smartEn – Smart Energy Europe, the European business organisation bringing together over 90 companies offering solutions to enable all consumers to become active and flexible, welcomes efforts made in drafting the network code for demand response (DR). We appreciate the decision by ENTSO-E and the EU DSO Entity to share with the drafting committee a first draft before launching the formal public consultation, even though the timeline for comments and amendments is very tight.
The network code offers the opportunity to shape a truly technology-inclusive framework for the market-based procurement of DR by system operators. This is an important step to unlock systemwide services provided by demand-response, storage, and other distributed energy resources (DERs).
However, we are deeply concerned that the current draft is not fit for this purpose, and it is not properly aligned with the requirements set by ACER in its Framework Guideline, both for its scope and content. To ensure nothing is left out, the drafting team should provide a clear overview of how and where in the draft network code each paragraph of the Framework Guideline has been incorporated.