How this links to the Cyber Security and Resilience Bill
Potential electrical control is the yardstick clause 6 uses to decide which load controllers are large load controllers. It measures what a controller could move, not what it does move, so fast-growing aggregators can cross the line before their actual dispatch looks significant.
- cl.6(2), new para 1(5B): the aggregate of maximum flow into all managed relevant ESAs taken together and maximum flow out, capable of being achieved in response to the controller’s signals.
- cl.6(2), new para 1(5C)(c): each device’s maximum flow is its electrical capacity as stated by the manufacturer.
- cl.6(2), new para 1(5A): 300 MW or more in the UK meets the threshold for the essential service of load control.
How is potential electrical control calculated?
Add together the maximum flow of electricity into every relevant energy smart appliance you manage, then add the maximum flow out of them. Use the capacity stated by each device’s manufacturer. A bidirectional device, such as a home battery or vehicle-to-grid charger, therefore counts in both directions.
Only devices you manage count, meaning those whose electricity flow you control by load control signals you send. Where an active intermediary is involved, devices can count for both parties under para 1(5E). Average consumption and actual dispatch are irrelevant. The Bill does not say how often the figure must be checked; the sector guide notes that DESNZ expects controllers to monitor it continuously.
Worked example (illustrative)
Illustrative example
A platform manages 30,000 smart charge points rated at 7 kW import only (210 MW in, 0 MW out) and 5,000 home batteries rated at 5 kW each way (25 MW in, 25 MW out). Potential electrical control is 210 + 25 + 25 = 260 MW, below the threshold. Adding 8,000 more batteries adds 80 MW and takes it to 340 MW, making it a large load controller. Figures are illustrative.
Where it appears in the Bill
- cl.6(2), NIS Sch 2 para 1(5B)Definition of potential electrical control as inflow plus outflow.
- cl.6(2), NIS Sch 2 para 1(5C)(c)Manufacturer-stated capacity sets each device’s maximum flow.
- cl.6(2), NIS Sch 2 para 1(5A)The 300 MW threshold.
References are to HL Bill 32 as brought from the Commons. Read the Bill.
Frequently asked questions
Does potential electrical control use actual or rated capacity?
Rated capacity. New paragraph 1(5C)(c) says the maximum flow into or out of each relevant energy smart appliance is determined by reference to its electrical capacity as stated by the manufacturer. How much electricity the devices actually draw or export, on average or at peak, does not change the figure used for the 300 megawatt test.
Do batteries count twice towards the 300 MW threshold?
In effect, yes. Potential electrical control adds the maximum flow into all managed devices to the maximum flow out of them. A battery rated at 5 kilowatts charge and 5 kilowatts discharge contributes 10 kilowatts in total, whereas a one-way charge point contributes only its import capacity.
What happens when a load controller crosses 300 MW?
It meets the threshold in new paragraph 1(5A) and is deemed designated as an Operator of Essential Services. It must notify the competent authority, which is the Energy Secretary and Ofgem jointly, and then meet the security duties and 24 and 72-hour incident reporting rules once clause 6 has been brought into force.