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.

EDSO welcomes the annual consultation of the European Commission on the establishment of the annual priority lists for the development of network codes and guidelines for 2017 and beyond. Over the last five years, EDSO has deployed considerable efforts to contribute to the development of the network codes & guidelines. By providing input & feedback on documents or consultations, participating in meetings & workshops, and more recently contributing to the activities of European Stakeholder Committees, EDSO has taken an active part in this process and is satisfied that the attention paid to considerations raised by DSOs has gradually improved throughout the last years. EDSO recognises that a substantial move toward the completion of this process was achieved in 2016 with the adoption of a majority of network codes and guidelines. However, it should be underlined that some of the most controversial rules are still to be finalised. At the same time, the rules that have already been adopted should be carefully implemented at the national level. Finally, lessons from this long and complex process should be drawn before envisaging the way forward at European level.

The work of the five associations (EDSO, CEDEC, ENTSO-E, EURELECTRIC and GEODE) in the field of TSO-DSO cooperation culminated with the publication of their common TSO/DSO data management report. The report serves to provide input to the European Commission’s forthcoming market design and renewables package. The document aims in particular at sharing recommendations on common European principles and criteria for data and information exchanges. This will help preparing the much-needed cooperation between TSOs and DSOs in the face of new challenges and developments including the prominent role of customers in the energy transition, the need for flexibility in balancing and congestion management, as well as in stepping up efforts of coordination between TSOs and DSOs.