Energy Efficiency Review – EDSO response to EC consultation

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EDSO welcomes this public consultation in preparation for the revision of the ‘Energy Efficiency Directive’ (EED).

In its response, EDSO focuses on the questions related to metering and billing (articles 9 to 11). In addition, we take this opportunity to make the following recommendations to the European Commission:

  • Avoid creating uncertainty for smart meter deployment
    A majority of European consumers will soon be equipped with smart meters, in compliance with the Third Energy Package. Deployment is already underway or being planned by DSOs. Proposing to further harmonise smart meter systems at this time, beyond the existing EC’s recommendations on minimum smart metering functionalities, could further delay smart meter deployment and thus consumers’ access to detailed and accurate information on their energy consumption.
  • Clarify the definition of “energy distributor”
    The EED introduced a definition for an “energy distributor,” which may or may be an electricity distribution system operator (DSO). This definition appears to be more suited for a heat network than for gas or electricity networks. The definition also lack clarity on which requirements are targeting DSOs, retailers and/or district heating operators. We suggest amending this definition to avoid any confusion between regulated activities and competitive activities.
  • Enable DSOs to use system services
    Article 15 of the current refers to ancillary services used by DSOs. To date, the use of such services has not yet materialised. DSOs often have no incentive to use system services from local consumers or generators or simply are prohibited to interact with grid users. The article should be amended to clearly states that DSOs are allowed to use ancillary services.