FGs on System Operation – Questions for Consultation

Personal Details:

Name / Gert De Block
Company / CEDEC
Address / Rue Royale, 55 B10 – 1000 Brussels
Contact email /
Phone / ++32 2 217 81 17
Country / BELGIUM

Consultation Questionnaire

General Issues

  1. The Initial Impact Assessment (IIA) identifies the following challenges (i) growing amount of distributed generation and variable generation (ii) increasing interdependence of control areas. Are there additional key cross-border challenges that the Framework Guidelines (FGs) and Network Code(s) on System Operation should address?

No additional key cross-border challenges should be addressed in the Framework Guidelines and Network Code(s). Furthermore it should always be checked whether the mentioned requirements are of cross-border importance or not and hence should be addressed or not.

  1. The Framework Guidelines identify a number of actions and requirements to be included in the Network Code(s) as a solution to these challenges. Are the actions and requirements identified in the Framework Guidelines appropriate to solve these challenges?

The proposed actions and challenges seem to be appropriate.

  1. Are the proposed levels of harmonisation sufficient to solve these challenges?

The proposed levels are sufficient and even going beyond the necessary harmonisation. Distribution grids considered as not relevant for cross-border energy exchange and with no relevance for cross-border system stability should not be addressed in the Framework Guidelines, nor should there be a need for requirements on system operation for those.

In the table herewith a lower level of harmonisation for a number of the challenges is proposed:

  1. Should the Framework Guidelines be more specific with regard to areas that need to be harmonised, both across and within synchronous areas?

The Framework Guidelines should not be more specific as they are only guidelines. There is no need for specific rules on system operation in the Framework Guidelines.

In our opinion it is important – from a practical point of view – on national levels and particularly within synchronous areas, to leave room to (existing) best practice proceedings. This will lead to a faster and less complex adoption of Network Code requirements, since fewer parties would be involved (existing DSO requirements would still be applicable).

  1. Should the Framework Guidelines require the development of common rules for System Operation between synchronous areas?

Representing DSO-member companies, we leave it to ACER whether to develop such rules or not.

  1. Considering the current arrangements of the system operation rules and procedures throughout the EU, what would be an appropriate level of detail for the Network Code(s) on System Operation?

The level of detail for the Network Code(s) on System Operation should be limited to a clear framework and not go into details of structured processes.

See also table in question 3.

  1. What key benefits and types of cost would you expect for compliance with these requirements? Please quantify from your point of view.

For DSOs, the following extra investments can be listed, but however not quantified at this moment:

-Extra staff + training

-ICT/ software tools

-Monitoring tools

-External services

A quantification of costs will only be possible once the final requirements in the Network Code are known. However, we strongly support a cost-benefit analysis before implementing the Network Code.

Benefits could eventually arise on market level where these requirements will be supporting the liberalised energy market.

  1. Should the Framework Guidelinesbe more precise on organisational aspects of operational security, in particular with regard to security assessment?

The Framework Guidelines do not need to be more precise on this topic. See also our response to question 6.

Specific Issues

  1. Are the implications for significant grid users clear and relevant?

The use of different terms in the Framework Guidelines does not contribute to the readability of the document, especially where it concerns the DSOs.

Throughout the document, the DSOs are considered as system operators on the one hand and as (significant) grid users to the TSO or other DSOs(both in their role as a Network Operator) on the other hand.

It is not always clear in what quality (grid user or system operator) the DSO is acting.

As already stated in our comments on the Framework Guideline on Network Connection, we reiterate our concerns regarding this dual use for the DSO and suggest again to not consider the DSO as a grid user. DSOs, like TSOs, are system operators and should be considered as such. The relationship between DSOs and TSOs is completely different from the relationship between TSO/DSO and a grid user (consumer and/or a generator). It is more a relationship of collaboration between system operators in which the DSO is not simply executing dispatching orders from the TSO, but where the DSO responsibility domain is recognised and respected.

  1. Are the roles and responsibilities sufficiently addressed?

The roles and responsibilities are sufficiently addressed, but keeping in mind our remarks in point 9.

  1. Are the individual provisions under Scope & Objectives, Criteria, Methodology & Tools, Roles & Responsibilities, Information Exchange and Implementation Issues, associated to the particular topic, adequate? Should there be any additional elements?

There is no need for additional elements.

  1. Could you foresee any other relevant New Applications which should be mentioned in these Framework Guidelines?

One new application which can be mentioned in the Framework Guidelines is storage (e.g. electric vehicle to the grid, storage of electricity through other energy carriers (Hydrogen, …) related to the balancing activities of the DSO in smart grids with a lot of decentralised generating units.

Confidentiality

Please state whether you would like ACER to treat your contribution confidentially. If yes, please provide a non-confidential version of your answer.

CEDEC contribution is not to be considered as confidential.