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 Commission’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 network
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 requires
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 prior-
itized 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 technology in
systems. Therefore, there is a need that cyber security is integrated fully in the net-
work 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 guide-
lines 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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