E.DSO Position Paper on the Affordable Energy Action Plan, on ACER’s Report on Network Tariff Practices and on the EC Guidance on Anticipatory Investments

E.DSO published a position paper “Securing the energy transition, while keeping energy prices affordable”, in a reaction to three key publications: the EU Affordable Energy Action Plan; the ACER’s Report on Network Tariff Practices; and the European Commission’s Guidance on Anticipatory Investments.

In this paper, E.DSO emphasises the need for supportive regulation, investment in grid infrastructure, proactive network planning (through anticipatory investments), flexible energy demand, and guiding principles on tariff methodologies to ensure affordable, sustainable electrification across Europe.

It also highlights the following key positions and recommendations:

  • Electrification needs substantial upfront investment in distribution networks, which will enable cheaper, cleaner energy and long-term price stability.
  • Regulatory frameworks must ensure transparent, fair, and stable returns for DSOs.
  • Guiding principles for clear and cost-reflective tariff principles, respecting national specificities (no “one-size-fits-all approach”).
  • Flexibility will be a complementary tool – but not a substitute – for cost-effective and efficient grid development, as flexibility alone cannot replace infrastructure needs.
  • The need for EU support for local flexibility markets, and demand-side tools.
  • Proactive planning and regulatory visibility at distribution level to avoid bottlenecks and accelerate RES deployment.
  • Once anticipatory investments are justified and approved, they must benefit from stable, unchallenged ex post treatment by NRAs.
  • Removal of investment caps that limit proactive development.
  • Public support tools – especially grants – should be promoted to ensure DSOs’ financial viability, and fair tariffs.

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