A Blockchain-based Privacy-friendly Renewable Energy Community
Stephan Cejka
1
, Franz Zeilinger
1
, Argjenta Veseli
2
, Marie-Theres Holzleitner
2
and Mark Stefan
3
1
Siemens AG
¨
Osterreich, Vienna, Austria
2
Energieinstitut an der Johannes Kepler Universit
¨
at Linz, Linz, Austria
3
AIT Austrian Institute of Technology GmbH, Vienna, Austria
Keywords:
Energy Community, Privacy, Blockchain, Clean Energy Package, Energy Transition, Energy Efficiency.
Abstract:
The European Union’s Clean Energy Package introduces two kinds of energy communities, namely the Re-
newable Energy Community (REC) in the Renewable Energy Directive of 2018 and the Citizen Energy Com-
munity (CEC) in the Electricity Directive of 2019. They aim for local improvements of energy efficiency, in-
creasing integration of renewable energy sources, and a reduction of greenhouse gas emissions, to be achieved
by jointly producing, temporarily storing, sharing, consuming, and selling locally generated energy. House-
holds and individuals shall thus be enabled to take an active part in the energy transition. When utilizing
blockchain technology for the implementation of such energy communities, as proposed in current research
projects, a focus must be laid on the technology-inherent area of conflict with privacy issues, especially since
data on households’ energy consumption count as personal data.
1 INTRODUCTION
Among the biggest challenges of our time is the cli-
mate change caused by enormous man-made emis-
sions of greenhouse gas. The global temperature level
has risen significantly in the last few decades and
the rise is expected to continue if no or not-sufficient
countermeasures are taken (IPCC, 2014). To limit the
continuing temperature rise to globally stipulated val-
ues in the 2016 Paris agreement (UNFCCC, 2016),
the European Union aims to reduce greenhouse gas
emissions by at least 40 % by 2030 (European Com-
mission, 2019a). It addressed the energy sector, being
one of the biggest sources of emissions (IPCC, 2014),
by issuing the ‘Clean Energy for all Europeans Pack-
age’ in 2018/2019 (European Commission, 2019c;
European Commission, 2019b). This shall also aim to
reach further key targets for 2030, which are a share
of at least 32 % of renewable energy and an improve-
ment of at least 32.5 % in energy efficiency (European
Commission, 2019a).
As suggested countermeasures on the local level,
the Clean Energy Package introduces two kinds of
energy communities to merge the energy production
as well as the consumption of individuals and en-
terprises. While awaiting concrete transpositions of
the Clean Energy Package’s directives into national
law of the European Union’s member states, some
research projects are already dealing with possible
implementations; for example, by using blockchain
technology as proposed in this paper.
We will first introduce the Clean Energy Package
with special focus on energy communities (Section 2).
Afterwards, we will go into detail about blockchain
technology, including its known issues with privacy
and energy efficiency (Section 3). The main contribu-
tion of this paper will be to combine the two aspects,
by describing a possible implementation of a privacy-
friendly blockchain-based renewable energy commu-
nity (Section 4).
2 CLEAN ENERGY PACKAGE
The latest development in European Union’s energy
law is its ‘Clean Energy for all Europeans Package’,
first proposed in 2016, and finally adopted by the
European Parliament, partly in the end of 2018 and
partly in Summer 2019. One of its main goals is to
bring EU and its member states on track for the re-
vised climate targets for 2030 (European Commis-
sion, 2019c; European Commission, 2019a; Euro-
pean Commission, 2019b). The package itself, con-
sists of four directive and four regulation acts:
Energy Performance of Buildings Directive (EU)
2018/844,
Cejka, S., Zeilinger, F., Veseli, A., Holzleitner, M. and Stefan, M.
A Blockchain-based Privacy-friendly Renewable Energy Community.
DOI: 10.5220/0009391300950103
In Proceedings of the 9th International Conference on Smart Cities and Green ICT Systems (SMARTGREENS 2020), pages 95-103
ISBN: 978-989-758-418-3
Copyright
c
2020 by SCITEPRESS Science and Technology Publications, Lda. All rights reserved
95
Renewable Energy Directive (EU) 2018/2001,
Energy Efficiency Directive (EU) 2018/2002,
Governance of the Energy Union and Climate Ac-
tion Regulation (EU) 2018/1999,
Electricity Regulation (EU) 2019/943,
Electricity Directive (EU) 2019/944,
Regulation on Risk-Preparedness in the Electric-
ity Sector (EU) 2019/941,
Regulation on the European Union Agency for
the Cooperation of Energy Regulators (EU)
2019/942.
The two acts of main interest for the scope of this pa-
per are printed in bold; the revised Renewable Energy
Directive (RED II) introducing ‘Renewable Energy
Communities (RECs)’ and the revised Electricity Di-
rective (ED II) introducing ‘Citizen Energy Commu-
nity (CECs)’ as a second type of energy communities.
2.1 Evolution to Energy Communities
Those energy communities are a third step in an
evolution shown in Figure 1, starting with house-
holds optimizing their own energy consumption and
proceeding by applying those procedures to apart-
ment buildings next. They are termed ‘renewables
self-consumer’ and ‘jointly acting renewables self-
consumers’ in the definitions of RED II:
Renewables Self-consumer: ‘a final customer [...]
who generates renewable electricity for its own
consumption, and who may store or sell self-
generated renewable electricity activity’.
Jointly Acting Renewables Self-consumers: ‘a
group of at least two jointly acting renewables
self-consumers [...] who are located in the same
building or multi-apartment block’.
According to RED II, those parties shall be able to
‘generate, consume, store, and sell electricity with-
out facing disproportionate burdens’ and ‘[c]itizens
living in apartments [. . . ] should be able to benefit
[. . . ] to the same extent as households in single fam-
ily homes’.
Main parts of the two energy communities’ def-
initions are similar while some differences between
them exist though. Their legal definitions in RED II
and ED II can be summarized as follows:
Renewable Energy Community:
a legal entity, based on open and voluntary par-
ticipation, and autonomous,
controlled by its shareholders or members,
which are natural persons, small or medium en-
terprises, or local authorities,
Figure 1: Evolution to energy communities.
shareholders or members are located in the
proximity of renewable energy projects owned
and developed by that legal entity,
its primary purpose is to provide environmen-
tal, economic or social community benefits
rather than financial profits.
Citizen Energy Community:
a legal entity, based on open and voluntary par-
ticipation,
controlled by shareholders or members that are
natural persons, small enterprises, or local au-
thorities; but open for participation of other en-
tities,
its primary purpose is to provide environmen-
tal, economic or social community benefits
rather than financial profits,
it may engage in generation, including from
renewable sources, distribution, supply, con-
sumption, aggregation, energy storage, energy
efficiency services or charging services for
electric vehicles or provide other energy ser-
vices.
The often appearing term ‘local energy community’
was contained in the European Commission’s draft of
the ED II, but was abandoned in favor of the term
CEC. However, despite the CEC not having a prox-
imity aspect, in our opinion this technical term is
properly suited as an umbrella term for RECs and
CECs. Speaking of RECs’ proximity aspect, this
is one of the main difference between those com-
munities. While an REC’s participant needs to be
located in close proximity to the community’s re-
newable energy projects, CEC’s participants may be
widely spread optionally also over member states’
borders. CEC’s legal definition includes a number of
activities they are able to perform, while REC’s def-
inition does not explicitly contain such an enumera-
tion.
However, this paper does not intend to give an in-
depth analysis of RECs’ and CECs’ commonalities
and differences (cf. (Cejka, 2020)). The intention is
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96
to describe a possible and already realized im-
plementation of an REC; thus, the remainder of this
paper will focus on this type of energy communities.
2.2 Renewable Energy Communities
RECs aim for the participation of individuals to im-
prove the local acceptance of renewable energy, local
investment, and improved participation of citizens in
the energy transition. To that end, the REC shall be-
come a non-discriminating position among the other
(larger) competing players on the energy market. In
result, the REC shall be enabled to
produce, consume, store and sell renewable en-
ergy,
share produced renewable energy within the com-
munity,
and access energy markets in a non-
discriminatory manner.
Its participants have to incorporate an autonomous le-
gal entity, effectively controlled by them. They have
to be located in the REC’s proximity, which requires
a clarification in the national implementations by ei-
ther applying technically or geographically defined
boundaries. Furthermore, participation is open and
voluntary, and shall also be open to indigent partic-
ipants. In contrast to CECs, RECs are not limited to
electricity, but could operate on all kinds of renewable
energy (e.g., heating, cooling). Still, there are some
open questions remaining, not only for the legal pro-
cess; for instance, a desired minimum or maximum
size of a community, a specification about the desired
mix of producers and consumers within a community,
the desired ‘environmental, economic, or social com-
munity benefits’ for the community itself, its partici-
pants, and the general public, etc.
2.3 National Implementations
National implementations of the directives are due
partly at the end of 2020 (e.g., the ED II), partly at
the end of June 2021 (e.g., the RED II). Some open
issues have been identified to remain open for the na-
tional adoption (cf. (Cejka, 2020)). Frieden et al.
provided a technical report on the current state of the
implementations of collective self-consumption and
energy communities into national law in June 2019
(Frieden et al., 2019). Accordingly, of 15 investigated
Europen Union member states, 7 already have legal
frameworks for collective self-consumption, only 3
for energy communities. However, legislative pro-
cesses for national implementations have been started
in some member states. Especially once approaching
the implementation deadlines, significant changes to
the report’s described state need to be considered.
3 BLOCKCHAIN
The use of blockchain technology is increasingly dis-
cussed and introduced in many areas (Casino et al.,
2019), including the energy sector (Andoni et al.,
2019; Alladi et al., 2019; Ahl et al., 2020). Pro-
leptic to national legal adoptions of RECs, research
projects are engaging with REC implementations us-
ing blockchain technology. As already done by many
authors, this paper will skip an introduction into
blockchain technology. In this regard, we want to es-
pecially point to (Joint Research Centre, 2019; Finck,
2019a) introducing and covering various aspects of
blockchain technology. However, privacy issues with
blockchain technology are well-known and necessar-
ily need to be taken care of in these projects. Though
using blockchain technology seems to be incompat-
ible with privacy law at first sight, there are options
to stay compatible. As many authors previously en-
gaged with privacy issues in blockchain technology
(e.g., (Finck, 2019a)), this paper will only focus on a
few picked aspects of special interest within the use
case.
3.1 Privacy Aspects
The General Data Protection Regulation (GDPR) is
the main European Union’s privacy act. As in the
form of a regulation act, it is directly applicable in
all 27 member states. It is applicable only for ‘per-
sonal data’ of a data subject, i.e., ‘any information
relating to an identified or identifiable natural per-
son’. In fact, households’ energy consumption data
are personal data, as they could reveal much of per-
sonal habits when recorded in high frequencies, for
example, by Smart Meters (Tang et al., 2015; Grev-
eler et al., 2012). Due to their increasing roll-out
around the globe, many authors have previously been
engaged with their privacy issues (Cejka et al., 2019;
Martinez et al., 2019). For energy communities, a
high frequency read-out of energy production and
consumption will be necessary; participants will thus
be required to be equipped with a Smart Meter.
3.1.1 Identification of the Data Subject
A person is identifiable if it can be unmistakably iden-
tified with any available means, including the combi-
nation with additional available information in order
A Blockchain-based Privacy-friendly Renewable Energy Community
97
to establish a concrete reference to a person. Accord-
ing to the GDPR, all means ‘reasonably likely to be
used’ to identify the respective natural person directly
or indirectly are included in this context, taking ob-
jective factors such as cost and time involved as well
as available technical means into account. Data that
is not traceable to any individual is ‘anonymous data’
and thus not subject to privacy law. It should be noted
that pseudonymized data also falls under the term of
personal data and that the GDPR remains applicable.
Encrypting data is also only a form of pseudonymiza-
tion that does not remove the reference to an individ-
ual.
The application at hand requires to keep the as-
signment of individuals with their energy production
and consumption data, as well as the involved par-
ties in their energy trades. It is expected, that at
least for the time being the number of participants
in RECs will be limited. Therefore, the assignment
to a specific subscriber is easily possible even when
using pseudonyms. Furthermore, for energy com-
munities most probably a private and permissioned
blockchain is used rather than a public and permis-
sionless blockchain; i.e., only authorized entities have
access to the blockchain and those entities need to be
authorized to execute transactions rather than permit-
ting anyone. Thus, by design an authority is required,
that is responsible for adding participants to and re-
moving them from the blockchain, as well as to de-
fine proper roles for them. This authority necessar-
ily needs to maintain an exact mapping between indi-
viduals and their blockchain pseudonyms’ represen-
tation.
3.1.2 The Controller
According to the GDPR, the ‘controller’ ‘determines
the purposes and means of the processing of personal
data’. Its main duty is to take appropriate technical
and organisational measures to ensure adequate pro-
tection for privacy risks. Furthermore, it is required to
ensure that only personal data is processed whose pro-
cessing is required for the particular purpose. How-
ever, in blockchain applications, it is not a priori clear
who serves as this controller. Eligible characters are
the application’s programmer, the application’s ini-
tiator, every participant executing a transaction, the
miner, or the node operator (EU Blockchain Observa-
tory and Forum, 2018). Depending on the use case ei-
ther none, one, or more of the mentioned options can
serve as the controller. In result, the question on who
is in charge can only be answered for a concrete use
case, but not for blockchain applications per se. If all
nodes are considered as controllers, they are neverthe-
less no ‘joint controllers’ according to the GDPR, as
they do not ‘jointly determine the purposes and means
of processing’ (Finck, 2019a).
3.1.3 Rights of the Data Subject
The GDPR stipulates various rights of the data sub-
ject, which the controller is responsible to fulfill.
Among them are the ‘right to rectification’ and
the ‘right to erasure’, which are of special interest
in blockchain applications due to their technology-
intrinsic immutability of persisted data. Later modifi-
cations or even deletions of data on the blockchain are
thus not possible. This immutability aspect is one of
the biggest advantages of the blockchain from a tech-
nical point of view, but critical from the data protec-
tion perspective. Thus, special technical and organi-
sational measures need to be taken to ensure suitable
fulfillment of those rights.
Principles. In this context, some principles of the
GDPR need to be mentioned: Pursuant to the prin-
ciple of storage limitation, personal data may only
be kept for as long as necessary in regard of the pur-
poses they were collected for. This requires in partic-
ular that the storage period for personal data is limited
to the absolutely necessary minimum. Close-by, pur-
suant to the principle of data minimization, only the
minimum required personal data for the specific use
case shall be collected.
Access and Information. The data subject has the
right to know whether and to what extent its personal
data is processed by whom and for which purposes.
This right of information is the central right in order
to claim further rights, for example, the right to recti-
fication, erasure etc.
Amendment. The GDPR requires all personal data
to be accurate and up-to-date. Thus, every reasonable
step with regard to the specific technology must be
taken to correct wrong data. However, modifications
of old data on the blockchain are not possible. Thus,
it may be sufficient to add the new corrected data as a
supplementary statement (Finck, 2019a), though still
keeping the old outdated data on the blockchain.
Erasure. If a person no longer wishes their data to
be processed and there is no legitimate reason to re-
tain it, its personal data must be deleted by the con-
troller. Furthermore, the controller is obliged to take
‘appropriate measures’ to inform other controllers
and processors of the data subject’s request. However,
as the GDPR contains no clear definition of erasure,
it can be argued that the requirements are not placed
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98
too high. It is arguable to be sufficient if the particular
personal data becomes unrecognisable for the proces-
sor, i.e., to become illegible or to be no longer avail-
able. Furthermore, a supplementary statement disal-
lowing its further processing may be reasonable.
There are proposals for introducing mutability
into the blockchain (Politou et al., 2019; Ateniese
et al., 2017); however, we disapprove to discard main
blockchain principles such as its immutability aspect.
Thus, access should be blocked in an appropriate
technical way without the need to destroy individual
data records or change the blockchain’s principles.
3.1.4 Data Protection Impact Assessment
GDPR contains the fundamental ideas of ‘privacy by
design and by default’ to ensure a correct handling
of personal data in every use case ab initio. Thus,
the immutability of persisted data on the blockchain
can be considered early in the design of the use cases.
The GDPR requires to carry out a ‘data protection im-
pact assessment’ (DPIA) prior to the data processing
if it ‘is likely to result in a high risk to the rights and
freedoms of natural persons’, in particular when us-
ing new technologies. The Article 29 Data Protec-
tion Working Party has issued additional guidelines
for criteria in which a high risk can be assumed, which
include (Article 29 Data Protection Working Party,
2017):
data processing on large scale (concerning the
number of concerned data subjects, the volume of
data processed, the duration or permanence of the
data processing activity, the geographical extent
of the processing activity),
innovative use or applying new technological so-
lutions,
when processing prevents data subjects from ex-
ercising a right.
In our opinion, especially the listed criteria are appli-
cable to solutions utilizing blockchain technology as
a ‘new technology’. According to the GDPR, a DPIA
needs to contain at least:
a description of the envisaged processing opera-
tions and their purposes,
an assessment of the necessity and proportionality
of the processing operations,
an assessment of the risks to the rights and free-
doms of data subjects, and
the measures envisaged to address the risks.
The DPIA needs to be carried out by the controller.
However, in our opinion this should be the duty of
the initiator of the blockchain application, as this cor-
responds best to the fundamental ‘privacy by design’
idea.
3.1.5 Smart Contracts
When using ‘smart contracts’, a program code trig-
gers an action once an event matches a corresponding
contract content without further human intervention.
Participants determine desired parameters, for exam-
ple, at which price how much electricity shall be pur-
chased or sold. As soon as matching declarations of
intent of two contracting parties are recognized, the
contract is automatically concluded (‘matching’), ex-
ecuted on-chain and cannot be rolled-back.
The RED II contains a definition for ‘peer-to-
peer trading’, which in our opinion sounds a lot
like considering smart contracts for trading (renew-
able) energy between self-consumers and within en-
ergy communities. It is defined as ‘the sale of renew-
able energy between market participants by means
of a contract with pre-determined conditions govern-
ing the automated execution and settlement of the
transaction’. Listed among the DPIA criteria of the
Article 29 Data Protection Working Party report is
also the ‘automated-decision making with legal or
similar significant effect’ (Article 29 Data Protec-
tion Working Party, 2017). Furthermore, the Article
29 Data Protection Working Party issued an own re-
port on automated individual decision-making (Arti-
cle 29 Data Protection Working Party, 2018). Only
recently, Finck dealt with privacy-related questions of
smart contracts, that can be subsumed under GDPR’s
regulation on ‘automated individual decision-making’
(Finck, 2019b). According to GDPR, the data subject
has the right ‘not to be subject to a decision based
solely on automated processing’ producing legal or
similarly significant effects. This does not apply, if
the decision
is necessary for entering into, or performance of, a
contract between the data subject and a data con-
troller;
is authorised by law, which also lays down suit-
able measures to safeguard the data subject’s
rights and freedoms and legitimate interests; or
is based on the data subject’s explicit consent.
It needs to be noted, that smart contracts are not nec-
essarily concluded between the data subject and the
controller only. However, there are opinions that de-
fine the publisher of a smart contract, or anyone ex-
ecuting this contract (i.e., in essence, every node) as
a controller (EU Blockchain Observatory and Forum,
2018). Furthermore, smart contracts are neither smart
A Blockchain-based Privacy-friendly Renewable Energy Community
99
in sense of AI nor contracts in the legal sense (Finck,
2019b). In essence, they are if/then relations only,
computer code that may nevertheless produce legal
effects.
Numerous regulations, for example, of civil law,
data protection law, consumer protection law, tax law,
e-commerce law etc., have to be taken into account
within the framework of smart contracts, which can-
not, however, be elaborated further in this study.
3.2 Energy Efficiency
Energy communities aim to improve local energy effi-
ciency, yet blockchains are in fact not known for pro-
viding an energy efficient operation (de Vries, 2018;
Vranken, 2017). It is estimated that the cumula-
tive energy consumption of blockchains already ex-
ceeds the energy consumption of medium-sized coun-
tries. This is due to the enormous use of energy
for the ‘proof-of-work’ consensus protocol, imple-
mented, for example, in the probably best known
blockchain the Bitcoin blockchain (Joint Research
Centre, 2019). According to University of Cam-
bridge, the energy consumption of this blockchain
alone currently already exceeds those of countries
such as Finland, Belgium, or Austria (University of
Cambridge, 2020). For energy community applica-
tions, however, we do not require a big blown pub-
lic blockchain. We thus use the ‘proof-of-authority’
consensus protocol, utilizing a subset of blockchain
nodes, trusted to generate new blocks on the chain on
behalf of all nodes.
4 A PRIVACY-FRIENDLY
BLOCKCHAIN-BASED
ENERGY COMMUNITY
The result of the privacy considerations is to avoid
persisting personal data on a blockchain whenever
possible. To mitigate data protection issues, the
use of a combined system with a classic distributed
database is often proposed (Zyskind et al., 2015; EU
Blockchain Observatory and Forum, 2018). Thus,
personal data are saved off-chain; pointers to those
data records and their hash values are saved on the
blockchain. Modifications are possible in the data
base while keeping the pointer on the blockchain in-
tact. They can be identified by comparing the per-
sisted initial hash value on the blockchain with the
current one. Deletions in the data base will result
in the pointer pointing to an empty cell. In this re-
gard, we do not count hash values as personal data
anymore as proper hash functions do not allow to de-
duce back to the original personal data value. How-
ever, this opinion is not yet clarified as some sources
do see hash values as pseudonymized data only which
would not suspend the applicability of the GDPR
(Finck, 2019a; Article 29 Data Protection Working
Party, 2014).
If it cannot be avoided to save personal data
on the chain itself, additional technical and organ-
isational measures, for example, pseudonymization,
anonymization, encryption, must be taken. In that
case, accurate handling of encryption keys need to be
guaranteed, including the proper dismissal of those
keys on a deletion request.
4.1 Architecture
The described solution uses a different approach by
only temporarily storing personal energy consump-
tion data. This architecture (Figure 2) intends to meet
the requirements for operating an REC as well as of
data protection. The central element is a permissioned
blockchain, which limits the number of participants.
New participants must be added by a central author-
ity, such as the community’s operator or administrator
(‘community representative’).
The proof-of-authority process is used as a con-
sensus algorithm for the formation of new blocks,
in which only certain assigned participants (so-
called ‘sealers’) write encrypted transactions into the
blockchain. In addition to these sealers, there can
also be ‘full nodes’ that also store a full local image
of the blockchain (‘Node DB’), but do not necessar-
ily have to be a community participant
1
. The nodes’
task is to enable the operation and updating of the
blockchain for the community. It is assumed that in
addition to the actual operator, other parties are ac-
cepted by the participants to also operate a node (e.g.,
the energy regulator or other legal authorities). In the
proposed approach, the distribution system operator
(DSO) also operates a node in order to be able to pro-
cess grid capacity releases via the blockchain. Nodes
can be added or removed dynamically; in the proof-
of-authority process sealers generate blocks in a de-
fined sequence; in case of the particular sealer failing,
the block is formed by the next sealer.
The infrastructure server is operated and main-
tained by the infrastructure manager of the commu-
nity, which may also be the DSO. The task of this
server is the distribution of the information necessary
for the operation of the blockchain, the active smart
contracts, the configuration of the participants and of
1
Sealers and full nodes are summarized in Figure 2 and
below as ‘nodes’.
SMARTGREENS 2020 - 9th International Conference on Smart Cities and Green ICT Systems
100
Figure 2: Structure of the privacy friendly blockchain implementation of an energy community.
the nodes. In addition, roles are assigned to the indi-
vidual participants to determine access rights to data
within the blockchain. An assignment of real cus-
tomer data to the pseudonym in the blockchain is only
possible for the infrastructure manager as administra-
tor. This is necessary in order to be able to transmit
billing-relevant information to the operator. Data is
stored in encrypted form, thus it can be read out by
authorized persons only. Along with that all data is
exchanged via encrypted connections to ensure maxi-
mum data security.
In contrast, end customers as well as local pro-
ducers are connected to the blockchain as so-called
clients only. Customers equipped with their own
photovoltaic installation are termed ‘prosumers’ in
combination. Their connection is made exclusively
via measuring devices and other sensors or actua-
tors. These hardware elements determine the energy
or power flows of the participants into or from the
distribution grid. They write these measurements as
encrypted data into the blockchain, using appropri-
ate data processing and the communication infrastruc-
ture. Clients do not store a complete image of the
blockchain, only as far as they require data for the ex-
ecution of transactions. If data from the blockchain
must be passed on to other devices (e.g., to control a
charging station for electric vehicles), this is also done
via a secure connection (‘Protected Control’).
By utilizing blockchain technology, stored infor-
mation (e.g., invoices) can be made available to the
participants in a traceable and transparent manner at
all times. This creates a high level of acceptance of
the technology and trust among the participants. Ac-
cess to data of the participants is possible in accor-
dance with defined access rights via a web servers
or ‘Gateway’ operated by the individual nodes. Ex-
amples of such data are measurements, sales or pur-
chases in or from the community or the storage use
of a central battery storage system. The implemented
gateways also offer the option of accepting customer
settings and forwarding them to the smart contracts
(e.g., whether the participant favors to save his sur-
pluses in the battery system for its own later use or
if the surplus should rather be distributed within the
community).
Peer-to-peer trading within the energy community
and the use of the battery system are fully automated
by executing smart contracts in the blockchain. Tak-
ing the access rights into account, additional tools
(e.g., ‘Smart Contract / Contract Design’) can be con-
nected via a ‘Gateway’. Authorized agents can ob-
serve and analyze energy flows and thereby draw con-
clusions for an improvement in the community’s op-
eration.
4.2 Implementation in Relation to Data
Protection
Due to the previously mentioned technical implemen-
tation and the management of the energy community
A Blockchain-based Privacy-friendly Renewable Energy Community
101
by the DSO, it is identified as the responsible entity
for data protection (‘controller’) in the proposed sys-
tem. While this remains questionable regarding smart
contracts, the stipulation of the DSO as infrastructure
operator does not rule out that there may be other en-
tities responsible for a specific application.
Based on the use cases listed, the following data
can be derived, which the REC participants store in
pseudonymized form in the blockchain:
actual energy values in high time resolution,
amount of energy sold to other energy community
participants,
purchased amount of energy from other energy
community participants,
amount of energy stored in the central storage sys-
tem,
amount of energy retrieved from the central stor-
age system.
In addition to the amount of energy, information about
the energy price is stored in order to enable billing and
to make this data transparent and available to every
participant. Unlike the aforementioned energy data,
which can be assigned to the respective community
participant, price data does not belong to the category
of personal data and is therefore not covered by data
protection laws.
Subsequently, in accordance with the data min-
imization principle, the purpose for which personal
data is collected or processed needs to be determined:
execution of the smart contracts (e.g., for handling
peer-to-peer trading of energy, for the usage of
central storage system, for the allocation of net-
work resources or for the release of network ca-
pacities),
billing of local energy trading within the energy
community,
enabling the traceability of storage usage (e.g., as
proof for potential lessors of a battery system and
their users),
provision of billing-relevant information and data
for the user (e.g., for control of the running sys-
tem, motivation of the participants, basis for deci-
sions regarding participant behavior)
Regarding the storage limitation principle, data is
only stored on the blockchain for the duration of an
accounting period (e.g., one month). At the end of the
billing period, the start of a new blockchain is initiated
by the infrastructure server (‘Infrastructure’ in Figure
2). The old blockchain is then archived in a database
(‘Archive DB’) and its hash value is stored as an ini-
tial transaction in the new blockchain to keep a proper
link to it. Since reading out energy data is required
for the operation of the energy community far more
often than it is legally defined for households, a clear
consent to participate is required which could also be
revoked at any time (Cejka et al., 2019). Participants
can leave the energy community in this way as legally
defined to be always possible in the RED II. Consid-
ering this step that may include a request to erasure
of personal data according to the GDPR, the data of
the former participant will not be available in the next
blockchain. Prior to the next blockchain round, pro-
cessing of his personal data must be restricted.
It may be legally required to keep archived
blockchains saved for up to some years accord-
ing to civil and tax law regulations. If individual
blockchains were deleted from the archive, energy
trading can no longer be fully retraced. Thus, only the
billing information would be available, but not how it
was determined.
5 CONCLUSION
As part of the ’Clean Energy for all Europeans Pack-
age’, energy communities beside other plans in the
package shall allow individuals to take an active
part in the energy transition. Contained in the Eu-
ropean Union’s revised Renewable Energy Directive
of 2018 and the Electricity Directive of 2019, the de-
scribed implementation of an energy community an-
ticipates their adoption into national law. As those
national transpositions are due 2020/2021, this area is
expected to be in significant motion within near fu-
ture.
Although using blockchain technology, which is
known for raising privacy questions, we have shown
a privacy-friendly implementation that allows to en-
force the right to rectification’ and the right to era-
sure’ in a feasible way. It has been rolled-out in a
small municipality in Styria, Austria, where the im-
plementation is currently field-tested with real cus-
tomers. Results of this field test will be part of a
subsequent publication. While in the related projects
only the type of ‘renewable energy communities’ was
examined, this implementation would also be utiliz-
able in a ‘citizen energy community’. As this type
of energy communities is not restricted to a defined
proximity, a high number of participants may be in-
volved that may be spread widely.
SMARTGREENS 2020 - 9th International Conference on Smart Cities and Green ICT Systems
102
ACKNOWLEDGMENTS
The presented work is conducted in the projects Sonn-
Wende+ (FFG 2808377) and Blockchain Grid (FFG
3089755), funded by the Austrian Climate and En-
ergy Fund (KLIEN) and the Austrian Research Pro-
motion Agency (FFG).
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