EDSO Response to the European Commission’s Public consultation on priorities for Network Codes and Guidelines for 2018
EDSO welcomes the consultation of the European Commission (EC) on the establishment of the annual priority lists for the development of network codes (NC) and guidelines (GL) for 2018. Considering the lack of new substance in the consultation document, EDSO would also like to take this opportunity to formulate some general remarks on the way forward in the development of network codes.
Joint DSO Response to All TSOs’ proposal for the key organisational requirements, roles and responsibilities in relation to data
This response paper is a joint response from EURELECTRIC, CEDEC, GEODE and EDSO for Smart Grids, taking part in the ENTSO-E public consultation on All TSOs' proposal for the key organisational requirements, roles and responsibilities (KORRR) in relation to data exchange pursuant to Article 40.6of Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation (SO GL). The consultation response has been submitted online.
EDSO position paper on local energy communities
Engaging in local energy communities represents a promising opportunity for Europe’s consumers to better manage their energy use while promoting a wider renewables uptake. In their function as neutral market facilitators and key enablers of the energy transition, distribution system operators will play a fundamental role in empowering prosumers, individually or collectively engaged in energy self-consumption. In this position paper, EDSO for Smart Grids highlights the roles that DSOs will play in supporting these new entities with the most adequate grid infrastructure solution. Such services can include grid balancing, data metering and other solutions they may need. However, EDSO also signals that the regulatory framework for energy communities must be rightly set, by making sure that new entities are not exempted from network charges and other system obligations that apply to the rest of the customers.
EDSO Response to EC consultation on Trans-European Networks – Energy (TEN-E) Evaluation
EDSO welcomes the public consultation on the evaluation of the TEN-E Regulation. It takes place at a decisive time for EU energy policy. The TEN-E framework considers smart grids as a “thematic area” with a marginal place in the program, while priority is given to the “corridors” that involve high-voltage networks and interconnectors. This paradigm should be abandoned in the reform of the TEN-E framework. Smart grids have become a central element in the energy transition and smart distribution grids will be instrumental in placing the consumers at the centre of the future European energy system. This should be reflected in a new TEN-E framework that should be adapted to this paradigm shift.
EDSO Reaction to MEP Kariņš’ Market Design Reports (Electricity Directive & Electricity Regulation)
As the centre piece of the Clean Energy Package, the Electricity Regulation and Directive are crucial legislative proposals for DSOs. Rapporteur Kariņš has published his draft report on the Market Design in June. In his amendment proposals he introduced important changes to the Commission’s original proposal.
EDSO Response to the CEER Consultation on its Work program 2018
Joint DSO response to ENTSO-E public consultation on the Stakeholder Survey on the Frequency Stability Parameters Implementation Guidance Document
EDSO Response to the European Commission’s Consultation on the list of proposed Projects of Common Interest
EDSO acknowledges the importance of smart grid projects to significantly contribute to market integration, sustainability, security of supply and competition throughout the European Union and therefore the need for such projects from an EU energy policy perspective. EDSO is therefore favorable to the acceptance of the 4 smart grid candidate projects in the Third list of Projects of Common Interest (PCI).
EDSO amendments on Renewables Directive
Simplify and accelerate administrative procedures for network development while ensuring high technical and safety standards Article 16 should clarify who are the applicants for the permits to build and operate infrastructures for the production of energy from renewable energy sources . We suggest that the permit granting process associated to the use of network infrastructure should not be restricted to privates RES investors, but should also include residential, commercial and industrial consumers. The applicant should be provided with all necessary information, and the single administrative contact points that will be created should coordinate and involve, in close cooperation with renewables developers, local authorities and distribution network operators. EDSO believes that for demonstration projects and installations with a limited electricity capacity a simplified grid access procedure could be established. However, administrative simplicity must be achieved while complying with technical grid codes and safety legislation. Thus, installations must only connect to the grid under DSO supervision and after network capacity and safety approvals are granted (Article 17).
EDSO amendments on Electricity Regulation
EDSO is strongly committed to proactively contribute to the institutional set up of the proposed DSO entity. Article 49 sets a number of provisions stating that the DSO body is open for undbundled DSOs and those which are not part of a vertically integrated undertaking. EDSO fully supports this clause as it gives a historic opportunity to have a fully-fledged, single representation for electricity DSOs at European level, without accounting for other parts of the value chain. In this regard, we fully agree that its membership should be limited only to electricity DSO companies, and that no formal representation is extended to member states representatives or industry associations to ensure a consistent and strong DSO view. These could nevertheless be assigned consultative or observers roles. Moreover, EDSO remains open as to the participation of smaller DSO companies, which could be tackled at a later stage. Participation can be envisaged for electricity DSOs with a customer base above 100,000 customers, which fits the EDSO current membership criteria. This entails that the expected magniture of the eligble DSOs could reach a dimension between 200 and 240 companies.