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GEODE - The voice of local energy distributors across Europe

GEODE is a European association representing local gas and electricity distribution system operators.

Lobbying Activity

Meeting with Lukasz Kolinski (Director Energy)

19 Jan 2026 · Grids package, Electrification Action Plan, Clean Energy Investment Strategy

GEODE Urges Flexible Standards for Local Energy Grid Digitalization

5 Nov 2025
Topic — EU initiative to integrate artificial intelligence and digital technologies into energy systems.
Message — GEODE calls for common standards that remain flexible enough for small, local distributors to innovate. They recommend a targeted approach to technology deployment rather than universal rollouts.12
Why — This strategy allows distributors to avoid expensive grid reinforcements by using local digital tools.3
Impact — Technology providers lose sales volume if operators adopt targeted rather than universal equipment rollouts.4
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Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur)

6 Mar 2025 · Electricity grids

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur) and Euroheat and Power

6 Mar 2025 · INI Report on Grids

Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and Finnish Energy - Energiateollisuus ry

6 Mar 2025 · Reti elettriche

Meeting with Emma Wiesner (Member of the European Parliament) and Eurelectric aisbl

15 Jan 2025 · EUs energipolitik

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Eurelectric aisbl and EU DSO Entity

15 Jan 2025 · Energy Breakfast

Meeting with Jutta Paulus (Member of the European Parliament) and Eurelectric aisbl and

15 Jan 2025 · Energy Breakfast

Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur) and Eurelectric aisbl and EU DSO Entity

15 Jan 2025 · Event on The role of electricity distribution grids in the green transition

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur)

3 May 2023 · Energy Market Directive

Meeting with Emma Wiesner (Member of the European Parliament) and Carbon Market Watch

28 Feb 2023 · Elmarknadsdesign

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

28 Sept 2022 · Gasmarktrichtlinie

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

4 Jul 2022 · Austausch zur Vekehrspolitik

Response to Revision of EU rules on Gas

12 Apr 2022

GEODE believes the proposal represents a unique opportunity to promote system integration in the EU energy sector and scale up the share of renewable and low carbon gases as key drivers for decarbonisation. Hydrogen is key in this context and this legislative text can dramatically enable its growth. To ensure that these objectives are achieved to their full potential, the role of distribution system operators must be fully acknowledged. This includes the creation of a coherent representation framework for DSOs at European level, reflecting their ability to manage different types of gases in an increasing integration of the energy system. GEODE's complete feedback can be found in the attached document.
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Response to Revision of EU rules on Gas

12 Apr 2022

GEODE believes the proposal represents a unique opportunity to promote system integration in the EU energy sector and scale up the share of renewable and low carbon gases as key drivers for decarbonisation. Hydrogen plays a central role in this context and this legislative text can dramatically enable its growth. To ensure that these objectives are achieved to their full potential, GEODE would like to share a series of recommendations to improve the proposal, highlighting how distribution system operators are crucial actors in this process. GEODE's complete feedback can be found in the attached document.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and EUROGAS and

22 Nov 2021 · Videoconference - Energy Taxation Directive in Fit for 55 package

Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

17 May 2021 · How local DSOs enable the energy transition Role of gas DSOs Implementation of CEP EU DSO Entity EU Recovery Facility – Next Generation

Response to Revision of the guidelines for trans-European Energy infrastructure

5 Mar 2021

GEODE - the European association representing local electricity and gas Distribution System Operators (DSOs) across Europe - welcomes the opportunity to comment on the revised TEN-E Regulation. We share the Commission’s view on the need for modernizing the Regulation by aligning it with the policy objectives of the Green Deal and the Clean Energy Package (CEP) regulatory framework, notably supporting an increased role of DSOs. However, we do believe that the proposal falls short of the above objectives – in particular in terms of allowing a more prominent role of distribution infrastructure as a “key enabler for the energy transition”. Regarding electricity smart grids, the proposal conditions DSOs’ participation solely with the support of TSOs from at least two Member States while infrastructure for low-voltage projects is not eligible and still excluded. This fails to acknowledge that the continuous increase of renewables and electrification, in line with climate and energy targets, does and will require considerable investments in the distribution system’s infrastructure to which 70% of EU RES is and will connect . These requirements along with the same technical criteria (50.000 users, 300 GWh/year with 20% from RES) make these funds for smart grid projects not accessible to DSOs. GEODE welcomes the inclusion of hydrogen and smart gas grids infrastructure. However, the proposed rules and criteria to qualify as a PCI exclude in practice local DSOs from participating as a cross-border dimension is required. DSOs’ participation is conditioned on the support of TSOs from at least two Member States, and pipelines for the local distribution of hydrogen are excluded overlooking here as well the important role of local DSOs in the system-wide development. The general exclusion of the gas infrastructure from the scope is seen critically since the repurposing of existing gas distribution grid to guarantee higher uptake of renewable gases and their storage facilities and flexibility potential is essential to ensure a pathway to climate neutrality. GEODE encourages the Commission to develop a wider approach to the definition of cross-border projects, applied both to electricity (including low voltage) and gas smart grids projects, in order to enable also the development of local and decentralized projects without physical cross-border impact, which could be replicated across borders, without the required support of at least two TSOs. Alternatively, similar requirement for transmission projects to have the support of DSOs should be applicable. Additionally, the interlinkages between lower voltage investment needs and cross-border or national energy network developments are many. A very concrete example is that, in some Member States, the ongoing efforts from DSOs to reinforce the capacity of their networks to allow the integration of increasing renewable energy sources in view of the next 5 to 10 years, require not only an enlargement of the current network, but also the increment of the capacity exchange on the respective TSO borders, having therefore a massive impact not only at the DSO level, but also on TSO level. An extended scope as proposed would also allow the consideration of district heating and cooling infrastructures, projects that could bring positive effects in developing a more integrated energy system across multiple Members States. In summary, GEODE believes that energy infrastructure investments should better reflect the current and future evolution of the European energy system, allowing distribution projects to play a major role under TEN-E Regulation. An initial step forward being for instance the inclusion of the new EU DSO-Entity in the TYNDP processes and within the TEN-E regional groups.
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

GEODE – the European association representing local electricity and gas Distribution System Operators (DSOs) – welcomes the EC’s draft delegated act under the EU Taxonomy Regulation. We are committed to the objective of climate neutrality in 2050 and believe that the development of a comprehensive Taxonomy will help the EU fulfill its targets. We would, however, like to express certain concerns regarding the draft delegated act. • DSOs are legally obliged to connect all grid-users that fulfill the technical requirements to their grids (consumption and production). Moreover, DSOs are obliged to not discriminate between them (Directive 2019/944) and to act as neutral market facilitators. 4.9 Transmission & distribution of electricity, criterion 2 is in contradiction to the existing regulatory framework and outside the DSOs’ control, leading to unwanted uncertainties on investments, which could hamper the development of the DSOs grids and puts into risk the energy transition. The eligibility of a distribution system should not be dependent on actions outside of the DSOs’ control. • 4.19 Co-generation of heat/cool and power from gaseous and liquid fuels: GEODE believes that the proposed value of life-cycle assessment for GHG emissions below 100gCO2e/kWh for this energy generation activity is overly ambitious. Emission thresholds alone do not fully capture the benefits of these activities, which is especially true for enabling activities that facilitate the long-term decarbonization. Co-generation of heat/cool and power out of gaseous or liquid fuels strongly contributes to security of supply, flexibility and resilience in an integrated energy system in line with EC ESI Strategy. Co-generation plants offer the possibility to replace fossil fuels with low-carbon alternatives, e.g. renewable and low-carbon gases (i.e. via retrofitting or re-purposing of a fossil CHP plant to a “green” CHP plant). Similarly, the same target under "4.7 Electricity generation from gaseous & liquid fuels" jeopardizes system stability as gas and hydro balance the grid. • Bioenergy (7.6 Installation, maintenance and repair of renewable energy technologies) should be seen as a long-term renewable energy source that meets the sustainability criteria set in accordance with RED II. Annex I, Chapter 7.6. should also include the construction/installation/maintenance/repair of bioenergy plants (excl. micro-CHP), bringing it in line with the Taxonomy Regulation Article 10(1): 1. • GEODE welcomes the acknowledgement that the technical screening criteria for enabling activities that facilitate the long-term decarbonization should predominantly be based on the nature of the activity or on the best available technologies (4.14 Transmission & distribution networks for renewable & low-carbon gases). Gas activities fully correspond to these characteristics and should be included in this approach as they contribute to an integrated energy system that is both secure and sustainable. • In order to guarantee security of supply in a cost-efficient manner, gas DSOs should be allowed to connect new flexible unities through gas grid extensions. Otherwise this could negatively impact on more complex injection of renewable gases and/or on higher costs for grid reinforcement. • GEODE also misses the explicit mentioning of biomethane as a valuable contribution to greening the gas grid. • The proposed emission threshold of 2.256 kgCO2/kgH2 (3.9 Manufacture of hydrogen) rules out the production of H2 from most European decarbonized grid mix and from electricity produced from solar. The criteria also largely pre-empt the debate on the forthcoming EU hydrogen regulatory framework. In summary, GEODE believes the Taxonomy needs to take a holistic approach looking at all solutions that contribute to meeting the EU energy, environmental, climate and circular economy goals. In this endeavor, GEODE is looking forward to supporting the EC in the further development of the EU Taxonomy.
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Response to EU Methane Strategy

31 Jul 2020

GEODE – the Association representing local gas and electricity Distribution System Operators (DSOs) across Europe – welcomes the opportunity to comment on the European Commission’s roadmap for an EU Methane Strategy. We support the development of an EU Strategy to further reduce methane emissions and we particularly welcome the cross-sectorial nature of the forthcoming Communication, encompassing agriculture and waste alongside energy. GEODE believes this holistic approach – echoing the EU Strategies on Energy System Integration and Hydrogen by removing silo structures – is necessary to tackle the issue of methane emissions in a cost-effective way. For the development of this Strategy and any legislative and non-legislative initiatives which will follow, we would like to highlight the following critical elements: • Firstly, it is paramount to consider and understand the different and often complex characteristics of the relevant stakeholders. In the case of the European gas DSO landscape, it is highly diverse in terms of company size, the number of connected customers, and resources, with some Member States having only a few large DSOs while other Member States have several hundred smaller DSOs. In light of that, any proposed actions need to be carefully designed to avoid a one-size-fits all approach. • Secondly, and linked to the first point, the Strategy and any related legislative or non-legislative initiatives need to consider the regulatory framework for DSOs. DSOs do not own the gas they are distributing, only the infrastructure, and this needs to be considered when developing procedures and processes for DSOs. • GEODE fully supports the European Commission’s intention to further promote leak detection and repair (LDAR) programs. A European-wide methodology to calculate emissions at distribution level and a common template for reporting would be welcome, taking into account the specificities outlined above. LDAR is already an essential task for GEODE’s members, and we stand ready to provide the European Commission with our technical expertise and experience in this regard. • GEODE also fully supports and welcomes the Commission’s intention to explore an enabling framework for methane capture from agricultural waste synergies with waste legislation in the context of biogas production through anaerobic digestion. GEODE is looking forward to working together with the European Commission and other stakeholders across the energy value chain and beyond to further reduce methane emissions, thereby contributing to reaching the 2050 climate targets.
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Meeting with Kadri Simson (Commissioner) and

27 Jan 2020 · Decentralized energy systems, establishment of EU DSO entity

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and

19 Jun 2018 · Clean energy package and role of DSOs

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

17 Apr 2018 · Clean Energy Package and DSO (workshop organised by GEODE/ASEME)

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

4 Apr 2017 · Market design

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

4 Apr 2017 · "Clean Energy for All Europeans” package

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

26 Oct 2016 · Electricity Market Design

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and NATURGY ENERGY GROUP

17 Mar 2016 · Electricity Market Design

Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

16 Mar 2015 · Energy Union

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

4 Feb 2015 · Priorities for this year on both ENERGY and CLIMAT ACTION

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

11 Dec 2014 · Introducing GEODE and future collaboration