Contribution ID: a7f106c0-d739-4f92-ace6-7f7acc70057f

Date: 10/06/2022 19:56:45

ACER Public Consultation on the Policy Paper on the

revision of NC RfG and NC DC

Fields marked with * are mandatory.

Important developments in the policies of decarbonisation of the European Union (EU) energy and
transport sectors have taken place since the inception of the development of the first European Grid
Connection Network Codes (GC NCs) in 2012.

In the framework of the Grid Connection European Stakeholder Committee (GC ESC), the European
Commission proposed for ACER to initiate the process towards the amendment of the existing GC NCs in
September 2022. The amendment process process, as presented to the GC ESC is outlined in the Figure
below:

Please note that this public consultation belongs to the first phase of the process (scoping phase) that will
be followed by the call for stakeholders to submit their proposals in September 2022 during the 8-week long
consultations.

For the avoidance of doubt, the Commission Regulation (EU) 2016/1447 of 26 August 2016 establishing a
network code on requirements for grid connection of high voltage direct current systems and direct current-
connected power park modules (NC HVDC) is out of the scope of this consultation as the work on its
amendment is expected to start in 2023.

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 The purpose of this consultation is to gather views, feedback and input from all stakeholders on the Policy
Paper (link) drafted within the scoping framework of the process. This consultation is addressed to all
interested stakeholders. Consulted Policy Paper, planned to be published by September 2022, aims to
transparently indicate to stakeholders the areas in which amendments are to be expected, as regards:

Commission Regulation (EU) 2016/631 of 14 April 2016 establishing a network code on

requirements for grid connection of generators (NC RfG) - link
Commission Regulation (EU) 2016/1388 of 17 August 2016 establishing a Network Code on
Demand Connection (NC DC) - link

Replies to this consultation should be submitted by 10 June 2022 23:59 CET.

ACER is highly committed in processing personal data in a lawful way.

Find out more how we process your data: https://www.acer.europa.eu/the-agency/about-acer/data-
protection

* 2 Name of the stakeholder:

WindEurope

* 3 Contact person:

Vasiliki Klonari

* 4 Contact person's email address:

vasiliki.klonari@windeurope.org

* 5 Country of the stakeholder's headquarters or main country of operation:

Belgium

* 7 Type of the stakeholder:

Note: Please, choose the type of organisation that is the most accurate description of the stakeholder
Generator (including association)
Consumer (including association)
Transmission system operator (including association)
Distribution system operator (including association)
Academia/research institution
Other (please, elaborate)

8 Please, elaborate on your answer above, if necessary:

* 9 What is the impact of the NC RfG or NC DC legal requirements on your organisation?

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 Direct impact (provisions are applicable to my organisation)
Possible direct impact (e.g., applicability in the foreseeable future)
Indirect impact (e.g., provisions apply to my contractors)
No relevant impact
I do not want to specify the impact
Other (please, elaborate)

10 Please, elaborate on your answer above, if necessary:

Direct impact on WindEurope's members

* 11 Do you consent to the publication of the stakeholder's name?

Yes
No

* 12 Do you consent to the publication of provided answers?

Yes
No (please, note that your answer, without your name and organization, may be shared with the EU
institutions and national authorities, drafting team members, and other persons or entities involved in the
adoption process of the consulted Policy Paper)

14 Knowing that the exact proposals for amendments will be sought during the public consultation starting in
September, please, provide your general comments or views on this Policy Paper, if any:

The Policy Paper suggests many important additional areas that need to be developed and integrated in the
current NC RfG and NC DCC. However, experience and lessons learnt from the development and national
implementation of the NCs in the past years has shown that several improvements are required to facilitate
grid integration and make it cost-effective and several gaps need to be addressed in core areas that are
already covered by the current version of the NCs. The Policy Paper is very weak when it comes to
recommendations on how to improve these core areas with the upcoming revision. Our reply to question 16
lists items that should not miss of the opportunity of this revision.

Moreover, the paper misses a clear introductory notice on the process that will be followed for the
consideration of the outcomes of already completed and ongoing Expert Groups: which ones will be
considered in the revision, when, which will not make it for this revision round and why. This should be
clarified and presented concretely in the paper together with a short overview/update on the progress and
objectives of each Expert Group. Several experts, companies (including TSOs and DSOs) and associations
are dedicating significant resources in these activities with the hope of creating immediate positive impact on
integration requirements for their assets and this must be acknowledged and their work must be seriously
considered in the revision process.

* 15 Is there any area that you consider important but has not been covered by this Policy Paper?
Yes
No
Other

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 16 Please, elaborate on your answer above, if necessary:

(1) After the release of NC RfG and DCC in 2016, national connection rules have been adapted and
established the non-exhaustive requirements at national level which led to large variety of requirements
across the EU. Lessons learned from this implementation must be considered and a mindful minimisation of
non-exhaustive requirements must be driven. Definitions of non-exhaustive requirements need to be aligned
across the EU at an adequate level of detail. This will be crucial for a better level playing field in the EU and
will drive significant benefits for consumers.
(2) The revision should investigate NC improvements and seek for stakeholder suggestions on how to
harmonise and simplify certification procedures. An Expert Group has been ongoing (Harmonization of
Product Family Grouping and Acceptance of Equipment Certificates in European Level - EG HCF) since the
beginning of 2022, will its recommendations be considered?
(3) The revision should consider and clarify the role of international standards (mainly CENELEC and IEC) in
the NC development and implementation. Gaps between NC requirements and standards are growing (e.g.
voltage range requirement as per NC RfG and relevant equipment standards) and several definitions
missing in the current NCs could be covered by the ones already suggested in international standards.
ENTSO-E and the standardisation bodies have made serious efforts to bring their work together but it seems
that a more targeted effort is needed to improve the NC requirements.
(4) A good example is the grid compliance process and its link to IECRE. Member States introduce country
specific grid compliance certification requirements which makes it extremely complex and costly for
technology suppliers and asset owners (with a direct impact on grid integration costs for consumers) to
monitor and assess these requirements, perform relevant tests and simulations and certify according to
varying requirements. IECRE and the work of WG010 should serve as a baseline.
(5) Another crucial point is the need for the updated NCs to clarify requirements and procedures in assets
where different facilities/technologies share the same grid connection. The recommendations in the Policy
Paper about Mixed Customer Sites and Storage do not seem to address combined renewables power plants
with or without storage or renewables co-located with storage. Requirements for renewables sharing the
same grid connection with storage (where storage is not connected only for self-consumption but as an
autonomous unit directly supplying power to the grid) must be explicitly described in the NC. This should
include the co-location of renewables with short- and long-term storage, EV charging stations, large heat
pumps and of course electrolysers. Both new combined assets and existing assets being hybridised must be
covered.
(6) Ancillary services must be addressed also from the grid compliance point of view. Details provided in
question 33.
(7) Advanced capabilities/grid forming. Details provided in question 33.
(8) The EG CROS has identified the need for NCs to assess system tolerance on (active, reactive) power
oscillations caused by DC connected systems. This issue might be even more relevant in the case of AC
connected system and should be considered in the revision.

* 17 To what extent do you agree with the policy analysis and recommendations on the requirements for pump-
storage hydro PGMs:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

18 Please, elaborate on your answer above, if necessary:

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 Amendment of the existing rules shall address identified disproportions between technical requirements and
actual PGMs’ effect on the overall system while ensuring its stable operation. Moreover, potential changes
shall be linked with the appropriate transitory rules.

* 19 To what extent do you agree with the policy analysis and recommendations on the determination of
significance of PGMs:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

20 Please, elaborate on your answer above, if necessary:

Amendment of the existing rules shall address identified disproportions between technical requirements and
actual PGMs’ effect on the overall system while ensuring its stable operation. Moreover, potential changes
shall be linked with the appropriate transitory rules.

* 21 To what extent do you agree with the policy analysis and recommendations on the technical requirements for
mixed customer sites with generation, demand and storage:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

22 Please, elaborate on your answer above, if necessary:

A possible amendment of the NC RfG shall consider:

a) Relevant features of the MSCs, including properties of installed units, operating modes, provided services
and topology;
b) Proper balance between the requirements for the connection of the MCSs and the system needs as well
as the impact on the implementation of the NC RfG and the NC DCC in the different Member States;
c) Examination of the reference to connection point, considering situation when MCS is connected to CDS;
d) Possible application of voltage criteria only above specific maximum capacity threshold
e) Alignment of respective requirements both in NC RfG and NC DCC

* 23 To what extent do you agree with the policy analysis and recommendations on the requirements for type A
PGMs:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

24 Please, elaborate on your answer above, if necessary:

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 A harmonisation of thresholds between type A and type B PGMs across the EU should be assessed,
considering power system needs, to increase the cost-effectiveness of grid integration by standardising
requirements for the capabilities of different technologies and enable technology manufacturers to optimise
their production and list of technologies. In addition, with the ramp-up of renewable generation and the
fulfilment of expanded requirements, such as FRT capability, system security should be further enhanced.

* 25 To what extent do you agree with the policy analysis and recommendations on the significant modernisation:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

26 Please, elaborate on your answer above, if necessary:

Further assessment and clarifications are needed to define, in a harmonised manner across the EU, the
criteria for “significant modernisation”.
These criteria should list the ranges of modification of the relevant technical characteristics which could be
considered as significant modernisations and the minimum requirements of the GC NCs which should apply
in these cases. The exact modification criteria and the requirements of the GC NCs applying in the case of
significant modernisation will have to be defined at national level in the same way as the requirements of
general application.
The hybridisation of assets (addition of another generation technology or storage) should also be considered
when setting such criteria.

* 27 To what extent do you agree with the policy analysis and recommendations on the technical requirements for
storage:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

28 Please, elaborate on your answer above, if necessary:

The requirements should consider both short- and long-term storage and also the colocation of storage with
renewables. Requirements for assets combining renewables and storage should not only consider cases
where the storage unit is only integrated for self-consumption in the generation facility but also assets where
both generation and storage (sharing the same grid access point) can both supply power to the grid
independently. Requirements should also address cases of integration of storage in existing generation (or
demand) facilities and not only stand-alone storage units or completely new assets. Requirements should
also differentiate between synchronous and asynchronous units. Certain forms of electricity storage devices
may be exempted from the requirements (e.g., synchronous flywheels, synchronous compensators,
regenerative braking systems, batteries used for internal services, etc.) without prejudice to the Member
States’ right to establish specific requirements at national level.

* 29 To what extent do you agree with the policy analysis and recommendations on the electromobility:

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 5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

30 Please, elaborate on your answer above, if necessary:

It is important to differentiate requirements between V1G and V2G charging points and align requirements
for V2G with the upcoming ones for storage. It is recommended that the technical requirements are set at
the connection point of the EV charging station. However, the scope of application of GC NCs should not be
extended to the EVs and their on-board devices unless their on-board V2G bidirectional converter is used to
inject power into public grids and their maximum exporting capacity is equal or above 0,8 kW or the
concerned EV (either equipped with V1G or V2G technology) is to provide demand response services. Also,
the electrical charging facility owners shall have the right to choose the EV or equivalent technology to
employ for compliance testing.
Modalities of EV charging stations with regard the employment of the on-site technologies (stationary
batteries, V1G and/or V2G) will need to be reflected in the application of the GC NCs. For example,
distribution connected V1G electrical charging parks, not providing demand response services to system
operators, should not need to be compliant with the respective requirements.

* 31 To what extent do you agree with the policy analysis and recommendations on the simulation models and
compliance monitoring:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

32 Please, elaborate on your answer above, if necessary:

Possible amendment of the NC RfG and NC DC could introduce common requirements for simulation
models requested by system operators, considering the confidentiality and encrypted level (including cross-
border network stability studies), validation of the models, and future maintenance if needed. The outcomes
of the EG Interaction Studies and Simulation Models should be considered including the recommendations
for the simplification and cost-effectiveness of the validation methods (which are included in the report of the
EG but not mentioned in the Policy Paper).

* 33 To what extent do you agree with the policy analysis and recommendations on the advanced capabilities for
grids with high penetration of DER:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

34 Please, elaborate on your answer above, if necessary:

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 Full support is given to any initiative for making distribution systems smarter and utilising the assets more
efficiently. Moving to a smarter approach seems the more efficient solution in the long term. Some
investments are needed at the beginning to install new intelligent and control devices, but in the long term
the benefits in terms of flexibility and less costly infrastructures would overcome the initial costs.
We expect that is development also demands updates on the regulatory regime and the introduction of
specific ancillary services for distribution systems. Ancillary services are not just a matter of system
operation requirements, contracting options with the system operator and market design but need to be
addressed also from the grid compliance point of view. The large variety of terms, definitions and units used
to describe the different capabilities of grid connected assets (normally covered by the NC RfG) and the lack
of common definitions of non-exhaustive requirements makes it impossible to establish an EU framework for
scaling up ancillary services. The Grid Connection Codes need to define to an adequate level of detail
capabilities and which are mandatory (which will necessarily clarify which are non-mandatory and should be
remunerated) in a common way across the EU so that this basis can afterwards be used by other regulatory
items for designing all market and remuneration related aspects. This applies not only for “advanced
capabilities” but also for all other core capabilities such as voltage control which are today required and
addressed in a large variety of ways by the different NRAs and System Operators. Certification for grid
compliance should result in certification to participate in ancillary services market, avoiding redundant
certification processes and not justified discrimination of technologies.

Specifically about advanced capabilities including grid forming: before defining such advanced capabilities
and integrating any relevant requirements in a revised NC, it is crucial to create a common basis for terms
and definitions of capabilities, whether advanced or not, across the EU, going to the necessary level of
detail. Considering the progress of work in the specific EG, this will most probably not be possible for the
foreseen timeline of the revision. Moreover, as agreed in the EG, defining advanced capabilities requires a
clear identification of respective power system needs that can only be achieved with a very active
engagement and coordination of the work by several TSOs and DSOs which is currently not the case in the
specific EG. Therefore, we agree that there is a major benefit in defining such advanced capabilities in the
NCs but this requires some important steps before which are not yet on track.

* 35 To what extent do you agree with the policy analysis and recommendations on the requirements for weather
hazards resilience of generators:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

36 Please, elaborate on your answer above, if necessary:

Proportionate requirements could deliver enhanced system resilience to unusual weather events capable of
compromising generation at a reasonable cost. The probability of risks and cost-effectiveness of the adopted
measures shall be analysed based on the experience of interested parties and available historical records or
performance studies.

* 37 To what extent do you agree with the policy analysis and recommendations on the technical requirements for
active customers/energy communities:
5 (strongly agree)
4 (agree)

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 3 (neutral)
2 (disagree)
1 (strongly disagree)

38 Please, elaborate on your answer above, if necessary:

All resources shall comply with the NC RfG or NC DC or both according to their own nature. Active
customers and mixed customers sites are equivalent and thus the same rules and requirements should
apply. Members within energy communities should comply with the requirements of the Grid Connection
NCs at their point of common coupling with the grid as all other resources.

* 39 To what extent do you agree with the policy analysis and recommendations on the requirements for units
providing demand response services:
5 (strongly agree)
4 (agree)
3 (neutral)
2 (disagree)
1 (strongly disagree)

40 Please, elaborate on your answer above, if necessary:

The review of NC DC technical requirements for units providing DR services shall not hinder their effective
and non-discriminatory participation in DSO local ancillary services markets. Both the System Operation
Guidelines and the Demand Connection code could be potentially problematic as: 1) they might require for
units providing demand response services to demonstrate that all of their equipment will be able to tolerate
certain system variations (e.g. frequency variations). The problem is that:
▪ The ability to withstand changes in the network would be really difficult if not altogether impossible to
demonstrate for clients that do not have brand new assets and equipment.
▪ These stringent requirements are imposed only when grid users decide to provide flexibility services to the
grid.
As such, we ask for general connection rules that are feasible to implement and most importantly, that are
equally applied to everyone and not just on those that provide DR services.
Another issue is the definition of significant grid users that is present in the System Operation Guidelines,
that might come up in the Demand Connection code: those grid users who have a strong influence on the
transmission system (e.g. big sites) are required to provide real-time telemetry, forecasts, and other granular
data so as to allow the system operators to correctly estimate and take into account their impact on the grid.
The problem is that these requirements are imposed automatically on DR providers, regardless of their size
and impact on the network: in fact, Article 2(d) of SOGL states that significant grid users are “existing and
new demand facilities … if they provide demand response directly to the TSO in accordance with the criteria
in Article 27 of the Demand Connection Code”, which effectively captures most DR.
For this reason, the definition of “significant grid usage” should be reviewed so as to apply only to those grid
users actually big enough to strongly impact the grid and we should avoid a possible uptake and application
of the definition so worded also in the Demand Connection Code
Vestas

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