Eurelectric response to ENTSO-E amendment proposal to aFRR/mFRR Implementation Frameworks, includingCommon Harmonisation Proposal

Eurelectric welcomes the opportunity to comment on ENTSO-E’s proposed Common Harmonisation Proposal for aFRR and mFRR Implementation Frameworks.

The harmonisation of prequalification processes for RPUs/RPGs grows ever more important as the European integration of balancing markets advances. While the present proposal contains noteworthy improvements, we believe that further opportunities for alignment going beyond a common process architecture and prequalification timelines need to be investigated.

We are therefore concerned by ENTSO-E’s proposal to move from yearly to triannual harmonisation surveys. In general, Eurelectric considers that further efforts toward a level playing field are needed and the yearly frequency for harmonisation surveys should thus be kept.

In addition, ENTSO-E should conduct a comparative assessment of prequalification practices, as well as ex-post verification across Europe. This assessment shouldidentifycurrent best practices for BSP prequalification, assessing options to harmonise technical requirements for RPUs/RPGs.

English language provisions: we welcome the publication of a non-binding English version of national T&Cs and would welcome additional standardised information about national balancing markets. When it comes to consultations and BSP-TSO communications, the national language should remain the main language.
- FRR prequalification timelines: Eurelectric needs further information about the rationale for proposed timelines. In the long term, harmonisation proposals should align with best practices.
- BSP switching:we support conditions for RPU/RPG switching between BSPs in a given LFC Area.
- RPU/RPG suspension: re-prequalification of RPUs/RPGs should only be required in case of repeated failures to deliver the contracted balancing service.
- IT harmonisation: wesupport the long-term convergence of exchange standards and communication protocols. TSOs should remain able to use already implemented standards if they remain fit for purpose.

About Eurelectric