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.

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 replied to the online consultation that CEER held on its 2018 Work Program.

The 4 DSO associations have published a joint comment paper to ENTSO-E public consultation on the Stakeholder Survey on the Frequency Stability Parameters Implementation Guidance Document.

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).

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 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.

EDSO sees a significant improvement to the proposed Clean Energy Package related to the recognition of the evolving DSOs’ tasks and responsibilities in meeting the clean energy transition. We support the enabling framework for DSOs to make use of flexibility as a means to improve system efficiency and avoid grid reinforcements, but submitting DSOs to strictly regulated exceptions, particularly on storage, can impose certain impediments. EDSO agrees with Article 36 that storage services should remain a market activity. However, if the DSOs needs the storage for maintaining grid stability and security, an exemption to the DSO use of own grid-scale storage facilitates shall be granted for this particular case. DSOs should not use storage to engage in the market, but only for technical purposes to solve local grid constraints (emergency situations, voltage limits and reactive power control.) DSOs will play a key role in facilitating and integrating the uptake of electro-mobility into distribution grids. Recharging infrastructure should be mainly developed by market parties if the business cases develops in this area. DSOs should nevertheless be allowed to deploy and operate the infrastructure in those member states where it is politically desired, as well as be involved the planning and development phases. Ensuring DSOs’ continued access to all grid and metering data, as well as handling it, when applicable on behalf of customers, is crucial for fulfilling core DSOs tasks in maintaining system stability and quality of supply. Given the diversity of data models across member

Electric vehicles are growing in importance and are adding new loads to distribution networks. EDSO fully supports the development of electro-mobility, as DSOs are key enablers of e-mobility and flexibility markets, and we welcome the Directive’s provisions to promote the electric vehicles’ integration within new building infrastructure. However, concerning the provisions in Article 1, we believe that at this stage ducts (pre-tubing) for recharging points in residential building structure is the most cost-effective way for incentivising customers’ switch to electric vehicles. This requirement should also be applied to non-residential buildings, since an obligation to equip parking spaces with recharging points that have smart charging capabilities would lead to onerous costs and burdensome complexity both for buildings owners and network operators.

The role of ACER and involvement of DSOs in the development of network codes: - When revising network codes, DSOs and other relevant stakeholders should be fully involved before ACER submits its proposal to the European Commission (Article 5) - Enhancing the role of ACER in new DSO areas, including its oversight over the new DSO entity is positive insofar as it calls for a proper involvement and consultation of DSOs - Involve member states in determining the boundaries of system operation regions (Article 8) - Keep the old voting rule, i.e. decisions of the Administrative Board of ACER shall be adopted on the basis of a two thirds majority of the members present to guarantee representative decision-making (Article 19) - EDSO has reservations about ACER’s recommendations on distribution tariff harmonisation (Article 16 (9) Electricity Regulation)