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)

The four Associations representing European Distribution System Operators (DSOs), notably CEDEC, EDSO for Smart Grids, EURELECTRIC and GEODE welcome CEER’s consideration of the use of flexibility with an emphasis on the distribution level and are pleased to provide this single joint response. Consideration of flexibility issues at distribution level is most welcome as it has been missing from many policy approaches so far. Any future regulation should fully consider the need to integrate and support flexibility at the distribution level which is the most affected by the ongoing transformation.

As set out in the European Commission’s Clean Energy Package, DSOs’ roles are set to grow in the future, alongside the deployment of smart grid solutions needed to accommodate the more decentralised and distributed energy resources. The new demand and supply patterns, as well as growing customers’ roles are affecting distribution grids in an unprecedented way. All this change will require distribution system operators to carry out significant investments to ensure their networks will be able to keep up with the innovation pace required. To enble innovative investments however, regulation too must be innovative. Regulators should help DSOs, customers and society to be able to switch from the ‘connect and forget’ to the ‘connect and manage’ approach.

How many smart meters have been deployed so far by EDSO members? How many times could their distribution networks cover the equator? What is the amount of their investments every year? All these questions (and even more) are answered in the “EDSO in Numbers” leaflet. Meet our 34 DSO members & associations, and discover our key figures.

This response paper is a joint response from EURELECTRIC, CEDEC, GEODE and EDSO for Smart Grids, taking part in the two ENTSO-E public consultations on: - the Common Grid Model Methodology pursuant to Article 18 of Regulation 2016/1719 ("CGMMv2") - the Generation and Load Data Provision Methodology pursuant to Article 17 of Regulation 2016/1719 ("GLDPM-v2")

Common statement: ENTSO-E, ENTSOG, SolarPower Europe, WindEurope, EDSO, SEDC, T&D Europe A common energy policy was at the heart of the European project at its inception. Bringing strategic assets together was seen as a stepping stone to rebuild a war shaken continent. The resulting peace and prosperity allowed Europeans to work together on a coordinated energy policy hinging on a liberalized energy market with power- and gas networks integrated across borders. In parallel, ambitious sustainability goals have been developed, clean tech is on the rise and the idea of an Energy Union, a European energy transition for all Europeans is gaining ground.

DSOs stand at the forefront of the energy transition as key enablers of electricity markets and smarter energy systems. In this regard, EDSO welcomes the publication of the European Commission’s Clean Energy Package, particularly in view of the enhanced visibility and recognition of new roles and capabilities given to Distribution System Operators (DSOs). We particularly support the proposals’ move to formally integrate DSOs at the EU level through a single DSO entity for electricity, and recognise their much-needed flexibility needs for an efficient system operation.

EDSO welcomes the opportunity to comment on the updated Energy Storage Technology Development Roadmap prepared by EASE and EERA. Electricity storage is a key technology that can be used by DSOs to defer grid expansion by making more efficient use of the existing capacity and improving the reliability, quality and affordability of the existing local distribution service.

The European associations representing distribution system operators (DSOs), CEDEC, EDSO for Smart Grids and GEODE and the association of automotive and industrial battery manufacturers, EUROBAT call on the EU institutions to deliver a clear regulatory framework incorporating storage as a key instrument towards achieving the Energy Union. Battery energy storage is an important grid management solution that can help boost the robustness of Europe’s electricity grids. To make use of this opportunity, network operators should be allowed to own and operate batteries for the purposes of grid balancing and operation.