To link retail and wholesale markets effectively and enable system users at distribution level to participate in the market, the TSO-DSO interface needs to be more clearly defined and agreed upon. TSOs and DSOs have already launched initiatives for closer cooperation in the areas of coordinated access to resources, regulatory certainty, grid visibility and grid data. There is a need to design an integrated solution for balancing and congestion management at both TSO and DSO level to make more efficient use of distributed resources in the interest of the customers. Therefore, DSOs and TSOs should investigate possible options for coordinating the use of flexible resources. One option could, for instance, take the form of a single marketplace for both flexibility and balancing services. TSOs could thus access distributed resources (all low-voltage connected customers and small-scale generation) for the overriding concern of system operation purposes (balancing, stability, etc.), while DSOs could at the same time use these resources to operate distribution networks.
We believe that Europe-wide or regional rules are needed to facilitate access of flexibility sources at distribution level to all markets and thus better integrate retail and wholesale markets. Such rules (no matter whether in the form of a regulation, guideline or network code) will allow maximising benefits of Demand Side Response, storage, distributed generation and smart grids to the benefit of the customer. The customer is also at the heart of data ownership, and an appropriate data model framework has to be developed swiftly across Europe. ENTSO-E believes that there would be efficiency and advantages for a single representation of DSOs in Brussels.
ENTSO-E will launch on a voluntary basis a work stream on distributed flexibility with DSOs and involve closely all interested stakeholders in this work and share conclusions.
The EC should propose European rules (i. e., a guideline, network code, regulation) on distributed flexibility, encompassing the TSO-DSO interface, data management, network fees and retail market integration of storage, empowerment and privacy rules for the customer, self-consumption and managing interactions between suppliers and independent aggregators.
TSOs and DSOs should investigate further integrated solutions for balancing and congestion management, at both TSO and DSO levels.
ACER should assess data governance models on a non-binding basis and develop guiding principles for NRAs on these, promoting the technical standardisation of data exchange formats and communication protocols.