欧洲电力行业联盟-欧盟DSO实体和ENTSO-E关于网络法规草案的协商（英）-2023.11-63页_583kb

Eurelectric Response to Public Consultation on Network Code for Demand Response

Eurelectric, representing the European electricity industry, submitted a comprehensive response to the public consultation on the Network Code for Demand Response (NC DR). The core objective is to foster a cost-effective energy transition by promoting market-based procurement, ensuring legal clarity, and integrating demand response with other flexibility resources.

Key Recommendations:

• Adapt regulations to accommodate DSOs' growing role, emphasizing local markets and avoiding overlaps with existing network codes.
• Ensure the NC DR includes load, storage, and distributed generation without exclusion, prioritizing technology neutrality and non-discrimination.
• Favor market-based procurement over non-market-based approaches, with clear compensations and procedures to prevent undue restrictions.
• Strengthen definitions and legal certainty by amending recitals, articles, and defining terms like "local service provider" and "prequalification" to avoid ambiguity.
• Harmonize rules to support cross-border interoperability, monitoring, and annual reassessments of national terms and conditions.
• Address practical concerns such as granularity in bid sizes, rebound effects, and data portability to enable wider participation.

Eurelectric advocates for a regulatory framework that enhances system security, supports carbon neutrality, and ensures fair access for all market participants through robust implementation and legal refinement.