I'd use the ALCS only as a control signal, so have a permanent supply to the charge point and the output from the ALCS as a control signal to the charger. The charger can then always be available to run in local override irrespective of the ALCS, say with a boost button on the charger.
 

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With a long cable between the ALCS and the charge point, and an override button on the charge point, I can see people fitting various workarounds to allow them to charge when/how they want.
Given the absence of SoC data in the AC connection how is the central system going to optimise charging when it has no data to base a calculation on? Any of the current crop of big batteried ESUVs could need anything from 1 to 70+ kWh, or 5 minutes to 11 hours of charging. Back in the days of Agile, Ohme had to work hard to get access to the API for the cars data but a lot of manufacturers didn't have suitable systems. DC systems supply the data but my understanding of CCS is that it's inconsistently implemented and a lot will not allow repeated on/off cycles without a reconnection.
 

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I quite agree, but in reality the UK Government doesn't have a solution on the shelf which it can mandate.
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So it ends up doing what it can, requiring something 'smart' but not being able to state what in any detail.
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Thus pretty much guaranteeing that any solutions provided will be inconsistent, unworkable and therefore never used. Either needs a properly thought through standard, or nothing. This half-arsed approach just adds cost for no benefit.
 

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needs a properly thought through standard
With full buy in from all vehicle manufacturers, including the legacy manufacturers, disrupters such as Tesla, and future businesses such as the Chinese. And a single standard consistently implemented.
or nothing. This half-arsed approach just adds cost for no benefit.
The first is a pipe dream that even a powerful market like China couldn't enforce, let alone the UK. So we are going too early and assuming too much importance as usual.
 

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No, what I mean is they need to push for a future proof solution, not just demand a basic plug. We all know V2G is coming so it's an opportunity to push the market.
Absolutely not. Basic plug is absolutely fine in most cases, maybe costs around £65 instead of around £650.
Of course if the point/parking space is not next to the house the costs may escalate dramatically.
People who don't drive don't need any of this so why should they pay for it?
 
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