Caruna Networks Oy
Caruna
Caruna is a Finnish electricity network company.
ID: 787774540739-10
Lobbying Activity
Response to Targeted technical update of EU rules on measuring instruments
12 Feb 2025
Caruna welcomes the Commissions (EC) proposal to update the Measuring Instruments Directive (MID) to match the latest technological developments. As a DSO, we own and operate our customers smart electricity meters and see that advancing the smart meter roll-out should be a priority. Caruna welcomes the EC proposal to introduce broader options for electricity meters display requirements (Annex I, 10.6.), allowing the meter to present the relevant data also on a remote display or on a device of the consumer or end-user. We see that this is a positive development, enabling technology development and allowing other several technical solutions to check the meter data in addition to the built-in display. When deciding on energy meters functionalities, a vision for 20 years ahead must exist as the meters are a long-term investment. Too frequent reinvestments of the meters cause unnecessary customer cost that is especially damaging to customers with low energy consumption. We see that the customers right to verify the data must be implemented more cost-efficiently than via a built-in display. Verifying the data can be done e.g. through DSO online services, where customers have access to the data in a more customer-friendly view. Caruna notes that all customers do not have access to the meter (apartment building), which is the case for many in Finland. Updating the information (e.g. tariff) on the display uses the meter's communication link capacity and is burdensome. The displays are the single component of the meters that are most likely to fail and if so, the whole meter must be replaced. As the meters must withstand extreme conditions (cold, moisture, heat), components like displays are vulnerable. In addition to being more consumer-friendly, display-free meters would save customer charges. Caruna notes that in Finland, a centralised information exchange system for the electricity retail market already exists. All metering data goes to Datahub, which also allows the consumer to see all data stored about them. For the individual consumer, checking the data from a DSO portal is the most feasible solution. Real-time data can be also read through a separate device via a HAN-port of the remote metering device. We therefore welcome the proposal on the indication of result. We see that this would allow a solution where the data is transmitted wirelessly from the meter to the end user's device, which would show the data in an application/browser-based service. Caruna notes that data transmission in other sectors is also done wirelessly and there are protocols for it. However, Caruna notes that the formulation of 10.6 still leaves room for interpretation and requires a common understanding of the definitions, especially regarding the end-users device. Caruna also notes that while data transmission must be ensured, the requirements should not demand an additional smart meter gateway device, but the meter's data transmission solution should be sufficient (external device/integrated). A key element is that other ways to show data are allowed in addition to the display to enable the production and use of smart meters without a built-in display in the future. As the granularity and demands for metering continuously develop, Caruna finally notes that there is always some level of uncertainty in metering. As part of a normal settlement process missing data can be complemented, due to a supply interruption or poor data connection, thus there must always be a possibility to complement missing data. The measurement accuracy is also evident in the imbalance settlement. Imbalances for each market participant are calculated and invoiced by accountable third party with the mandate from Nordic TSOs. Also, if needed, the meter can be manually read by a professional. We see that the MIDs primary target should be enabling technology development and different technical functionalities, for reliable and efficient measuring.
Read full responseMeeting with Maria Guzenina (Member of the European Parliament)
20 Nov 2024 · Energy
Meeting with Aura Salla (Member of the European Parliament)
19 Nov 2024 · The role of electricity distribution in ensuring clean transition development projects, attracting industrial investments and securing supply security in Europe
Meeting with Eero Heinäluoma (Member of the European Parliament)
19 Nov 2024 · Energy issues
Response to Targeted technical update of EU rules on measuring instruments
17 Oct 2024
Caruna welcomes the Commissions plans for a technical update on the Measuring Instruments Directive to match the latest technological developments for the clean transition. Caruna agrees with the EC that the current MID is not fit for purpose when it comes to technological progress. We agree with the EC that the role of smart metering is crucial when considering well-functioning electricity markets. As a DSO, we own and operate our customers smart electricity meters and see that advancing the smart meter roll-out should be a priority. When deciding on energy meters functionalities, a vision for 20 years ahead must exist as the meters are a long-term investment. The roll-out of meters is a major project when compared to other DSO investments. Too frequent reinvestments of the meters cause unnecessary customer cost that is especially damaging to customers with low energy consumption. Therefore, MID should set the framework and obligations for metering, but not define the technology. E.g., the customers right to metering data falls in our view to the MID framework, whereas how this is achieved should allow for technological innovations. Caruna welcomes ECs plans to introduce more flexible rules on electricity meters display requirements that would allow several technical solutions in addition to the built-in display. We see that the customers right to verify the measuring data must be implemented more cost-efficiently than via a built-in display. Other possibilities should be allowed: verifying the data can be done e.g. through DSO online services, where customers have access to the same meter data in a more customer-friendly view. All customers do not have access to the meter (apartment building), which is why checking the measurement data must be done in an accessible way. Another key reason is that the display unnecessarily increases costs. Updating the information (e.g. tariff) on the display uses the meter's communication link capacity and is burdensome. The displays are the single component of the meters that are most likely to fail and if so, the whole meter must be replaced. As the meters must withstand extreme conditions (cold, moisture, heat), components like displays are vulnerable. Also, it represents a large cost component when compared to the entire meter cost. As the costs are ultimately channeled to the users, display-free meters would save both DSOs costs, as well as customer charges. We see WELMECs proposals (10/2023) on the indication of result (Annex I) going to the right direction as it proposes alternatives to the display, including a metrologically controlled remote display, application software or channel (data storage, website). Caruna notes that in Finland, a centralised information exchange system for the electricity retail market already exists. All metering data goes to Datahub, which also allows the consumer to see all data stored about them. For the individual customer, checking consumption/self-production data from a DSO portal is the most feasible solution. We welcome the ECs plans to amend the part on indication of result and see that websites should be included as one of the solutions. As the granularity and demands for electricity metering continuously develop, Caruna notes that there is always some level of uncertainty in metering. As part of a normal settlement process missing measurement data can be complemented, due to a supply interruption or poor data connection thus there must always be a possibility to complement missing data. The measurement accuracy is also evident in the imbalance settlement. Imbalances for each market participant are calculated and invoiced by accountable third party with the mandate from Nordic TSOs. To ensure that the clean transition goals are achieved, we see that the revised MID's primary target should be enabling technology development and different technical functionalities, to produce reliable and efficient solutions for measurement.
Read full responseMeeting with Miapetra Kumpula-Natri (Member of the European Parliament)
30 Jun 2023 · Meeting on energy related topics
Response to Revision of the EU’s electricity market design
22 May 2023
Caruna welcomes the Commission's proposal to reform the EU electricity market with targeted measures to support the achievement of the climate targets through accelerated renewables deployment, ensuring industry competitiveness while protecting vulnerable consumers. The future energy system is more dependent on electricity, which requires a massive uptake of new renewables and ways of energy production, flexibility as well as digital solutions. Grids and distribution system operators (DSOs) are crucial enablers of the transition, connecting every piece of the energy system puzzle. To best support the transition and maintain the future system, reliable DSO operations need to be ensured. Caruna would like to highlight the following aspects: -Customer empowerment regarding demand response and metering should be handled cost-effectively and safely -Regulation models for DSOs should encourage the acquirement of flexibility services as a real alternative for investments -In different reporting, existing information should be utilised as far as possible and data protection considered The Commission proposes a new definition of a dedicated metering device, to allow DSOs to use data from these devices for the observability and settlement of demand response and flexibility services. We strongly support enabling customers to use flexibility solutions this is required for the fluent operation of the future energy system. Therefore, it is crucial that the legislative framework is accurate with the right incentives. However, the broadness of the provision leaves room for possible misinterpretation and could lead to the use of private meters that are not readable by DSOs. Caruna sees that the requirements for quality of measurement must remain, as of today, reliable and safe. When smart metering is applied, all meters that provide data to a DSO-process (billing and settlement), should be compliant with the Measurement Instruments Directive and the DSO systems, considering cybersecurity as well. When considering the whole process, smart meters operated by the DSO would also be the most cost-efficient solution. As the situation is diverse in different Member States, we see that the technical aspects of demand response and metering should be addressed in the specific network codes, and the definition could be updated accordingly, to prevent misinterpretation. This would ensure that measuring for DSO purposes remains safe, reliable and compatible with DSO processes. We welcome the Commission's signal to support anticipatory investments and consider both capital and operational expenditure in tariff methodology incentives. The DSO industry is CAPEX-intensive by nature, and this is why the regulation models in Member States incentivise the use of CAPEX. However, when the future energy system requires more innovative flexibility solutions, incentives to use flexibility services are also needed. Therefore, OPEX use replacing investments should be separately handled and incentivised, to support the acquirement of economically sensible flexibility services. The resulting increased OPEX can be beneficial for the customer if it is due to replacing investments with acquiring these services. In addition, Caruna sees the assessment of flexibility needs and objectives as positive to enable the development of the future energy system but would like to point out that the usability of existing reporting for this purpose must also be considered. Furthermore, regarding publishing data on capacity available for new connections, Caruna highlights that further discussion is needed on the optimal level of sharing the information. Although optimising the locations for new renewable energy production is important, striking a balance between transparency and critical infrastructure protection is crucial. With these aspects in mind, Caruna is looking forward to the legislative process to help achieve the electricity system of the future with grids in its core.
Read full responseMeeting with Nils Torvalds (Member of the European Parliament)
17 May 2023 · Electricity markets
Meeting with Nils Torvalds (Member of the European Parliament)
24 Mar 2023 · Energy industry