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.

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 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