Danish comments on priorities for network codes and guidelines for 2019
Office
EU Department
Date
22 January 2019
Case No
2018 - 3713
/ SIDHO
The Danish Government welcomes the opportunity to comment on the Commis-
sion’s public consultation on priorities for network codes and guidelines for 2019
based on Article 6(1) of Regulation (EC) No 714/2009 and Regulation (EC) No
715/2009.
The Danish Government overall agrees with the Commission’s priority to continue
the ongoing work of implementing network codes and guidelines for 2019.
The Danish Government fully supports the recently developed and adopted net-
work codes and guidelines on electricity and gas that in a Danish perspective in-
clude the most prioritised network codes and guidelines to support efficient markets
in Europe on electricity and gas.
The process of implementing already adopted network codes and guidelines re-
quires substantial resources from all relevant parties, including the Commission,
ACER, ENTSO-E and the national regulatory authorities. The recently adopted
network codes and guidelines still have to show their effect on the functioning of the
internal market and Denmark agrees that this is generally not the time to develop
new rules.
However, Denmark wants to mention storage (for electricity) as a topic that should
be prioritized in the future, possibly already from 2019. Storage and the connected
technologies (batteries, etc.) are developing at a fast pace. In order to ensure a
certain level of harmonization, we find that European rules for storage would be
very valuable. The RfG (Requirements for Generators) network code does not in-
clude storage (apart from pump storage). A recast of the RfG code could hence be
the relevant network code to address. Given the timeline for legislative proposals
and approval, it could be relevant to start this work in 2019 already.
Apart from that, the Danish Government supports the Commission’s priority of re-
sources on full implementation and enforcement of the recently developed and
adopted network codes.
Side 1/1