This paper acts as SolarPower Europe's response to the ACER Public Consultation on the draft network code on demand response.
ACER Demand Response Consultation
The aim of the new rules on demand response is to enable the participation of demand response including load, energy storage and distributed generation (individually or aggregated) in all electricity markets, contributing to market integration, non-discrimination, effective competition and the efficient functioning of the market.
Download the position paper
Dedicated Measurement Devices (DMDs)
- Dedicated Measurement Devices (DMDs) should be deployed for flexibility applications where smart meters don't suffice or are unavailable.
- In areas with compatible smart meters, grid operators must ensure accurate accounting by linking DMDs to connection points with smart meters and properly segregating data.
- Certification should be standardized across Europe through the Demand Response Network Code’s Terms and Conditions and Methodology.
1
Simplify and harmonised data standards
- We recommend simplifying and harmonising data requirements and protocols for aggregated assets and mass-produced Distributed Energy Resources (DER) across Europe.
2
Harmonised standard for interoperability
- The code should target a common approach to interoperability of control (“subsidiarity”). This should be facilitated by proven and globally applied ETSI-CEN-CENELEC standards. W
3
Market based procurement and derogation rules
- Ensure that the System Operator provide transparent grid data (on congestion and flexibility prices)
- Ensure revenue stacking will be possible through future intraday 15’ markets
- Restrict direct system operator control measures to emergency post-market measures when the market is feasible
- Establish clear conditions for regulators to agree on market access and market-based derogation principles
4
Flexible grid connection agreements and power control systems
- FCAs will play a crucial role in the future energy system by enabling faster asset connections, reducing costly grid upgrades, and promoting consumer flexibility in constrained areas.
- It’s essential to recognise that FCAs should not be used to address grid congestion, delay necessary reinforcements, or replace vital curtailment compensation for generators
- EU-wide definition and certification process of power control systems to support effective FCA implementation and protect grid users from unnecessary expenses.
5
Harmonised prequalification for Frequency Control Reserve
- It is recommended that the Transmission System Operators (TSOs) participating in joint procurement of Frequency Containment Reserve (FCR), such as through the "FCR Cooperation," should harmonize their prequalification processes at the synchronous area level.
6
Stakeholder Involvement & implementation of requirements
- It is important that the regulation clearly states the start of requirements aside from when they should be accomplished.
7
Header Image
© Shutterstock
Interested in becoming a member?
Why become a member?
Do you want to stay up-to-date about solar energy?
