Response to Council of European Energy Regulators (CEER) consultation on flexibility use at distribution level

Response to Council of European Energy Regulators [ 2.9 mb]

We welcome this consultation and the focus on flexibility on the distribution level. Balancing networks at the distribution level and tapping into the growing number of flexibility sources has the potential to improve network efficiency and increase consumers’ control of their own energy bills.

Citizens Advice further supports the endeavour of developing guiding principles for national regulatory authorities (NRAs). We do not believe that going beyond principles in pursuit of greater harmonisation is desirable. EU Member States have made varying progress down the path of making their grids smart and flexible, and the challenges that individual Distribution System Operators (DSOs) face on their network vary greatly. NRAs need to be able to establish a framework and processes to facilitate and coordinate access for DSOs to flexible resources which are appropriate and relevant to their national context. This includes developing definitions for flexibility products.

In this response we have addressed the changes we believe are necessary to make flexibility work for consumers. The consultation document approached flexibility from an electricity system and regulatory point of view. It listed potential benefits to consumers but not the critical success factors to make these benefits a reality. We believe that DSOs and NRAs should do more to inform and protect consumers, prevent discrimination of and provide support to vulnerable consumers, and enable consumers to take full opportunity of a flexible energy system.