Response to Public Consultations

Strategy for Long-Term EU Greenhouse Gas Emissions Reductions

October 2018

EASE has submitted a response to the European Commission’s Public Consultation on the Strategy for Long-Term EU Greenhouse Gas Emissions Reductions.

Our members are fully supportive of the EU’s efforts to achieve a low-carbon economy, and we support ambitious greenhouse gas emissions reduction targets.

Energy storage deployment can facilitate the transition to a low-carbon energy system in many ways, e.g. by:

  • Enabling higher shares of RES in the energy mix
  • Supporting electrification of the heating, cooling, and transport sectors
  • Supporting the secure, cost-effective, and efficient operation of the grid by providing key services at all levels of the energy system
  • Extending the lifetime of existing grid assets
  • Allowing active consumers to optimise self-consumption or provision of services to the grid
  • Ensuring security of supply: avoiding PV and wind curtailment avoids importing fuel
  • Enabling a faster energy transition on islands and in isolated areas

We hope that the long-term EU greenhouse gas emissions reductions strategy will take into account the vital role of storage.

You can read EASE’s consultation reply here.

The Future of Energy Storage in the EU

September 2018

In the framework of the Electricity Coordination Group, which gathers electricity experts from each Member State, the European Commission launched an informal public consultation on the future of energy storage in the EU.

Read the full response to the public consultation here.

Establishment of the ETS Innovation Fund

April 2018

EASE submitted a response to the European Commission Public Consultation on the “Establishment of the ETS Innovation Fund”.

The EC legislative proposal for a revised EU emissions trading system (ETS) reform involves the creation of an ETS Innovation Fund (IF). This fund is meant to support low-carbon innovative technologies, including energy storage technologies, by allocating funds to demonstration projects or projects between TRLs 6-9. It will be financed through the earmarking of revenues from the sale ETS allowances.

The European Commission has published a public consultation on the design elements of the ETS Innovation Fund.

Given the importance of the funding that could be available to energy storage projects in the future, EASE drafted a reply to the public consultation.

Read the full response to the public consultation here.

All Continental European and Nordic TSOs’ Proposal for a Cost Benefit Analysis Methodology

February 2018

EASE submitted a response to the ENTSO-E Public Consultation on “All Continental European and Nordic TSOs’ proposal for a Cost Benefit Analysis methodology”.

Key messages:

EASE welcomes the efforts by ENTSO-E to propose a methodology suitable for assessing the time period required for FCR providing units or groups with limited energy reservoirs (LER) to remain available during alert state in Continental Europe (CE) and Nordic synchronous areas.

However, we wish to propose several amendments and clarifications, since some aspects of the proposed methodology might lead to strong distortions of the results or to an incomplete CBA:

  • Normal state, pre alert state, alert state and emergency state parameters should be clearly defined to correctly run the CBA: these parameters should be based on the definitions of the System Operation Guideline and if not possible, more clearly defined in the draft CBA methodology. If we support the ENTSO-E proposal to analyse the sizing of LER-FCR reservoirs during the pre-alert and alert states, we also believe that all other states should be analysed in order to correctly size these reservoirs.
  • The FRR behaviour should also be clearly defined in terms of the amount of energy provided by this service and the way this energy is provided in time, since this can have an important effect on FCR provision.
  • There should be more transparency regarding the relevant frequency profiles and historical data used to determine the different scenarios and Monte Carlo sampling assumptions. Incidents older than 10 years should not be taken into consideration because they do not reflect the current electricity system behaviour. The correlation between long lasting frequency deviations and power outages should be taken into account to produce a more precise evaluation.
  • Regarding the economic approach needed to evaluate the cost-benefit impact of the FCR provision, more information should be given on how the costs will be determined.
  • Following the previous remark and given the complexity to assess the reserve cost, we would also suggest to split the proposed methodology into two parts:
    • First, an evaluation of the technical requirements for FCR, taking into account system needs in terms of security and reliability.
    • Then the CBA.

Read the full response to the public consultation here.

PUBLIC CONSULTATION on the draft Grid+Storage 10-year roadmap

June 2016

The Grid+Storage consortium is glad to announce the publication of their draft research and innovation (R&I) roadmap 2016-2025, integrating for the first time energy storage issues into electricity network activities.

The development of this integrated roadmap has been based on a thorough monitoring of past and ongoing research projects and on the gathering of research and innovation needs identified by European stakeholders during 9 regional workshops.

All stakeholders of the electricity value chain and of other energy networks are invited to provide feedback about the detailed activities foreseen in the roadmap which should drive the energy storage and smart grids R&I strategy at European level for the next decade.

The public consultation is running up to 5 July 2016. Online questionnaires are available on Grid+Storage website

For websites other than Grid+Storage:

About Grid+Storage: Complementing the activities performed so far by the European Electricity Grid Initiative (EEGI) and the Grid+ project, a consortium formed by TECHNOFIEASEEDSOENTSO-ERSE and VITO has been selected by the European Commission to support DG Energy and the Member States in defining a European R&D roadmap integrating energy storage into grid research and innovation activities, both at electricity transmission and distribution levels. More information at


Cost Benefit Analysis Methodology (CBA 2.0)

May 2016

EASE responded to ENTSO-E’s public consultation on the next European Cost Benefit Analysis Methodology (CBA 2.0).

EASE welcomes the updated CBA 2.0 and the transparent process reflected in this consultation. However, we would like to see the dedication to transparency continue beyond the consultation, extending to the assessment of TYNDP projects by ENTSO-E regional groups and to the assessment of Projects of Common Interest (PCIs) by EU Regional Groups. The current process for ranking projects seems rather opaque.

EASE welcomes ENTSO-E’s efforts to clearly explain the difficult notions contained in the CBA 2.0 methodology. One potential further improvement would be to explicitly highlight the modelling complexity to give a sense to the non-modelling reader that models can be limiting. We would welcome an annex that includes more descriptions of the current models used in order to further the reader’s understanding of potential limitations and areas of improvement.

Throughout the CBA 2.0 methodology, it is unclear whether the socio-economic welfare (SEW) indicator refers to gross SEW or net SEW (the difference between the socio-economic welfare and the investment costs of the project). EASE supports presenting “net SEW” as the final result.

Regarding the assessment of Energy Storage projects, EASE notes that there are additional indicators for storage, which may render a comparison with conventional transmission projects more difficult.

The modelling of Energy Storage projects in the CBA 2.0 seems to rely on strong simplifications, which may hamper a true assessment of the benefits of some Energy Storage plants.

Read the full response to the consultation here.


May 2016

EASE submitted a response to DG Research and Innovation’s public consultation on the development of a comprehensive, integrated Research, Innovation, and Competitiveness Strategy for the Energy Union.

Key messages

EASE fully supports the development of an Integrated Energy Union Research, Innovation and Competitiveness Strategy which ensures that research and innovation efforts contribute to making Europe the world’s leader in renewables & low-carbon technologies and solutions while maintaining a competitive industrial base.

One of the most urgent challenges for research and innovation to support the low-carbon transformation is achieving the full deployment of Energy Storage. The development of innovative technologies that increase storage capacity and performance should be encouraged.

Support to research and innovation should be driven by a careful assessment of which technologies provide the largest overall benefits in terms of decarbonising the energy system. Renewable subsidies for mature technologies should be eliminated and non-discriminatory access to technologies which can facilitate the economic growth of renewables (such as Energy Storage) should be facilitated through market-based regulation.

However, support to research and innovation will not in itself lead to the full deployment of available technologies. Research and innovation efforts must be complemented by steps to tear down regulatory barriers to allow for the use of valuable and innovative technologies.

One of the priority measures to ensure that citizens support the transition to a low-carbon economy is to establish electricity retail tariffs that properly reward consumer behaviour and encourage the deployment of small-scale renewable energy sources and Energy Storage technologies.

Read our full response here.

Renewable Energy Directive for the period after 2020

February 2016

EASE responded to DG Energy’s Public Consultation on the Preparation of a new Renewable Energy Directive for the period after 2020.

Key messages

We believe that providing confidence for investors and producers of renewable energy is important.

EASE calls for subsidies for mature renewable technologies to be eliminated. We also call formarket-based regulation, which allows for a non-discriminatory access to technologies, such as energy storage, facilitating economic growth and the further integration of the RES into the energy system.

EU-level support to research and innovation (R&I) for novel renewable energy technologiesneeds to be assured. Additionally, research efforts should focus on the proper integration of renewables into the grid, relying on technologies such as energy storage and smart grids.

A mechanism needs to be found to properly reward consumer behaviour and to encourage thedeployment of small-scale RES and energy storage technologies.

The storage of heat and cold by use of different storage technologies is key for the success of the EU’s decarbonisation efforts.

Read our full response here.

Market Design

October 2015

EASE responded to DG Energy’s Public Consultation on a new Energy Market Design.

Key messages

EASE would like to stress that the future governance framework of the Internal Energy Market needs to incorporate regulatory changes creating a separate asset category and rules for electricity energy storage systems. This is necessary due to their dual generation and demand nature. The new asset category should recognise the contribution energy storage systems will make to system security, loss reduction and the provision of other ancillary services on the T&D networks.
In terms of regulatory oversight and the future role of ACER, EASE thinks the procurement of ancillary services and the way tariffs for transmission network use of system charges are estimated and applied, must also be made transparent across Europe to provide the right investment signals for providers of flexibility (i.e. energy storage and DSR operators).

Read our full response here.

Heating and Cooling Strategy

September 2015

EASE participated to the Heating and Cooling Forum organised by the European Commission.

Key messages EASE highlighted at its intervention at the Forum:

  • Heat storage has been underestimated in the strategy
  • Smart electric thermal storage is not mentioned
  • Storage could help balance energy supply and demand, and help with peakshaving
  • Storage should be seen as a decarbonisation tool
  • Necessity of coherence between Directives, e.g. Ecodesign directive could eliminate heating technologies including storage

Read our full response to the Issue Papers I to V here.

Network Code on Emergency and Restoration

April 2015

EASE responded to ACER’s call for comments on the Network Code on Emergency and Restoration.

Key messages

EASE, the European Association for Storage of Energy, calls for a level playing field for all the services energy storage can render to the system:

  • through a definition that recognises energy storage as an own asset class in all electricity related regulations and that does not restrict its application to system balancing only;
  • through the recognition of energy storage not only as a load but also as a power source capable to contribute to the Frequency Deviation management procedure;
  • through a non-discriminatory consideration of and a fair treatment for energy storage at national level alongside other measures.

Read our full response here.

Retail Energy Market

April 2014

EASE has responded to the Public Consultation of DG Energy on the Retail Energy Market.


Future retail energy markets should take into consideration the following principles:

  • goals of increased empowerment of the consumer in a competitive, sustainable and secure energy system should be primarily attained through instruments designed in a market oriented, non-discriminating and technology-neutral manner;
  • In particular:
    • energy storage constitutes a special and important asset of the complete energy value chain. Therefore the current and future levy structure should not hinder the integration of energy storage;
    • the use of energy storage must be technologically neutral: each case must adopt the most suitable technological and economic solution. Therefore any wording in this regards must be open and not technically discriminatory;
    • the main challenge is related to the value of energy storage, being it monetary or socio-economic, as it can deliver a number of strategic services both to the regulated and to the deregulated parts of the power industry. Therefore the operator of such devices may differ;
    • energy storage will play an important role in new market designs, especially with regards to flexibility markets;
    • specific storage regulation and market mechanisms for flexibility in combination with a new market design will help to create energy storage markets and will contribute to the development of a competitive energy storage industry in Europe.

EASE therefore calls for:

  • a non-discriminatory consideration of and a fair treatment for energy storage alongside other measures, such as demand side management and the increase of interconnection capacity, when considering possible solutions for enhanced grid flexibility, stability and quality;
  • a market design that allows specialised energy storage operators to emerge, as long as this does not trigger market distortion.

For more information, please check the EASE response and the accompanying document.

Draft Guidelines on environmental and energy aid for 2014-2020

February 2014

EASE has responded to the Public Consultation Paper of the Services of DG Competition containing Draft Guidelines on environmental and energy aid for 2014-2020.

Key messages

EASE, the European Association for Storage of Energy, welcomes the draft Guidelines on environmental and energy aid for 2014-2020, in particular the recognition that:

  • climate and energy policy have become increasingly intertwined;
  • a robust state aid control is a must if we are to achieve a well-functioning internal energy market;
  • goals of increased environmental protection and a competitive, sustainable and secure energy system should be primarily attained through instruments designed in a market oriented, non-discriminating and technology-neutral manner;
  • electricity storage will contribute to provide services and value to the entire energy system.

EASE also takes this opportunity to provide feedback, offer expertise and ask for a level playing field for all energy storage technologies in a constructive dialogue with the European Commission (EC).


The definition of storage should […] not be restricted and should include a wider concept of Energy Storage, compared to the current reference to Electricity Storage. Different technologies and concepts are included in the concept of Energy Storage and the selection is expected to be mainly based on the device location and on the different services provided by the device. Moreover, the concept and the value of energy storage technologies must be considered comprising itscapabilities in transferring energy between sectors (e.g. power to gas, hybrid electric vehicles, heat storage…).

Energy storage allows for the use of more RES by avoiding curtailment when there is too much intermittent generation (e.g. solar photovoltaic and/or wind). This service should therefore beremunerated.

EASE strongly believes that the use of energy storage must be technologically neutral: each case must adopt the most suitable technological and economic solution. Therefore the wording must be open and not technically discriminatory.

EASE […] calls for:

  • Equal consideration of energy storage as a solution for enhanced grid flexibility, stability and quality along with other technologies.

EASE […] supports:

  • a non-discriminatory consideration of and a fair treatment for energy storage alongside other measures, such as demand side management and the increase of interconnection capacity, when considering aid to generation capacity;
  • that any measures to ensure generation adequacy, such as potential future capacity markets/payments, or to balance the energy system must be shaped in such a way thatevery energy storage technology is eligible to participate without discrimination, provided it is able to fulfil the technical requirements.

Click here for the full response.

Network Code on Electricity Balancing

August 2013

The EASE response to the ENTSO-E public consultation on the Network Code on Electricity Balancing has just been published on our website.

EASE welcomes the Network Code on Electricity Balancing as a tool to foster effective competition, non-discrimination and transparency in markets. It will further help driving the way to a more harmonised pan-European balancing market.

However, EASE does use the opportunity of this public consultation to express some concerns about the points that we consider central in shaping the future balancing market:

  • EASE believes that the Network Code on Electricity Balancing should ultimately lead to a harmonised framework for a pan-European Balancing Market. The Network Code should be designed as a driver for this evolution.
  • In order to foster the participation of emerging technologies – such as energy storage and demand response – and renewable energy sources, aggregation should be facilitated for both load and generation entities.
  • The evolution of the energy system is likely to trigger the need for balancing products with faster response times and particularly more accurate response curves. The Network Code should not hinder the development of products that are capable of delivering such services.
  • Obligations for market players to put up their unused capacity for bids in the balancing market may prevent market entry of potential players, thus hindering rather than supporting the intended development of markets and competition. They risk enhancing rather than reducing market distortions.

Read our response here.

Green Paper on a 2030 framework for climate and energy policies

July 2013

On 27 March 2013, the European Commission published a Green Paper presenting an overview of the issues that must be considered in the development of a 2030 Framework for Climate and Energy Policies.

This Green Paper served as the basis of a stakeholder consultation on the development thereof.

EASE responded to this public consultation and calls for:

  • A 2030 framework that provides long term stability and clarity for investors;
  • Binding targets for GHG emission reduction;
  • A fair market design: the main challenges for energy storage are not only economic and technological but also regulatory as there is no clear EU framework to incentivise the building of storage capacity and provision of storage services;
  • The recognition that energy storage is expected to greatly contribute to the achievement ofoverall socio-economic targets. For instance energy storage technologies not only ease the market and technical integration of variable RES, but also ensure a higher security of energy supply;
  • Focused RD&D support for energy storage technologies, which aim at supporting a competitive, low-carbon economy;
  • An optimisation of instruments such as the EU ETS to help driving investments forward provided that it can function efficiently (and thus deliver on its principle of a market-based and technology neutral means of CO2 reduction).

Read our response here.

THINK Project

May 2012

THINK is an FP7-financed project that advised the European Commission (DG Energy) on a diverse set of energy policy topics (June 2010 until May 2013).

EASE responded to a public consultation on Topic 8: “Electricity Storage: how to facilitate its development and deployment in the EU?“.

Read our response here.

Renewable Energy Strategy

February 2012

EASE responded to the public consultation intended to help prepare a Communication to inform the EU’s renewable energy policy for the period post 2020. This complements a Communication on the Internal Energy Market also planned for next year which will also help inform the evolution of the EU’s wider energy policies following on from the Energy 2050 Roadmap.

Read our response here.