Joint DSO Response to CEER Guidelines of Good Practice for Flexibility Use at Distribution Level

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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.


Policymakers and regulators should have a clear understanding on the real practical needs of DSOs, which could be captured in the following statement:
‘DSOs need to have adequate means in place to make use of flexibility resources, supervise flexibility operations and make it easier and cost-efficient for customers to benefit the most, while ensuring quality of service and security of supply in a challenging environment.’
Furthermore, regulators also need to be aware of two main aspects with regards to DSOs’ flexibility roles. One aspect is how does flexibility impact distribution system operation in relation to their dual function, namely market facilitation and reliable electricity service provision, and another aspect is the own technical needs of the DSOs.
The European Commission’s proposals on a regulatory framework that allows and incentives DSOs to procure flexibility services, which may complement or obviate the need to upgrade or replace electricity capacity and supports both the efficiency and secure operation of the distribution system, is welcomed. Nevertheless, this should not place any limitations on DSOs from accessing all forms of flexibility options, including by the models set out by CEER in this consultation.