Comments of European engineering industries on ENTSO-E draft Demand Connection Code (DCC)

The European Engineering Industries represented by Orgalime support the development of a Demand Connection Code and agree that grid stability/system security is essential and should be the key objective of grid codes elaborated by ENTSO-E, as this represents an indispensable prerequisite for manufacturing operations in Europe.

In particular, our industries fully agree that continuity of the service and quality of the service of the power system is a crucial issue, including for the participation of demand side resources in the future European power system.
However, the draft DCC, and in particular the current approach to “Demand Side Response Delivering System Frequency Control”, raises Orgalime’s concerns, as it:

1. At the least undermines the core concept of a consumer oriented European energy system

2. Suggests a centralised, mandatory shut on/off for appliances and no opt out possibility for the end-user

3. Suggests a business case without rewarding the end-user for the service that he is offering to the grids, and therefore does not recognise the positive contribution that devices provide to load shifting, and

4. Thereby, in our view, risks going beyond the given mandate in the ACER framework guidelines on electricity grid connections of 20 July 2011 and the EC mandate letter of 5 January 2012.