Joint DSO response to ENTSO-E public consultation on the Stakeholder Survey on the Frequency Stability Parameters Implementation Guidance Document

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Distribution System Operators (DSOs) fully recognise the usefulness of ensuring a coordinated approach at synchronous area level of the national implementation on frequency related parameters and transparency on the approaches, processes and decisions taken in each Member State.

A public consultation of stakeholders on guidance for Connection Codes implementation of frequency related parameters is thus very welcome. However, DSOs are surprised by the limited scope of the survey aiming exclusively at generators. The IGD on parameters related to frequency stability clearly states frequency non-exhaustive requirements require co-ordination between TSOs and DSOs. As already agreed between all stakeholders, including ENTSO-E, in the European Stakeholder Committees, frequency stability is a subject across grid connection requirements as well as system operation. Due to the limited scope of the survey now published, DSOs are concerned that TSOs intend to define parameters related to frequency stability at European level without extensive coordination with DSOs. The concerns of the EU Associations representing DSOs’ are listed in this document.