31 October 2024
WindEurope response to ACER consultation on Network Code Demand Response
In May 2024, EU DSO Entity and ENTSO-E submitted their draft proposal to ACER of a new Network Code on Demand Response. Their proposal also included amendments to the three related electricity network codes: balancing, system operation, and demand connection. ACER consulted on their revised draft from September 5 to October 31. This document presents WindEurope’s response to the ACER stakeholder consultation on the draft Network Code.
Apart from comments on articles such as flexible connection agreements and congestion management, our general comment is this draft Network Code fails to achieve the intended harmonization of market rules. It assigns the development of numerous methodologies to TSOs and DSOs and anticipates that most of the aspects requiring harmonization will be further defined in national Terms and Conditions or Methodologies. This approach undermines the purpose of the Network Code, as it relegates fundamental elements to a subsidiary process rather than addressing them comprehensively at the European level, which is essential for achieving effective market harmonization.
