Danish comments on priorities for network codes and guidelines for 2020
Center
Centre for Global
Climate Action
Team
EU Green Transition
Date
10 May 2020
Case No
2020-2159
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 59(3) of the Electricity Regulation (EU) 2019/943 and Article 6(1)
of the Gas 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 2020.
The Danish Government fully supports the recently developed and adopted net-
work codes and guidelines on electricity and gas. In a Danish perspective, they
include the most important network codes and guidelines that will 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.
Denmark wants to emphasize storage (for electricity) as a topic that should be pri-
oritized in the future given the increasing importance of e.g. batteries and other
storage facilities. In order to ensure a certain level of harmonization, we find that
European rules for storage would be very valuable. This would help facilitate the
integration of more renewable energy while maintaining a high security of supply.
Secondly, Denmark wants to emphasize cyber security. Denmark anticipates that
the integration of sustainable energy sources and the green transition will result in
the actors being more reliant of
smart
solutions in the existing operational technol-
ogy in systems. Therefore, there is a need that cyber security is integrated fully in
the network codes and guidelines in agreement with relevant parties. Specifically
Demark emphasizes cyber security in demand response. As the latter grows more
important in balancing the electricity grid, so does the need to ensure a high level of
cyber security for the small digital units (e.g. IoT and IIoT) that are used to that
effect. Therefore, Denmark highlight the need to coordinate the network codes and
guidelines for respectively cyber security and demand response more closely.
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.
/ NIKKO
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