Laura Degallaix Federica Sabbati Dr. James Watson Dr. Fiona
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Laura Degallaix Federica Sabbati Dr. James Watson Dr. Fiona
Brussels, 27 April 2015 Subject: Addressing remaining concerns regarding the derogation procedure for a group of Type A generating facility owners Dear Member of the Electricity Cross-Border Committee, The organisations co-signing this letter1 have been involved in the Network Code on Requirements for all Generators (NC RfG) legislative process, advocating for a balanced code that ensures grid stability, while taking into account the diversity of generators, their ability to adapt to the new grid code requirements and the shift in the energy markets towards more distributed generation and a higher focus on small-scale consumers. While recognising that the amendment introduced in Article 61 of the latest NC RfG draft from 10 April (specifying that for Type A generating facilities, derogation requests can be made by third parties) is a step in the right direction, we believe that this provision deserves further clarification. We specifically request that the NC RfG derogation procedure takes into account the capabilities of micro- and small-scale generator owners (lower range of the Type A) as well as how those appliances (series produced and normally installed at household or SME level) are brought to the market. Considering that a) standardised and series-produced micro- and small-scale generators are sold via sales and installer networks, b) that their commissioning can be very quick, and c) the benefit of having a workable solution for manufacturers with a view to further supporting the internal market, the NC RfG should additionally clarify that a third party can apply for derogation on behalf of a group of series-produced Type A generating facilities. This will ensure that the decision to derogate on some of the NC RfG provisions for Type A series-produced generating units is granted or declined before the product is even sold to the customer, for a proportionate, easy-to-implement and nondiscriminatory derogation procedure. ECOS, EHI, EPIA and COGEN Europe acknowledge that the amendment to Article 61 in the latest version of the NC RfG addresses to some extent concerns regarding limited or restricted access to request derogation for Type A generator owners. Nevertheless, the organisations co-signing this letter ask you to clarify that third parties can apply for derogation on behalf of a group/class of Type A generating facility owners, to ensure free and non-discriminatory access to the derogation procedure for small and micro-generator owners. Yours faithfully, Laura Degallaix Federica Sabbati Dr. James Watson Dr. Fiona Riddoch Director ECOS Secretary General EHI CEO EPIA Managing Director COGEN Europe 1 ECOS (European Environmental Citizens’ Organisation for Standardisation), EHI (European Heating Industry Association), EPIA (European Photovoltaic Industry Association) and COGEN Europe (European Association for the Promotion of Cogeneration)