camelot-forum.co.uk

Form A3-1 from Western Power Distribution has the following question:

"PGM installation complies with cybersecurity requirements Yes/No"

Can anyone tell me what these requirements are or where they can be found?

N.b. the ENA website has an old version of the form - Amdt 6 2020, which is two issues out of date, pretty rubbish for a regulatory body!

Perhaps you should be asking Western Power Distribution if all their systems comply?

Job for the "likely" complete a-hole of a data controller when you encounter such vociferous language pertaining to forcing "data rape" upon you.

Query it directly, sounds like strong arm forced compliance of data to be taken abroad & you roughly fisted, let them prove otherwise & do the EU compliancy dance for a change.

PGM = Power Generation Module.

WPD are asking if your installation is compliant with the government's cybersecurity guidelines for Internet connected devices (IoT).

If the system is not connected to the internet then the answer is a simple Yes.

Otherwise have a look here -

https://www.energynetworks.org/industry ... idance.pdf

As you will see domestic installations are, per se, out of scope for the requirements.

Galahad wrote: ↑Wed Jul 27, 2022 5:33 pm PGM = Power Generation Module.

WPD are asking if your installation is compliant with the government's cybersecurity guidelines for Internet connected devices (IoT).

If the system is not connected to the internet then the answer is a simple Yes.

Otherwise have a look here -

https://www.energynetworks.org/industry ... idance.pdf

As you will see domestic installations are, per se, out of scope for the requirements.

So for domestic premises I would say the most appropriate answer is N/A.

nowty wrote: ↑Wed Jul 27, 2022 6:49 pm

Galahad wrote: ↑Wed Jul 27, 2022 5:33 pm PGM = Power Generation Module.

WPD are asking if your installation is compliant with the government's cybersecurity guidelines for Internet connected devices (IoT).

If the system is not connected to the internet then the answer is a simple Yes.

Otherwise have a look here -

https://www.energynetworks.org/industry ... idance.pdf

As you will see domestic installations are, per se, out of scope for the requirements.

So for domestic premises I would say the most appropriate answer is N/A.

Normally I would agree. But the WPD form here https://www.westernpower.co.uk/downloads/549679 is very prescriptive. Unlike some other questions it does not allow N/A as an answer, and NO results in immediate failure.

So I think I will reply YES as I do in fact comply with everything ENA requires for a domestic application and rely if challenged on the ENA guidance, specifically this

<1.2.1 Out of scope
The scope for this guidance does not include:

• Domestic applications> which implies they require nothing at all (thanks for the link @Galahad).

Also I am constrained by the Victron remote access technology, and since the MultiPlus has UK type approval ENA have presumably OK'd it. Otherwise I would have changed the port numbers so as not to use the default settings as I have done for the PV inverters and various other stuff.

Has anyone else been faced with this question from other DNOs?

If answering YES gets it through, then that is the correct answer.

Just to confuse the world even further I've just had an email from Western Power Distribution to say they are becoming National Grid. Have they been reorganised and nationalised? They were "spun off" from SWEB when it was deemed by the powers the be that they might favour SWEB customers over other suppliers using the distribution network, a bit like Openreach and BT.

National Grid as a national network controller is a complete nuts-up. OFGEM allowed them to pursue commercial interests in the US rather than concentrate on managing the UK National Grid (surely the clue is in the name). Then they allowed them to acquire distribution companies in the UK giving them a very obvious conflict of interest (they have owned WPD since June last year (source https://en.wikipedia.org/wiki/Western_P ... stribution).

To resolve this "In 2021, Ofgem called for the creation of a fully independent operator in view of potential conflicts of interest from NG's ownership of the transmission network, and in 2022 the UK government confirmed that a fully independent public body - the Future System Operator, covering electricity and gas - would be established." (from https://en.wikipedia.org/wiki/National_Grid_plc).

Still that is small beer compared with OFGEM's poor oversight of all the fly-by-night undercapitalised energy companies that have gone bust taking our money with them one way or another.