On March 9, 2023, the European Commission invited the association representing all sizes of Distribution System Operators (DSO Entity) and the European Network of Transmission System Operators (ENTSO-E) to submit a proposal for the Demand Response (DR) network code to the European Union Agency for the Cooperation of Energy Regulators (ACER). To ensure transparency and gather diverse perspectives, the DSO Entity and ENTSO-E initiated a public consultation on the proposal's content, concluding on 10 November.

Recognising the profound importance of this matter to the clean energy research community, EERA actively participated in the consultation, providing detailed insights into its stance. Several key points emerged from the submission, highlighting critical considerations for developing the DR market.

Firstly, the reply underscored a pressing need for a more comprehensive exploration of baseline development methods, emphasising the importance of an open and harmonised approach to create an efficient and reliable validation tool. Additionally, EERA emphasised the significance of allowing smaller bid sizes, fostering incentives for creating efficient aggregation tools and operational procedures to extend the potential resource base for DR and encourage innovation in the aggregation landscape.

Interoperability of data was underlined as a crucial aspect, stressing that all data must follow a semantic structure with well-defined ontology elements. Standardisation was emphasised as vital for achieving seamless interoperability and enabling effective data exchange among various stakeholders in the DR ecosystem. In the realm of register platforms, EERA advocated for user-friendly interfaces adhering to a standard for data exchange with different stakeholders to ensure accessibility and collaboration in the demand response market.

EERA also called for a more harmonised pan-European development approach, expressing concern over potential market segmentation resulting from delegating market development to individual system operators. It underscored that a cohesive and efficient DR market necessitates a unified strategy. Recognising the value of energy-limited capacity products, it urged acknowledging their importance in the prospective EU regulation, as such products carry out the essential function of allowing system operators to dispatch a predetermined amount of energy within a specified activation window.

Finally, EERA highlighted the need to set clear limitations on the magnitude of the rebound processes, especially concerning thermal loads, to ensure accurate forecasting and the reliable delivery of DR services.

To access EERA’s full reply, please click here.