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In the wake of the upcoming negotiations on the reform of the electricity market design, E.DSO, today, publishes a third detailed statement for the attention of EU Co-legislators.

E.DSO members welcome the consumer-centric approach of the Commission's proposals. In particular, we welcome the recognition of anticipatory investments needs to support flexibility services optimizing the electricity network and promoting demand response. E.DSO equally backs the incentivisation of efficient investments in the network (including flexibility resources and flexible connection agreements) and the involvement of DSOs in the evaluation process of demand side response as well as storage capacity needs, to further promote system security and the realization of the existing flexibility potential.

Despite the positive developments mentioned above, the members of E.DSO feel compelled to underline a series of improvements aimed at increasing the efficiency of this reform, ensuring its coherence, and avoiding subsequent complications, ultimately serving the interest of the customer. In this vein the statement tackles the following points:

The mobilization and integration of distributed flexibility, and the implementation of an appropriate timeline for the delivery of the National Assessment Report of Flexibility under Article 19c.
The unique opportunity to reasonably consolidate the role of DSOs in European legislation, enabling a sustainably support also at national level in the substantial challenge of network investments.
The risk of discriminating DSO peak shaving products (Article 7a).
The need to ensure adequate investments from generators in grid services when implemented price support schemes / CfDs (Article 19c).
The benefits of incentivizing energy sharing between local generators and consumers.
The risk of introducing unreadable, insecure and uncertified sub-metering devices, increasing billing overview complexity for the consumer. A clear differentiation between regular advised and sub meters must be ensured.
Capacity availability for new connections and the associated need for transparency from DSOs.