Revision of the Network Code on Requirements for Grid Connection of Generators

117 submissions in the snapshot (111 from organisations), portal total 117. Feedback list on the portal.

111 of 111 organisation submissions analysed; the model reads them as: opposes 1 supports 18 wants changes 60 32 held back for review (low confidence).

• Micro company, AUT Academic or research institution, AUT model reads as: wants changes source
  • The Commission should establish a graduated intervention ladder for distribution-level stress rather than relying solely on mandatory control.

    The submission asks the Commission to recognise a graduated intervention ladder: (1) DSO-originated network-state signals with voluntary reaction, confined to the slow outer loop; (2) negotiated, CBA-justified flexibility linked to the Article 4546 methodology; and (3) mandatory control retained unchanged as the backstop.

  • Mandatory control actions should be prioritized from least to most disruptive and protection thresholds diversified across units.

    Within the control tier, actions should be ordered from least to most destructive reactive/cos φ adjustment before curtailment before disconnection and protection thresholds diversified across the population to avoid the correlated tripping identified by the Iberian Expert Panel.

• Kiwa Primara Company, DEU model reads as: wants changes source
  • Compliance demonstration for Type A modules should be simplified to equipment certificates and installation documents.

    For Type A, compliance should be demonstrable exclusively via a manufacturer's equipment certificate and installation document at unit/type level; a power-generating module document or site-specific testing should not be required.

  • ENTSO-E should be mandated to prepare harmonised compliance testing and simulation methodologies in parallel with the Regulation.

    ENTSO-E should be mandated (Art. 22) to develop harmonised compliance tests, simulation methodologies and performance criteria, in parallel with the Regulation and applicable no later than the requirements themselves;

  • Mutual recognition of accredited equipment certificates and compliance tests must be made legally binding across Member States.

    We propose (Recital 25 / Art. 50): system operators, certification bodies and Member States shall accept equipment certificates and compliance tests performed by EN ISO/IEC 17065 / ISO/IEC 17025 accredited bodies in any Member State, without national re-certification; deviations only for duly justified, published, site-specific requirements.

• Doosan Skoda Power a.s. Company, CZE model reads as: wants changes source
  • The response time limit for steam turbine units should be agreed in connection agreements rather than set explicitly in the regulation.

    The limit should not be set explicitly in this document but it should be rather mutually agreed in the connection agreement with the system operator.

  • The simulation methodology for low-voltage ride-through needs explicit clarification regarding fault application and voltage recovery.

    We are missing the definition of the way the LVRT simulation should be performed.

  • The default inner envelope shape in Figure 14 should be adjusted to reflect realistic synchronous generator capabilities.

    Please note that the default position of the inner envelope is significantly misplaced towards laggin reactive power, which is not realistic for any synchronous generator unit.

• legrand Company, FRA; register: Companies & groups model reads as: wants changes source
  • The regulation must differentiate between bidirectional AC and DC charging stations.

    we believe it is necessary to distinguish between bidirectional AC and DC charging stations:

    machine translation by the Commission, original in FR
  • The intermediate electrical infrastructure should ensure compliance by monitoring current and disconnecting non-compliant AC feed-in.

    It is therefore necessary for the electrical infrastructure (located between the vehicle and the grid connection point) to ensure compliance. This is achieved by measuring the currents fed into the grid by the vehicle and cutting off this feed when it is no longer compliant.

    machine translation by the Commission, original in FR
  • The text should remain technology-neutral by regulating the measurement and cut-off function rather than specific EVSE equipment.

    It is therefore important to amend the document accordingly that it remains technology neutral

    machine translation by the Commission, original in FR
• Ministry for the Ecological Transition and the Demographic Transition Public authority, ESP model reads as: wants changes source
  • The governance model should maintain the decision-making role of Member States in approving and implementing requirements.

    We do not agree with the governance model, according to which the Member States play an irrelevant role in the process of approving and implementing requirements.

    machine translation by the Commission, original in ES
  • Title V should be amended to retain the option for TSOs to seek national-level derogations.

    Amendment of Title V Derogations is requested to provide for the possibility for the TSO to request derogations at national level.

    machine translation by the Commission, original in ES
  • The voltage criterion for classifying generating modules should be reinstated alongside capacity.

    It is particularly relevant in pooled networks (shared evacuation infrastructure), which are very present in the Spanish electricity system. It is therefore proposed to restore the stress criterion.

    machine translation by the Commission, original in ES
• Charging Interface Initiative (CharIN) e.V. Business association, DEU; register: Trade and business associations model reads as: supports source
• Micro company, FIN Business association, FIN model reads as: wants changes source
  • Consider the appropriateness of real-time manoeuvrability requirements for equipment.

    We call for consideration to be given to the appropriateness of these real-time manoeuvrability requirements.

    machine translation by the Commission, original in FI
  • Allow in-equipment parameters set via the embedded OCPP protocol to serve as an alternative to real-time control by the grid operator.

    As an alternative to real-time control by the grid operator, the in-equipment parameters set via the OCPP protocol embedded in the charging devices, which already control the operation of the devices, can serve as an alternative.

    machine translation by the Commission, original in FI
• Asociación de empresas de energía eléctrica (aelēc) Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Mandatory retrofitting under Article 45 should only be applied as an exceptional last resort when market-based options cannot meet system needs.

    Mandatory retrofitting should be a "subsidiary and exceptional" measure of last resort, used only if market-based alternatives cannot meet system needs.

  • Grid forming capabilities should be justified by cost-benefit analysis rather than imposed as a default mandate across all Type C and D units.

    Grid Forming capabilities should not be a default requirement for all Type C and D units. Instead, they should be justified by a transparent cost-benefit analysis (CBA) and defined jointly by TSOs and DSOs.

  • Enforce mandatory compliance only after all necessary technical parameters, testing criteria, and compliance schemes are fully approved and operational.

    There is a need for "regulatory symmetry": mandatory compliance should only be enforced once all necessary technical parameters, testing criteria, and compliance schemes are fully approved and operational.

• WindEurope Business association, BEL model reads as: wants changes source
  • Require inertia or energy beyond inherent capability only when a system need is proven, ensuring remuneration through market or system-service mechanisms.

    Requirements for inertia or energy beyond inherent capability should apply only where the system operator has demonstrated a system need, and should be met through the most efficient system-level solution rather than imposed broadly on all Type C and D power park modules (PPMs).

  • Anchor the applicability of the new network code to a final and binding contract to protect committed projects.

    Applicability of new NC RfG must be anchored to a final and binding contract, so that already committed projects are not captured in new rules in case of unexpected delays.

  • Base the classification of co-located technologies on export capacity in the connection agreement rather than sum of installed capacities.

    That said, classification should be based on export capacity in the connection agreement rather than the sum of installed capacities behind the connection point, supported by harmonised guidance on Pmax.

• Micro company, BEL Consumer organisation, BEL model reads as: supports source
  • Enact a swift entry into force of the revised network code to enable a robust energy system through harmonised requirements.

    IFIEC Europe in general most strongly supports a swift entry into force of RfG 2.0 (to be followed by DCC 2.0 and NC DR), in order to allow a robust energy system at the lowest possible costs through harmonization of requirements.

  • Approve the adapted Requirements for Generators Network Code including electricity storage within its scope.

    IFIEC Europe would like to indicate the importance of the long-awaited approval of an adapted Requirements for Generators Network Code, in particular because of the inclusion of storage into the scope of the network code, which should allow for better harmonization across Member States, which could and should lead to economies of scale and thus overall system cost reductions.

• Equinor Company, NOR model reads as: wants changes source
  • Adopt a phased approach to mandatory grid-forming requirements.

    We encourage policymakers to adopt a phased approach to grid-forming requirements, clarify the definition of significant modernisation, establish realistic oscillation limits for wind generation, provide a clear framework for hybrid power plants and other assets sharing the connection points, and ensure compliance obligations remain practical and harmonised across Member States.

  • Ensure compliance requirements remain technically achievable, proportionate, and economically justified.

    At the same time, we call policymakers to ensure compliance requirements remain technically achievable, proportionate, and economically justified.

• Iberdrola S.A. Company, ESP; register: Companies & groups model reads as: wants changes source
  • Reinforce the independent oversight role of ACER alongside ENTSO-E and the EU DSO Entity to limit divergent national implementation.

    Reinforcing the oversight role already assigned to ACER, working with ENTSO-E and the EU DSO Entity, would reduce this risk without displacing the legitimate role of national operators and regulators.

  • Subject new technical requirements to demonstrated necessity, proportionality, and the Energy Efficiency First principle.

    Relatedly, Iberdrola asks that any new technical requirement, whether set at EU or national level, be subject to demonstrated necessity, proportionality and the Energy Efficiency First principle, and that a clear line be drawn between capabilities properly forming part of a connection requirement and those that amount, in substance, to a continuous system service.

  • Rely on competitive market mechanisms rather than unremunerated connection requirements for system services.

    Where the latter applies, allocation and remuneration should rest with competitive, technology-neutral market mechanisms (out of this Network Code) rather than an unremunerated connection obligation, with direct implications for cross-border competition and the internal market.

• Agora Think Tanks NGO, BEL model reads as: wants changes source
  • Extend the roadmap and needs-assessment mechanism to Type C and D power park modules before imposing grid forming obligations.

    We recommend extending the Article 29(1) to (2) roadmap and needs-assessment mechanism to Type C and D modules, and to the Type B category connected at higher voltage levels currently carved out under Article 30(3).

  • Ensure mandatory energy storage beyond inherent module capability is justified by cost-benefit analysis and eligible for market remuneration.

    Where energy storage beyond a module's inherent storage capability is required under Article 31(4)(b), this should be subject to cost-benefit justification and eligible for market-based remuneration, since Article 9 provides no cost-recovery route for such capability when imposed directly on the power-generating facility owner.

  • Make fast fault current and dynamic voltage support mandatory for Type B, C, and D modules independent of grid forming obligations.

    we recommend making fast fault current and dynamic voltage support mandatory requirements for all power park modules of Type B, C, and D, independent of any grid forming obligation.

• Terna S.p.A Company, ITA model reads as: wants changes source
  • Extend implementation timelines for national rules and compliance framework definitions to accommodate necessary stakeholder coordination.

    extend timelines for national implementation of the new regulation, for the definition of compliance schemes considering the necessary coordination among different stakeholders;

  • Allow TSOs and DSOs flexibility to establish differentiated requirements based on documented network security justifications.

    preserve an appropriate balance between European harmonisation and national flexibility ensuring that TSOs and DSOs can define different requirements where justified by documented network security needs and subject to regulatory approval;

  • Ensure complete observability and controllability of all network-connected resources to support secure grid operation.

    guarantee the observability and controllability of all the resources connected to the network and their respective injection profiles to allow a secure system operation by TSOs especially in times of more frequent overgeneration phenomena;

• Svenska Kraftnät Company, SWE model reads as: wants changes source
  • Retain separate thresholds for determining type C and D power-generating modules between the Continental Europe and Nordic synchronous areas at 10 MW and 30 MW.

    Svenska kraftnät promotes keeping thresholds for determining type C and D separate between the CE and Nordic synchronous areas; the thresholds should remain as they are i.e. 10 MW for type C and 30 MW for type D in the Nordic synchronous area.

  • Implement ACER draft text from NC HVDC concerning island applications and synthetic inertia requirements.

    Svenska kraftnät promotes some writing from ACER drafts on NC HVDC be implemented, e.g. application on islands and returning synthetic inertia requirements to GFL PPM (see ACER 2023 draft NC HVDC articles 7(b) and 14, respectively).

  • Align the wording of Article 50(2) on compliance testing with Article 51(2).

    Regarding article 50(2); the word minimum has been removed from the original RfG 1.0 phrasing on compliance testing. SVK promotes phrasing article 50(2) using the same wording as in 51(2).

• Izba Energetyki Przemysłowej i Odbiorców Energii NGO, POL; register: Trade and business associations model reads as: wants changes source
  • Introduce a provision requiring the development of a national allocation mechanism to transfer compliance tasks from small DSOs to regular DSOs.

    1) the introduction into the New NC RfG of a provision requiring the TSO and all DSOs, where both small DSOs and regular DSOs operate in a Member State, to develop a proposal for national TCM, setting out the allocation of tasks or obligations of the RSOs arising from the New NC RfG from small DSOs to regular DSOs, subject to approval by the NRA; the same TCM should establish the procedures for TSO DSO coordination when developing and updating the national compliance scheme, and for the other national TSO DSO coordination processes identified in the New NC RfG;

  • Enable the national regulatory authority to decide on individual assignments of system operator tasks to another operator.

    2) individual assignment of task or obligations of the RSOs by the NRA individual system operator could apply to the NRA for a decision specifying which obligations entrusted to it under the New NC RfG or, where applicable, pursuant to the TCM, would be performed by other RSO (e.g. regular DSO) and setting out the rules for cooperation between them in the performance of those obligations.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Exclude efficiency upgrades from the definition of significant modernisation.

    1. Efficiency upgrades should be excluded from "significant modernisation" definition

  • Ensure frequency stability requirements remain technically proportionate.

    2. Frequency stability requirements should remain technically proportionate

  • Adapt droop requirements to take into account steam cycle constraints.

    3. Droop requirements should account for steam cycle constraints

• Razom We Stand NGO, UKR; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Adapt EU grid connection rules to the rapid growth of decentralised renewables, storage and flexible generation.

    adapt EU grid connection rules to the rapid growth of decentralised renewables, storage and flexible generation.

• Ministry for Energy, the Environment and the Regeneration of the Grand Harbour Public authority, MLT model reads as: wants changes source
  • Make the first row in Table 3 bold to distinguish it as a title.

    In Table 3, it is suggested to distinguish the first row by making it bold , as conventionally done in other tables, to identify it as a title from the remaining other rows which are the data.

  • Consider changing the title of Article 18 to start with Limited frequency instead of Load frequency.

    We are not sure whether in Article 18 the title should start with the words Limited frequency instead of Load frequency

• APPA Renovables Business association, ESP model reads as: wants changes source
  • Refine the final text to ensure new technical capabilities deliver demonstrable system benefits without disproportionate costs or investment disincentives.

    That the observations below therefore focus on the areas in which APPA Renovables considers that the final text should be refined to ensure that new technical capabilities deliver a demonstrable system benefit without creating disproportionate costs, fragmented national implementation or disincentives to renewable investment and modernisation.

  • Ensure grid-forming requirements and significant modernisation do not force unnecessary redesign of facilities or create uncompensated connection obligations.

    In particular, grid-forming requirements and significant modernisation should not operate together in a manner that forces unnecessary redesign of entire facilities or turns system services requiring additional investment into uncompensated connection obligations.

• Danish Utility Regulator Public authority, DNK model reads as: wants changes source
  • Maintain the application of the entirety of Title IV of Regulation 2016/631 for existing PGMs and RSOs.

    DUR suggests that the entirety of 2016/631 Title IV continues to apply for RSOs and owners of PGMs for which the 2016/631 general requirements continue to apply.

  • Rephrase Article 18(2) to protect ESM batteries from being discharged too deeply.

    In light of this, DUR suggest that the article be rephrased as [] and until its energy reservoir is nominally depleted, which would respect the necessary protection of the ESM module.

  • Remove the reference to Article 18 from Article 22(1) and move ESM-specific requirements into an independent chapter.

    DUR recommends removing the reference to Article 18 from Article 22(1) and moving everything ESM-specific into its own chapter (DURs reasoning for this follows under Structure).

• Axpo Company, CHE; register: Companies & groups model reads as: wants changes source
  • Preserve the fundamental grandfathering principles and protect existing facilities from retroactive requirements.

    The fundamental grandfathering principles of the current NC RfG should be preserved. Existing generation facilities were designed, licensed, financed and connected to the network under a specific regulatory framework and should not be exposed to retroactive requirements except in clearly justified and exceptional circumstances.

  • Maintain a clear distinction between existing and new facilities so operators are not discouraged from maintenance and modernisation.

    The revised NC RfG should therefore maintain a clear distinction between existing and new facilities and ensure that operators are not discouraged from undertaking maintenance, refurbishment and modernization measures that contribute to security of supply and the energy transition.

  • Reconsider the specific articles highlighted in the attached submission document.

    Axpo therefore urges to reconsider the articles described in the attached pdf-document.

• Statkraft AS Company, NOR; register: Companies & groups model reads as: wants changes source
  • Preserve proportionality in the treatment of significant modernisation under Article 4.

    Preserve proportionality in the treatment of significant modernisation (Article 4)

  • Base grid-forming requirements under Articles 29-32 on demonstrated system needs.

    Apply grid-forming requirements based on demonstrated system needs (Articles 29-32)

  • Restrict new requirements from applying to existing assets and maintain appropriate transition rules.

    Restrict the application of new requirements to existing assets (Article 45)

• Amprion GmbH Company, DEU; register: Companies & groups model reads as: wants changes source
  • Require combined cycle power plants to show a robustness of 2 Hz/s over 0.5 s in the event of RoCoF.

    Therefore, even the latest combined cycle power plants must contribute to system resilience in the event of RoCoF by showing a robustness of 2 Hz/s over a period of 0.5 s.

  • Reconsider the relaxation of RoCoF requirements for type D SPGMs above 140 MW in Article 27(4).

    we would like to draw the attention to the reduced RoCoF requirements for type D SPGMs above 140 MW in article 27(4).

  • Take into account the general points and positions raised by ENTSO-E.

    Where we, as the four German TSOs, have not proposed any specific amendments or clarifications, we would like to refer in general to the points raised by ENTSO-E, which we support.

• GIMELEC Business association, FRA model reads as: wants changes source
  • Active islanding detection should be permitted across various architectural elements rather than restricted solely to the EVSE.

    The detection function may be implemented in the AC V2G EV, the AC V2G EVSE, the upstream electrical installation, or through a coordinated combination thereof, provided that compliance and interoperability are demonstrated through the applicable certification framework.

  • Article 6.2 requirements should be limited to reverse charging instead of direct charging.

    Art 6.2 requirement should not apply to direct charging but only to reverse charging.

• Enedis Company, FRA; register: Companies & groups model reads as: wants changes source
  • TSOs and DSOs should be involved on an equal footing to jointly develop proposals and implement RfG requirements.

    Involve TSOs & DSOs on equal footing to implement RfG at European level (amendments, guidance) & national level (CBA, specifications) to ensure TSO-DSO alignment for critical interface, issues on system security vs. safety of network operation, and optimal collective welfare.

  • Constructive equipment capabilities must be clearly distinguished from actual operating settings defined at national level.

    Clearly distinguish the constructive requirements of the equipment, homogeneous European wide for mass produced devices, ie the possible range of settings / configuration of the equipment, from the actual settings / configuration of the equipment, ie what is actually expected as a behavior to be defined in subsidiarity to take into account the protections schemes of DSOs & system needs.

  • The proposed high-voltage ride-through requirement for Type A generators must be removed.

    The proposed HVRT requirement for Type A (1.3 pu for 100 ms & 1.2 pu for 1 min) must be removed.

• nucleareurope Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The definition of significant modernisation should be limited to fundamental alterations of system behaviour.

    The definition of significant modernisation should be limited to changes that fundamentally alter the system behaviour of an installation.

  • A mandatory proportionality test must precede any retrofit requirement on existing generation assets.

    Before any retrofit obligation is imposed on an existing asset, the Regulation should require a robust proportionality test.

  • The cap on transmission charges for generators under Annex B to Regulation (EU) No 838/2010 should be maintained.

    nucleareurope strongly opposes the Commissions announced intention to delete Annex B to Regulation (EU) No 838/2010, which currently limits transmission charges for generators.

• EUGINE Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Efficiency improvements should be excluded from the scope of significant modernisation.

    Efficiency upgrades should be excluded from "significant modernisation" definition

  • Power system stabiliser requirements should be applied at the individual unit level.

    Power system stabiliser requirements should apply at unit level

  • Transitional provisions should safeguard projects currently under development.

    Transitional provisions should protect projects already under development

• Vattenfall AB Company, SWE; register: Companies & groups model reads as: wants changes source
  • Broad retroactive application to existing assets should be avoided by enabling proportionate approaches such as asset-class derogations.

    We consider it essential to preserve regulatory certainty for existing assets and avoid unintended consequences whereby routine modernisation activities or future cost-benefit assessments result in broad application of new requirements to existing facilities.

  • Implementation deadlines should be extended from 24 months to at least 36 months.

    Additionally, implementation should be extended from 24 months to at least 36 months.

  • Requirements for stability and storage should account for technological readiness.

    Technological readiness needs to be taken into account.

• Svaz energetiky ČR Business association, CZE; register: Trade unions and professional associations model reads as: wants changes source
  • Applicability of new requirements during the transition period should be based on the connection agreement date rather than physical connection.

    The decisive criterion should remain the date of conclusion of the connection agreement, as provided for in the current RfG.

    machine translation by the Commission, original in CS
  • Definitions of synchronous power generating modules and major upgrades should be clarified.

    The Czech Republic proposes that the definitions of synchronous power generating modules and major upgrades be clarified so that they are more in line with real-life technological configurations and do not allow for different interpretations.

    machine translation by the Commission, original in CS
  • A single 24-month deadline should be established for V2G requirements rather than a prolonged postponement.

    We do not agree with the proposed long postponement of the requirements for V2G vehicles and infrastructure and propose a single 24-month deadline.

    machine translation by the Commission, original in CS
• E.ON SE Company, DEU; register: Companies & groups model reads as: wants changes source
  • Establish a stronger and more explicit role for Distribution System Operators in the specification and implementation of requirements.

    Key priorities include a stronger and more explicit role for Distribution System Operators (DSOs) in the specification and implementation of requirements, reflecting the fact that most affected assets are connected to distribution networks.

  • Introduce grid-forming capability requirements for Type A installations only after assessing system benefits, feasibility, and affordability, keeping mandatory deployment needs-based.

    With respect to Grid-Forming capabilities, E.ON considers that requirements for Type A installations should only be introduced following a thorough assessment of system benefits, technical feasibility and affordability.

  • Adopt less stringent European ramp-rate values to avoid unintended protection trips.

    Finally, while E.ON supports the harmonization of ramp-rate requirements at European level, it recommends adopting less stringent ramp-rate values to avoid unintended protection trips and ensure robust system operation.

• Bundesverband Energiespeicher Systeme e. V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Ensure robust grandfathering and a narrow, practical definition of significant modernisation to protect existing assets.

    A more robust grandfathering and a narrow and practical definition of significant modernisation, protecting advanced projects and ensuring that modernisation of existing assets is not discouraged by disproportionate retrofit or compliance obligations.

  • Base grid-forming requirements on demonstrated system need and technology maturity, providing appropriate remuneration for additional burdens.

    Grid-forming requirements should follow demonstrated system need and technology maturity; where they require reserved capacity, SoC management or additional hardware, appropriate remuneration is needed; market-based procurement should remain the preferred approach for system services beyond minimum connection requirements.

  • Provide a sufficiently long transition phase of at least 36 months.

    A sufficiently long transition phase of at least 36 months.

• Technology Organization VDE Other, DEU; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Reinstate the 24-month deadline for national implementation in Article 7(6) of the NC RfG 2.0.

    Reinstate the 24-month deadline for national implementation in Article 7(6) of the NC RfG 2.0 to ensure a transparent, technically sound, and stakeholder-coordinated implementation.

  • Extend the transitional period under Article 62 to give stakeholders sufficient time to adapt.

    Extend the transitional period under Article 62 so that manufacturers, power-generating facility owners, and certification bodies can implement the requirements in a timely and appropriate manner.

• EDF Company, FRA model reads as: wants changes source
  • Maintain the explicit distinction between existing and new generation facilities with differentiated requirements.

    removing the explicit distinction between existing and new generation facilities (possibility of differentiated requirements)

  • Do not reopen agreements and technical compromises reached during the ACER process, such as RoCoF criteria.

    These agreements should not be reopened.

  • Make adjustments to the European Commission proposal before adoption.

    Therefore, some adjustments to the EC proposal appear necessary before the text is adopted

• UFE - French Union of Electricity Other, FRA model reads as: wants changes source
  • Clarify the applicable scope of the Regulation and define existing facilities criteria as the conclusion of a connection agreement.

    For the clarity of the text, the criteria should therefore be defined as the conclusion of a connection agreement.

  • Do not systematically impose grid-forming capabilities on all Type C and Type D power park modules.

    The obligation to provide grid forming capabilities should not be imposed systematically on all power park modules of Type C and Type D facilities.

  • Ensure the implementation timeline is realistic and consistent with industrial cycles and operational constraints.

    Ensure a realistic implementation timeline consistent with industrial cycles & operational constraints of TSO, DSOs, equipment manufacturers & project developers.

• vgbe Business association, DEU model reads as: wants changes source
  • Retain the explicit distinction between existing and new generation facilities and keep compromises reached in the ACER process.

    notably by removing the explicit distinction between existing and new generation facilities (and thus the possibility of differentiated requirements) and by not retaining some of the technical compromises reached during the process led by ACER.

  • Make adjustments to the European Commission's proposal prior to adoption.

    Some adjustments to the Commission's proposal therefore appear necessary before the text is adopted.

• SMA Solar Technology AG Company, DEU model reads as: wants changes source
  • Differentiate and simplify grid forming requirements between PV and electricity storage modules, mandating specific inertia provision only from ESM.

    Grid Forming Requirements have to be differentiated between PV and ESM and should be simplified

  • Limit the overvoltage Ride-Through capability for type A PPM to 1.25 p.u./100ms instead of 1.3 p.u./100ms.

    The overvoltage Ride-Through capability in Article 17 should be limited to 1,25 p.u./100ms (instead of 1,3 p.u./100ms) for type A PPM, since this capability is applied today in member states.

  • Ensure that extending a plant by adding PV does not mandate modernising existing installations under significant modernisation rules.

    Extending a Plant e.g. by adding a PV installation on another roof in a mixed customer site mustnt lead to a mandate on modernizing an existing installation (Article 4(3)).

• EPIA SolarPower Europe Business association, BEL model reads as: wants changes source
  • Broaden the definition of existing generating modules to encompass projects under development with binding equipment procurement contracts.

    Broaden the definition of existing generating modules to include projects under development that have concluded a final and binding main equipment procurement contract, rather than limiting the definition to already connected assets only (Article 45 and 55).

  • Narrow significant modernisation criteria so new requirements only apply to modernised, renewed, or added components.

    Narrow the criteria for triggering significant modernisation and ensure that any new requirements apply only to the modernised, renewed or newly added parts of an installation, avoiding disproportionate barriers to repowering, hybridisation, component replacement and asset upgrades (Article 4).

  • Limit remote-control obligations to emergency situations and last-resort measures at the connection point.

    Limit remote-control obligations to emergency situations and last-resort measures at the point of connection, ensuring system operators can specify required import or export behaviour but cannot directly control individual generating units, inverters or behind-the-meter assets (Articles 13 and 15).

• EU DSO Entity Business association, BEL model reads as: wants changes source
  • Require TSOs and DSOs to develop relevant requirements jointly rather than merely in coordination.

    Relevant requirements should, where appropriate, be developed jointly, rather than merely in coordination, ensuring system and local network security and safety are addressed in a balanced manner.

  • Retain class derogations to address unforeseen issues affecting mass-market equipment.

    Class derogations should be retained to address unforeseen issues, particularly for mass-market equipment, where potentially millions of assets could be affected and individual derogations would be impractical.

  • Replace the Technical Annex for EVs and Type A PGMs with European harmonised standards.

    Regarding Annex III and its proposed five-year lifetime, we support the development of European harmonised standards for EVs and, ideally, Type A PGMs, to replace the Technical Annex.

• Orlen Company, POL; register: Companies & groups model reads as: wants changes source
  • Protect investments that are already at an advanced stage of development.

    (1) protection of investments that are at an advanced stage of development;

  • Ensure requirements remain proportionate to the actual impact of each unit on the system.

    (2) proportionality of requirements to the actual impact of a unit on the system;

  • Protect existing and modernised assets against disproportionate obligations.

    (4) protection of existing and modernised assets against disproportionate obligations;

• Tesla Motors Netherlands B.V. Company, USA; register: Companies & groups model reads as: wants changes source
  • Lock in harmonisation and minimise national discretion across requirements.

    We call to lock that harmonization in, and close the gaps to limit national discretion to the minimum necessary.

  • Establish a single, fully harmonised technical specification for separate EV and EVSE certification.

    Separate EV and EVSE certification can only work if the requirements themselves form a single, fully harmonized technical specification.

  • Provide a clear pathway for lab-tested combinations to enter the market while full interoperability matures.

    In parallel, there must be a clear pathway for lab-tested combinations to enter the market while full interoperability matures.

• ASOCIACIÓN ESPAÑOLA DE ALMACENAMIENTO DE ENERGÍA - ASEALEN Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Ensure the framework provides a harmonised, proportionate, and technologically neutral implementation that protects existing investments and distinguishes connection capabilities from remunerated services.

    It is therefore essential that the new framework ensures harmonised, proportionate and technologically neutral European implementation; to protect investments already committed; and to clearly differentiate between the minimum technical capabilities required for connection and the additional services to be contracted and remunerated.

    machine translation by the Commission, original in ES
  • Adapt connection requirements originally designed for generators to account for the bidirectional operation and technical limits of storage.

    Furthermore, the bi-directional nature of storage requires adapting the requirements originally conceived for generating installations, considering their different modes of loading, unloading and transition, their power and energy limits and their state of charge.

    machine translation by the Commission, original in ES
  • Acknowledge the technological diversity of storage and assess facilities by delivered performance at the connection point rather than mandating specific architectures.

    The regulation should also recognise the technological diversity of storage and assess the facilities for the behaviour actually delivered at the connection point, without imposing specific architectures or technical solutions.

    machine translation by the Commission, original in ES
• COGEN Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Balance system benefits against individual installation burdens and account for technology-specific characteristics.

    Grid connection requirements must consider both the system benefits and the burden on individual installations (or technology classes), so that the impact on specific technologies is not disproportionate compared to the effects at system level.

  • Adopt and recognise European and international standards to harmonise requirements and compliance processes.

    European and international standards shall be adopted and recognised as part of NC RfG 2.0 to support the harmonization of requirements and compliance process.

  • Prioritise standardisation, proportionate rules for micro-CHP, realistic timelines, and regulatory clarity.

    COGEN Europe recommends that RfG 2.0 prioritise harmonisation through European standards, ensure proportionate treatment of emerging and small-scale technologies such as micro-CHP, provide realistic implementation timelines, and strengthen regulatory clarity to deliver a consistent, efficient and future-proof European grid connection framework.

• Micro company, GBR Company, GBR model reads as: wants changes source
  • Grid compliance enforcement should be anchored in isolated hardware rather than software-level controls.

    To protect European transmission and distribution systems, the execution layer must be anchored into bare-metal physics.

  • Process boundaries should be governed via an isolated hardware interposer to halt unauthorized bidirectional power transfers mechanically.

    Shifting process boundary governance completely off the host operating system down to an isolated PCIe hardware interposer mechanically halts unauthorized bidirectional power transfers at the exact millisecond of errant intent.

  • Compliance metrics should be locked into the hardware layer rather than using modifiable software documents.

    Instead of relying on modifiable software-vouched files like Supply Equipment Documents (SEDs) or Power-Generating Module Documents (PGMDs), our architecture locks compliance metrics into the hardware layer

• Micro company, IRL NGO, IRL model reads as: supports source
  • Grid connection planning should incorporate broader regional development objectives, especially in coastal areas hosting offshore infrastructure.

    As renewable energy deployment accelerates, grid connection planning should take account of wider regional development objectives, particularly in coastal areas that will host significant offshore renewable energy infrastructure.

  • Grid investment needs to bolster local resilience and support economic opportunities for coastal communities.

    Grid investment should support resilient local infrastructure and enable long-term economic opportunities for coastal communities alongside the delivery of Europe's climate objectives.

  • Network planning should be coordinated with maritime spatial planning and strategic port development.

    Coordination between electricity network planning, maritime spatial planning and strategic port development will become increasingly important as Europe's offshore energy system expands.

• CENELEC NGO, BEL model reads as: wants changes source
  • Technical modifications to the draft should be kept minimal now to prevent publication delays, postponing non-urgent items to a later revision.

    To avoid further delay of RfG publication these further need of modification should be addressed in a later version of RfG, but work should start immediately after publication of the current draft and technical modifications now should be kept to an absolute minimum.

  • The regulation should include a follow-up mechanism based on harmonised standards after the five-year expiry of the technical annex.

    Recital (27) describes the application of harmonised standards after of the technical annex is expired, unfortunately this is not reflected in the draft text of the network code. Following the intention of recital 27 CENELEC proposes the modifications as in the file attached.

• Unión Española Fotovoltaica (UNEF) Business association, ESP; register: Trade and business associations model reads as: wants changes source
• Redeia- Red Eléctrica Company, ESP; register: Companies & groups model reads as: supports source
  • Use the date of connection to the network as the determining criterion for applying revised requirements.

    Furthermore, using the date of connection to the network as the determining criterion for the applicability of revised requirements would provide clarity and regulatory certainty.

  • Maintain the voltage level criterion for categorising power generating modules to safeguard security of supply in private connection networks.

    In this respect, maintaining the voltage level criterion for the categorisation of Power Generating Modules (PGMs) is essential to ensure compatibility with security of supply in systems with private connection networks.

  • Condition the mutual recognition of equipment certificates on fully harmonised or exhaustive requirements.

    Finally, the mutual recognition of equipment certificates issued by authorised certifiers in Member States should be linked to fully harmonised requirements or exhaustive requirements.

• Green Power Denmark Business association, DNK model reads as: wants changes source
• ECOS Environmental organisation, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Base national compliance schemes for mass-market products as much as possible on harmonised standards.

    In order to ensure coherence in the EU Single Market, it is key that the national compliance schemes of these products are based as much as possible on harmonised standards or parts thereof.

  • Allow system operators to curtail grid elements such as grid connection points instead of only directing instructions to single units.

    In line with the comments by effiziente.st Energie- und Umelrconsulting e.U., ECOS recommends allowing solutions that lead to lower cost and lower system complexity for EV1, EV2 and Type A level units, instead of only allowing the binding operator instructions to single units (Art. 15(7), (11)(13); Art. 18(5)).

  • Add a recital prioritising robust autonomous reactions over real-time remote-control techniques for all generator unit types.

    In that context, ECOS recommends adding a recital to the draft prioritising robust autonomous reactions over real-time remote-control techniques for all types of generator units (including Type A, EV1 and EV2), in order to improve system resilience.

• Slovenské elektrárne, a.s. Company, SVK; register: Companies & groups model reads as: opposes source
  • Avoid regulatory revisions that create barriers for new facility connections or impose additional burdens on existing assets.

    The current proposal for the revision of the RfG Network Code creates additional barriers to the connection of new facilities while also imposing further requirements on existing facilities, which may undermine the economic viability of assets that are essential for a successful energy transition.

• EDP SA Company, PRT model reads as: wants changes source
  • Clarify explicitly that connection requirements are technical conditions rather than mandatory service provision obligations.

    As a key point, EDP calls for explicit clarification in this revision of the RfG, that requirements are technical conditions for grid connection, not obligations to provide services, which are governed by other EU legislation.

  • Establish clear and proportionate criteria for significant modifications that exclude standard maintenance and replacements.

    Criteria for significant modifications should be clear and proportional, excluding normal maintenance and replacements.

  • Implement grid forming and synthetic inertia requirements in an evidence-based and phased manner.

    Grid forming and synthetic inertia requirements must be phased and evidence-based, considering technical and economic impacts.

• Energy Storage Europe Business association, BEL model reads as: wants changes source
  • State explicitly in the final text that the new requirements apply only to newly built assets rather than retroactively.

    Energy Storage Europe would nonetheless recommend that this scope be stated explicitly and unambiguously in the final text, so that developers, financiers and asset owners can rely on it with full confidence rather than inferring it from the structure of the Regulation.

  • Adopt a consolidated approach across frequency and voltage provisions to ensure bidirectional storage is treated consistently.

    While the draft rightly establishes the principle that storage should meet the same requirements as generators in both operating states, this principle is not yet consistently reflected across the individual frequency and voltage provisions, and Energy Storage Europe believes a more consolidated approach is needed to avoid inconsistent interpretation and implementation across Member States.

• E-Mobility Europe Business association, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure type-test certification schemes for V2G-capable electric vehicles and EVSE are harmonised, mutually recognised, and interoperable.

    E-Mobility Europe supports the introduction of separate type-test certification for V2G-capable EVs and EVSEs under this Draft Regulation, provided that the respective certification schemes are fully harmonised, mutually recognised and interoperable across the EU.

  • Ensure mutual recognition across the EU for V2G EVSE product certifications rather than requiring separate national certifications.

    Certification issued in one Member State should be mutually recognised across the EU, ensuring a truly harmonised framework and preventing unnecessary administrative and market-access barriers.

• Micro company, ITA Company, ITA model reads as: supports source
  • Update the grid code to account for emerging developments such as renewables, e-mobility, and storage.

    This initiative will update and future-proof the grid code for grid connection of generators to further support the EU electricity grid, taking into account emerging developments such as increased deployment of renewables, e-mobility and battery and H2 storage as proposed in the annexed study EnergiaBeneComune.

    machine translation by the Commission, original in IT
• Ministry of Industry and Trade Public authority, CZE model reads as: wants changes source
  • Adopt targeted refinements to wording, clarify deadlines, and harmonise terminology across key provisions.

    Particular attention has been given to the definition of significant modernisation, the requirements for type A power-generating modules, electricity storage modules, and V2G technologies, where we propose targeted refinements to the wording, clarification of deadlines, and harmonisation of terminology, in order to ensure proportionality, transparency, and alignment with system operators' technological capabilities.

• European Network of Transmission System Operators for Electricity Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • System operators should retain authority over technical proposals, while designated entities should only approve or reject them without altering content.

    They shall therefore remain responsible for proposing technical requirements, characteristics as well as compliance schemes. Designated entities shall approve, or reject where appropriate, such proposals, but shall not themselves establish or modify the technical content.

  • Voltage-based classification should be reintroduced as an option for generating module categorisation.

    ENTSO-E therefore proposes to reintroduce voltage-based classification as an option for some types.

  • Fixed deadlines for retroactive application of requirements should be removed.

    the Regulation should remove fixed deadlines for identifying retroactive application of requirements.

• Asociación Empresarial Eólica Business association, ESP model reads as: wants changes source
  • Advanced stability and grid-forming capabilities should be procured through market mechanisms prior to imposing mandatory retrofits.

    Grid Forming capability, synthetic inertia, Fast Fault Current and advanced stability services should therefore be obtained primarily through appropriately designed service markets before considering mandatory retroactive obligations for existing facilities.

  • The Regulation should uphold technology neutrality by assessing delivered performance rather than specific architectures.

    Finally, the revised Regulation should explicitly reinforce the principle of technology neutrality by assessing compliance on the basis of delivered performance and system outcomes rather than through implicit preferences for particular technological solutions or implementation architectures.

  • Legitimate investment expectations and mature projects should be safeguarded.

    Protection of legitimate investment expectations and mature projects.

• Danish Energy Agency Public authority, DNK model reads as: wants changes source
  • Consider specific concerns and amendment proposals regarding the draft regulation.

    we would therefore appreciate, if you could take the concerns and specific proposals for amendments described in the attached document into account in your further work on the draft Regulation.

• APREN - Portuguese Renewable Energy Association Business association, PRT model reads as: wants changes source
  • Prioritise safe continuation of operation during disturbances and distinguish minimum connection capabilities from remunerated system services.

    It should also prioritise the safe continuation of operation during disturbances and a coordinated system response, rather than indiscriminate disconnection, and distinguish minimum connection capabilities from flexibility and system services that require contractual activation and remuneration.

  • Harmonise functional behaviour at Union level, rely on product certification for mass-market units, and protect committed investments.

    The revised RfG should harmonise functional behaviour at Union level, rely primarily on product certification for mass-market equipment, establish clear governance for remote instructions and protect investments already committed under the existing framework.

  • Reduce avoidable discretion in national implementation by using harmonised European methodologies subject to regulatory oversight.

    Requirements, parameters and verification arrangements that materially affect equipment design, project economics or connection timing should be based on harmonised European methodologies wherever possible, be subject to independent regulatory oversight and meaningful stakeholder consultation and be supported by an assessment of technical feasibility and cost impacts for manufacturers and facility owners.

19 more analysed submissions on the consultation page.