Eurelectric - Response to the Public Consultation on the ENTSO-E Draft Demand Connection Code
Executive Summary
The response paper reiterates that the demand connection code (DCC) should focus on cross-border issues. The search for the optimal technical and socio-economic solutions to outstanding cross-border issues must consider all available system options at the interface between TSOs and grid users. Requirements deviating from existing practices should be justified by a cost-benefit analysis (CBA).
Demand-Side Management- Well-functioning markets with active customer involvement are key to developing demand side participation, including demand-side management (DSM) and demand response (DR).1 The market design for consumer products that support grid balancing should be addressed in the balancing network code. The remuneration of customers and market operators must be taken into account when assessing requirements.
- Technical requirements for DSM that are unrelated to connection should apply only to customers who decide to enter the programme. Therefore, such requirements must not become a precondition for connecting customers to the network or for maintaining their connection. No specific notification procedure for DSM capabilities can thus be expected in the connection phase. As monitoring DSM requirements cannot result in losing the right to be connected to the network, the DCC should explicitly state that it does not regulate compliance monitoring of these capabilities.
- In any case, compliance monitoring for mass demand side participation as currently proposed would create substantial and unnecessary costs for the system. European standards should be used to assess compliance with these requirements. ENTSO-E and the European Commission should thus ensure proper coordination between the network code development and current standardisation processes (i.e. Mandate M-490 for Smart Grids).
Reactive Power Exchange Capabilities- Reactive compensation at the TSO-DSO connection point is not a suitable tool for emergency management. It can provide an alternative to transmission network development, but at the cost of important investments and operational costs (losses) and constraints in distribution networks. Imposing it through the DCC without an appropriate CBA conducted by ENTSO-E would result in a mere transfer of costs from TSOs to DSOs. Such a mandatory requirement does not take into account the need for distributed energy resources to participate in voltage control. It would also have an adverse effect on the development of market-based ancillary services.
- All possible solutions for regional control of reactive power and voltage must be considered. Article 10.1b should thus be deleted or leave some flexibility for defining the requirement at national level. The decision on the reactive power exchange between TSO and DSO should be based on the result of a national CBA. An agreement between TSOs and DSOs should be required. Any efficient DSO costs need to be recovered.