smartEn acknowledges the paramount importance of a high level of cybersecurity for the energy sector in general, and for demand-side flexibility in particular. In order to be successful, innovative solutions need trust from society and politics. smartEn has repeatedly asked for a thorough involvement from stakeholders in the development of this legislation, and for this reason we appreciate the opportunity to participate in this consultation and in the development of the CS NC.
smartEn has concerns on the overall scope and development process of the CS NC. While we appreciate the complexity of such a piece of legislation, and the time-constraints that come with it, we think that the current approach of drafting a high-level network code that includes numerous delegations for different articles and details could lead to an extended implementation timeline in which stakeholders are not involved.
smartEn supports the creation of a network code that is as detailed as possible, and that delegates where necessary to different expert groups at a later stage. However, the conditions and contents should be clearly defined in the NC as well as ensuring the participation of all stakeholders in that drafting process, in the same way that they participate in the drafting process of the NC.