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smartEn Smart Energy Europe

smartEn

smartEn is a European business association dedicated to promoting demand-side energy flexibility.

Lobbying Activity

Meeting with Virgil-Daniel Popescu (Member of the European Parliament) and Eurelectric aisbl and

10 Dec 2025 · Conference Debate "The grids package: storage for system strength and affordability"

Response to Electrification Action Plan

9 Oct 2025

smartEn is the European association representing the Flexible Demand Management Industry (FDMI), bringing together over 100 leading businesses across the DSF value chain. We welcome the ECs efforts to boost the decarbonisation of the EU economy through the Electrification Action Plan. Together with the revision of the Heating & Cooling Strategy, these initiatives will help remove existing barriers to electrification while reinforcing key enablers, such as the swift implementation of the current regulatory framework and the promotion of consumer-centric policies to enhance system flexibility. On the latter, we particularly support the consultations focus on enhancing system flexibility, notably by leveraging demand-side response as a driver for the smart electrification of the energy system. A smart electrification of the energy system driven by smart grid management and demand-side flexibility offers substantial benefits for all energy end-users, including: - Lower wholesale electricity prices - Reduced system costs, including by optimising investments in infrastructure - Lower energy bills and more opportunities for additional consumer revenues While these benefits are well-understood and widely recognised for households, for example for buildings and mobility, they are equally relevant for industrial processes, including in EIIs. Smart electrification of EIIs can not only reduce energy costs but also create new revenue streams for such industries, thereby enhancing their competitiveness. To support this, smartEn is attaching to this call for evidence a recent Compass Lexecon study on the potential for flexibility provision in EIIs (https://shorturl.at/kVXUO). The study highlights benefits at the installation level, showcasing the flexible potential of electrifying the core processes across five key energy-intensive sectors: steel and iron, pulp and paper, aluminium, cement and glass. It also considers how the valuation of flexibility in electricity markets can help close the decarbonisation cost gap (i.e., the additional revenues needed to offset the costs of shifting toward smart electrification). For each sector, a single technology was selected, and its potential for load management analysed (in terms of activation volume, duration, and frequency). Based on these findings, the study evaluates the markets where this flexibility best fits the flexibility profile and provides the highest value.The study assumes that barriers to the participation of DSR are removed, enabling flexibility to access wholesale markets (day-ahead and intraday), ancillary services, other system services (such as capacity remuneration mechanisms), and congestion management products. However, the modelling has certain limitations. It does not assess the total flexible potential available at a site for each sector (only the flexibility of core processes), nor does it account for the possibility to pool resources within an aggregators portfolio, which could increase the potential revenues from flexibility. There are significant variations in the flexibility potential across the sectors considered (e.g., high in pulp and paper and cement, low in aluminium). Yet, for all of them, the revenues from flexibility can contribute to bridging the decarbonisation cost gap. The highest revenue is observed in the pulp and paper industry, where the installation and valuation of flexibility from hybrid steam production with a steam accumulator can lead to revenues of up to EUR 340,000/MW/year. Additional monetisation opportunities exist in certain markets and through aggregation, including: - Oversizing of processes - Installation of on-site battery storage - Participation in aggregator portfolios - Flexibility provision from non-core processes present on each site We remain at disposal for additional information. Further insights on the benefits of DSF beyond EIIs (i.e., transport and buildings) will be included in smartEns response to the public consultation.
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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

Response to Clean corporate vehicles

4 Sept 2025

Corporate fleets make up six out of ten new car sales in the EU, giving them a pivotal role in transforming Europes vehicle stock - but equally importantly, their daily operations make them ideally suited for smart charging (V1G) and vehicle-to-everything (V2X) solutions, from vehicle-to-grid (V2G) to vehicle-to-building (V2B). These technologies can accelerate decarbonisation, cut energy system costs, and provide valuable grid services. While their use cases and operational needs are diverse, corporate vehicles differ from those of private consumers in that they often follow more predictable driving patterns and are often parked in centralised locations such as depots and parking lots. This provides aggregators offering V2X-based services with both scale and helpful plannability to optimize the use of fleet vehicles as distributed energy assets, usually without the need to change operational driving patterns. On the other hand, fleet operators aiming to cut their operating cost can profit from the significant savings and market-based remuneration generated by V1G and V2X across their fleet - a key advantage for commercial operators, who tend to more frequently base their purchase decisions on their calculator and TCO calculations compared to private consumers. Smart and bidirectional-capable corporate fleets could also help achieve scale in what is currently a niche market with major long-term potential, solving the chicken-and-egg problem by creating demand and driving down costs for production and installation of both smart and bidirectional-capable vehicles and chargers, while also enabling a shop window effect for consumers. SmartEn therefore calls on EU policymakers and regulators to: In the context of the announced initiative on Clean Corporate Fleets, promote the uptake of, and improve consumer information on, smart and bidirectional charging, also in combination with local, distributed renewable production and storage; Encourage companies to conduct an analysis on the cost and benefits of adopting EVs and deploying smart and bidirectional charging in their fleets and parking spaces; Mandate Member States to assess and tackle regulatory barriers to EV adoption in corporate fleets, including in national taxation frameworks, and publish best practices to this end; Assess and tackle regulatory barriers to smart and V2X technologies, such as blockers in grid & network codes, a lack of standardized communication protocols, double taxation and non-discriminatory access to vehicle/battery data (e.g. state of charge, state of health); Ensure full interoperability and facilitate open markets so that consumers are always able to choose both their car model and aggregator/supplier freely, by finalising the revision and harmonisation of connection requirements of both the Requirements for Generators Network code and Demand Response Network Code as a matter of urgency; DG GROW should consider changes to type approval to help ensure V2X capabilities for all newly sold EVs on the market, in line with the Commissions recent Action Plan on the Future of the Automotive Industry. Attached for further background is our recent position paper on the matter, including case studies showcasing concrete examples of real-life deployment.
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Meeting with Alina Nedea (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

21 May 2025 · The role of electrification to contribute to the EU’s competitiveness and security

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

7 Apr 2025 · Clean Industrial Deal, Electrification Action Plan, Affordable Energy Plan, CISAF

Meeting with Lukasz Kolinski (Director Energy)

3 Apr 2025 · Exchange of views on demand side flexibility

Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and E-MOBILITY EUROPE

17 Mar 2025 · Reti elettriche

Meeting with Dan Jørgensen (Commissioner) and

14 Mar 2025 · Clean Industrial Deal, Affordable Energy Action Plan and new State aid Framework (CISAF), Electrification Action Plan

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

24 Feb 2025 · INI Report on Grids

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Meeting with Eszter Lakos (Member of the European Parliament)

29 Jan 2025 · Electricity markets

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

14 Jan 2025 · Presentation of the Electrification Alliance Position Paper and exchanging views with the Cabinet.

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

29 Nov 2024 · Recommendations for an Electrification Action plan in Europe

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

9 Oct 2024 · Meeting with Smart EN on grids

Meeting with Matej Tonin (Member of the European Parliament)

9 Oct 2024 · Topics on transport, industry, building sectors

Meeting with Nicolás González Casares (Member of the European Parliament)

8 Oct 2024 · Energy transition

Meeting with Christophe Grudler (Member of the European Parliament)

8 Oct 2024 · Politiques énergétique et industrielle européennes

Meeting with Sigrid Friis (Member of the European Parliament) and Siemens AG and

8 Oct 2024 · Upcoming term in relation to energy policy

Meeting with Bruno Tobback (Member of the European Parliament)

8 Oct 2024 · Smart energy integration

Meeting with Virginijus Sinkevičius (Member of the European Parliament)

8 Oct 2024 · Discussion on innovative and smart solutions in the digital, transport, industry and building sectors

Meeting with Dario Tamburrano (Member of the European Parliament) and European Forum for Renewable Energy Sources

8 Oct 2024 · Priorità per la legislatura

Meeting with Elisabetta Gualmini (Member of the European Parliament) and The Sherwin-Williams Company

8 Oct 2024 · ITRE Committee

Meeting with Benedetta Scuderi (Member of the European Parliament)

8 Oct 2024 · Energy

Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

Meeting with Benedetta Scuderi (Member of the European Parliament) and Terna spa

18 Sept 2024 · Energy

Meeting with Giorgio Gori (Member of the European Parliament) and Bioenergy Europe and Open Fiber

17 Sept 2024 · Presentation of priorities

Meeting with Michael Bloss (Member of the European Parliament)

4 Sept 2024 · Austausch Energie- und Klimapolitik

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

15 May 2024 · to follow

Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Mar 2024 · Clean Transition Dialogue for Cities

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Isidro Laso Ballesteros (Cabinet of Commissioner Adina Vălean)

13 Dec 2023 · Transport; EV Charging

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

22 Nov 2023 · EU Grids Action Plan

Response to Network Code on Cybersecurity

17 Nov 2023

smartEn Smart Energy Europe, the European business organisation integrating the consumer-driven solutions of the clean energy transition supports the establishment of robust sector-specific cybersecurity rules for the electricity sector. The demand-side flexibility industry is committed to applying ambitious cybersecurity standards to ensure a secure and clean energy transition, where consumer engagement is based on trust. smartEn acknowledges the works carried out by the European Commission and notes that some clarifications have been brought, notably regarding the roles and responsibilities of national and European competent authorities and improved interlinkages with NIS2 regarding the definitions and the processes. We also welcome the improved involvement and consultation of stakeholders in the processes foreseen by the network Code. However, despite these limited improvements, we feel compelled to stress the many persisting shortcomings of the current draft of the Network Code and to reiterate our critical concerns, in particular on: The Scope of application: it is still unclear which actors of the electricity value chain will effectively fall under the obligations of this Network Code. The companies of our sector need to understand if they will likely be considered as high or critical impact entities. The governance: Clarity is still lacking notably on the process for adopting methodologies, the role of competent authorities and the feasibility of the processes, including for risk-assessments. The governance framework should seek to ensure consistency and harmonization in the application of cybersecurity requirements among actors across Europe. Yet, this is not the case with the current code, weakening the purpose of having a European Network Code. The Network Code is not fully harmonized with the framework of EU and national regulations in the field of Cyber Risk management on the electricity sector. There is a risk of generating different approaches to mitigate similar Cyber Risks by creating an overload of compliance. The transitional period: While the timelines have been extended to test the processes and solve issues, the objectives and the requirements of the transitional period are still unclear. Overall, the processes and measures outlined in this Network Code remain incredibly complex for actors to understand what, how and when to implement these obligations. It is still difficult to fully assess the effort and the associated costs, requested by these new potential obligations. Therefore, it is critical that the requirements of the transitional period remain optional, at least for the entities that are not grid operators. Most importantly, the different processes will take 7 years to ensure a full implementation of the Network Code. This proposed timeline is simply not acceptable and disconnected from the reality of the energy system which is faced with ever-evolving and growing cybersecurity threats. In addition, subjecting actors to a waiting period of up to 48 months after the entry into force of the Network Code before notifying them of their identification as a high-impact or critical-impact entity is incongruent with their imperative for visibility and certainty to adopt the necessary cybersecurity requirements. Given the complexity of the processes outlined in the Code and the persisting uncertainties, we are convinced of the importance of targeted efforts by the European Commission to provide guidance for a swift and adequate implementation. smartEn urges the Commission to develop implementation guidelines specific to each category of stakeholders: national and European authorities, system operators and market parties such as flexibility service providers. These guidelines should be developed without delay through a transparent and inclusive process with the relevant stakeholders through the new Cybersecurity working group of the Smart Energy Expert Group or a new ACER expert group.
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Meeting with Kadri Simson (Commissioner) and

23 Oct 2023 · Roundtable meeting with 10 Secretary Generals and CEOs of the Electrification Alliance on the revised Renewable Energy Directive (revised REDII), electricity market design, grids and storage.

Meeting with Kadri Simson (Commissioner) and

20 Jun 2023 · Presentation of new report on smart electrification.

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

11 May 2023 · Energy Market Directive

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur)

4 May 2023 · Electricity Market Design

Meeting with Michael Bloss (Member of the European Parliament)

2 May 2023 · Strommarktdesign (Staff level)

Meeting with Kadri Simson (Commissioner) and

3 Apr 2023 · Discussion on how to strengthen the EU-US cooperation to increase the deployment of renewables.

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 Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

14 Nov 2022 · Energy efficiency, electricity market reform

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

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

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

11 Jul 2022 · To discuss how demand-side flexibility can play a crucial role to support EU demand reduction plan to mitigate the impact of a potential Russian gas supply disruption on the whole energy system.

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

6 Jul 2022 · EPBD

Meeting with Michael Bloss (Member of the European Parliament)

6 Jul 2022 · Fit for 55

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur)

6 Jul 2022 · RED III

Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur) and Schneider Electric and

6 Jul 2022 · The Energy Performance of Buildings Directive

Meeting with Mohammed Chahim (Member of the European Parliament)

5 Jul 2022 · Energy transition/Fit for 55

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

Meeting with Andreas Schieder (Member of the European Parliament, Rapporteur) and Liquid Gas Europe

24 May 2022 · Exchange of Views EPBD

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

25 Apr 2022 · US-EU Task Force Convening: Clean Energy Technologies. Carrier, Tado and the European Council for an Energy Efficient Economy (ECEEE) also participated.

Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur) and European Alliance to Save Energy and

31 Mar 2022 · The Energy Performance of Buildings Directive - Stakeholder Event

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

7 Mar 2022

With the proposal for the Energy Performance of Buildings Directive (EPBD), the Commission is setting policy measures to accelerate the renovation rate of buildings and to achieve the vision of a zero-emission building stock by 2050. smartEn welcomes this legislative proposal and suggests the following improvements: • anticipate the phasing-out of the worst-performing buildings through EU-level minimum Energy Performance Standards (MEPS) to ensure a timely achievement of the 2050 target. • focus the measurement of the energy performance of a building around the new carbon metric to calculate operational greenhouse gas emission. This new metric should also open the possibility to quantify the benefits from demand-side flexibility, measure and incentivise progress through national building renovation plans and financial incentives. • strengthen the new requirements to allow third parties to access building data to support the development of demand-side flexibility business models. • improve the timid provisions for bidirectional charging in buildings to complement the requirements on smart charging. More details in the attached document.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and EPIA SolarPower Europe and

24 Nov 2021 · RED III

Response to Revision of the Energy Tax Directive

15 Nov 2021

The new energy taxation system proposed by the Commission, applicable from 2023, considers electricity among the least taxed energy sources in view of fostering its use (i.e. 0,15 EUR/Gigajoule as for Advanced sustainable bioliquids, biogas and Renewable fuels of non-biological origin). In addition, tax exemptions and reductions for energy from renewable sources, including electricity, may be applied by Member States. To support active customers owning an energy storage facility, art. 22.4 seems to eliminate double taxation as it allows Member States to consider electricity storage facilities and transformers of electricity as redistributors when they supply electricity. This specific provision should be strengthened to make it mandatory, with a clear reference to the support of prosumers business models to avoid misinterpretations. More information in the attached document.
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Response to Revision of Alternative Fuels Infrastructure Directive

15 Nov 2021

Although the Commission contemplates the use of various alternative fuels, with AFIR the Commission recognises the specific contribution of electricity in the transport sector and notably of smart charging to enable EVs to contribute to the flexibility of the energy system and to the further absorption of renewable electricity. This is a significant step in acknowledging the contribution of electrified end-use sectors to support a renewable-based and efficient energy system. Such approach to the transport sector is also well reflected in the Renewables Directive and constitutes a major improvement compared to the lack of such a similar vision for buildings, industry and H&C in the Renewables Directive. However, some timid and confusing provisions are foreseen in AFIR: art. 5.7&8 might lead to a binding requirement for all publicly accessible normal power chargers to be digitally-connected and smart capable, but this is not reflected in the national requirement to set targets and national policy frameworks, as it is just left to progress reports. The development of V2X is left to an assessment by System Operators, which might limit its uptake. More information in the attached document.
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Response to Review of Directive 2012/27/EU on energy efficiency

15 Nov 2021

With the Energy Efficiency Directive proposal, the Commission has timidly started to embrace a system efficiency perspective resulting from the activation of demand-side flexibility, although it is not fully compliant with its own Energy System Integration Strategy. System Operators are identified as responsible players for the correct implementation of the EE1st principle at system level to avoid stranded assets: the procurement of flex services to increase system efficiency should be specified in legal provisions, building on the good Recital 100, both in the context of the Energy Efficiency Obligation Schemes (art. 9) and in the dedicated article on Energy transportation, transmission and distribution (art. 25). To unleash the demand-side flexibility potential of industry, it is important to ensure that Energy Management Systems required to be deployed in large enterprises also integrate them with the energy system and react on the basis of external signals. The innovative idea to define through Delegated Acts national, voluntary "data centre sustainability indicators" has the potential to promote the prosumer business model of data centres, notably in light of the efficiency and renewable-based element of such indicators. More information and details in the attached document.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Nov 2021

With the revision of the Renewable Energy Directive, he Commission is setting policy measures to increase efforts in renewable energy. However, it does not necessarily encourage clean electrification, in particular of buildings, industry and H&C. This leads to vague/absent provisions on their flexible integration with the electricity system, notably in art. 15a (buildings), 22a (industry) and 23 (H&C). This should be strengthened with minimum mandatory requirements for the flexible consumption and storage of renewable electricity both produced on-site and from the grid at least for industry and H&C, if the flexible capability of buildings is going to be addressed in the forthcoming revision of the Energy Performance of Buildings Directive (December 2021). When specifically addressing system integration of renewable electricity (art. 20a), the Commission is making valuable proposals that would support the development of demand-side flexibility business models, including a sort of real-time locational marginal carbon/green intensity information by System Operators, the requirement to share battery data also with third parties and provisions to support smart charging in non-publicly accessible normal chargers to complement rules in the new Alternative Fuels Infrastructure Regulation. More information in the attached document.
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Meeting with Seán Kelly (Member of the European Parliament, Rapporteur)

2 Jul 2021 · Implementation of the Energy Performance of Buildings Directive (Assistant on behalf of MEP)

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

smartEn welcomes the launch of a consultation phase with stakeholders in view of the revision of the Energy Performance of Buildings Directive (EPBD). Considering the roadmap and scenarios proposed by the Commission in its Inception Impact Assessment, smartEn supports Option 3 to amend the EPBD in a coherent way with both the Renovation Wave and the Energy System Integration Strategies. The business community we represent calls for an ambitious regulatory framework that would enable buildings to become flexibility assets, fully integrated energy infrastructures in the energy system, and whose demand-side flexibility would increase the efficiency of the energy system. As calculated by the Commission itself, €5bn/year could be saved at low voltage level from the activation of distributed flexibility; a large share of this potential relies in buildings and their smart interaction with the e-mobility sector. To this end, smartEn would like to highlight the following inputs and recommendations in view of the EPBD revision that are attached to this feedback.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

27 Oct 2020 · Business and investor support for higher ambition and the just transition

Response to Establishment of a smart readiness indicator for buildings

14 Jul 2020

smartEn welcomes the draft Delegated Regulation and recommends taking into account the following suggestions: • Art. 3 - Increased digitisation and connectivity in buildings increases cybersecurity risks and makes buildings and their systems more vulnerable to cyber threats. The SRI should help to inform building owners and users of those risks in general terms as well as the specific level of these risk in a building. In fact, a general warning on cybersecurity, if not complemented by a building specific evaluation, could hamper the attractiveness of innovative solutions. A description of the integrated cybersecurity measures could invoke trust. • Art. 6 – In order to simplify adoption, decrease confusion among stakeholders and end-users, and streamline links with EPCs and other certificates, each Member State that opts to implement the SRI scheme should: o only choose to apply it on a mandatory basis, and not also on a voluntary basis, for buildings or building units located on the territory of that Member State, o adopt the common methodology defined at European level and outlined in Annexes I-IX to avoid unnecessary fragmentations and multiplications of similar SRI schemes across Europe. Modifications, adaptations and evolutions should be discussed and revised at European level, involving the “SRI Platform”. • NEW art. 10 – The draft Delegated Regulation presented by the Commission in December 2019 introduced a “SRI Platform” involving all relevant interested parties, such as Member States’ administrations, competent bodies, stakeholder associations of the buildings sector and consumer organisations. At the last stakeholders’ consultation meeting, all parties welcomed this proposal. smartEn recommends reintroducing this provision in the Delegated Regulation to establish a “SRI Platform” to: o contribute to the promotion of the SRI scheme in the EU, o provide the Commission and Member States with advice and assistance on the implementation of the SRI scheme, notably on formation modules and trainings for accredited experts to issue reliable SRI certificates, o issue recommendations on possible evolutions of the methodological framework for calculating the SRI.
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Response to Implementation modalities of the smart readiness indicator for buildings

14 Jul 2020

smartEn welcomes that the draft Implementing Regulation further details the principles set in the revised EPBD and recommends taking into account the following suggestions: • Art. 3 - As demand-side flexibility is one of the three smart readiness functionalities to be assessed in the SRI, experts accredited and qualified to issue SRI certificates should have a recognised knowledge of the capabilities and requirements of smart and active buildings. We doubt that experts accredited or qualified for issuing Energy Performance Certificates (EPC), or for carrying out inspection of heating, air-conditioning, combined heating or air-conditioning and ventilation systems, have also the skills and competences to assess demand-side flexibility functionalities. In this light, Member States should set specific requirements and dedicated trainings for those experts willing to qualify for issuing SRI certificates, • Art. 5 - Although the voluntary nature of the SRI does not impose any mandatory deployment, we encourage Member States that opt for its uptake to couple it in a mandatory way with the issuing of EPCs and to the BACS deployment trigger points in accordance with Articles 14 & 15 of the EPBD, • Art. 6 - Also information on online self-assessments should be collected and monitored by national and European authorities, beyond information on SRI certificates issued by a qualified or accredited expert, • Art. 7 – SRI certificates should be integrated in a set of regulatory and financial incentives in Member States that opt for its deployment in order to guide and monitor progress in building renovation. In this light, Member States shall establish dedicated measures to support the uptake of the SRI scheme in the context of the long-term renovation strategies, as well as the Renovation Wave and the national recovery plans, • Art. 8 - The SRI needs to get tested to become sufficiently relevant for all relevant parties and for the clean energy transition. Testing of the SRI is important to get all different stakeholders acquainted with this new scheme and methodology. However, the testing phase should not postpone further the structural deployment of the SRI. smartEn welcomes the reduction of this testing phase to 6 months or 1 year at the latest. smartEn supports the requirement to concerned Member States to submit a report on the related feedback to the Commission. This might lead to suggestions on how to improve the SRI implementation, including simplifications and recommendations on how to complement the SRI with existing tools as EPC to increase its value, • Annex – Monitoring of the SRI implementation is key for a proper assessment of the expected “push and pull” impacts. However, it should not be limited to the issued SRI certificates, but cover also online self-assessments. While all data listed in the Annex is relevant for an accurate monitoring, key are the smart readiness scores for the three smart readiness functionalities. Such data should be aggregated at national level as well as at European level. Also the European Commission should be subject to an annual reporting obligation, relying on data collected by Member States, to be made available to all EU institutions and a dedicated “SRI Platform” involving all relevant interested parties, including stakeholder associations and consumer organisations (to be introduced in the Delegated Regulation).
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Response to Revision of the guidelines for trans-European Energy infrastructure

3 Jun 2020

smartEn would like to contribute to the consultation on the Roadmap/Inception Impact Assessment with the following recommendations: • Revise the TEN-E Regulation in line with the Clean Energy Package The energy system of the past relies on large, centralised power plants that generate energy and send it across long distances over power grids that were built as a one-way street, sending energy from the producer to passive households, commercial and industrial consumers. Significant changes are under way, boosted by the EU regulatory framework, notably the Electricity Market Design, which supports the development of decentralised energy resources, eliminates barriers to demand-side flexibility and stimulates the active participation of energy consumers of all sizes to the clean energy transition. While the interconnection of the European system remains important, the revised TEN-E should be consistent and aligned with this evolution to reflect and support the move towards a smart, decentralised energy system made of internet-connected and smart devices in buildings, demand-management programmes in industry and electric vehicles that can flexibly adapt their energy consumption. • Put demand and supply side on an equal footing for proper infrastructure planning Smart energy and demand-side solutions challenge the old supply-side focussed energy paradigm. The changes in supply and demand raise the need for more flexibility to manage variability of supply and demand and provide electricity consistently and reliably. In this light, a shift in focus is necessary to put demand and supply on an equal footing to increase system efficiency. • Apply the “Energy Efficiency First principle” at system level to assess the possibility of non-wire alternatives Energy infrastructure decisions often have an impact of several decades, making today’s decisions crucial to achieving a climate neutral energy system by 2050. The rise of digitalisation, electrification, sector integration and active demand management offer a broader spectrum of solutions which can make grid reinforcements unnecessary. To avoid investments in stranded assets, the TEN-E Regulation should define a methodology to determine whether it would be beneficial for the system that project promoters invest in grid extensions and reinforcements or in flexibility options. As calculated by the European Commission in 2016, increased demand-side flexibility could lead to savings of €5.6bn/year from reduced back-up capacity, network and fuel costs in Europe. In the UK alone, the UK National Infrastructure Commission calculated that the application of flexible technologies to electricity grids could reach £8 billion/year savings in 2030 in operating and investment costs. • Support the roll-out and a common approach of flexibility markets for local system services across Europe In line with the previous recommendation, the TEN-E Regulation should support and leverage market-based solutions to procure flexibility services at distribution level and facilitate greater integration of variable renewables across borders. • Include “Distributed infrastructures” among the new and updated infrastructure categories The centralised, large infrastructure logic of the TEN-E Regulation should be fundamentally revised to valorise grid-edge assets as flexibility options integrated in the energy system. • Include in the eligibility criteria the aggregation of small, decentralised projects In line with the above, bundling small-scale, individual projects on the demand side into aggregated ones should be allowed to integrate them on a cross-border level to increase system efficiency and improve financing. For example, the renovation of buildings and the deployment of normal-power, smart charging infrastructure for electric vehicles should be pooled to form new Projects of Common Interest. • Develop synergies among different sectors and align the identification of PCIs with the TYNDP
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Response to Commission Communication – "Renovation wave" initiative for the building sector

3 Jun 2020

smartEn welcomes that the strategic Communication will establish an Action Plan with both legislative and non-legislative instruments and enabling tools. In particular, smartEn would recommend the Commission to: • Recognise and promote fully integrated renovations based on energy efficiency, on-site renewables and demand-side flexibility to achieve smart and decarbonised buildings. • Valorise all decentralised energy resources (distributed renewable generation, energy storage and demand response) in buildings as key enablers of the clean energy transition and support their deployment by: o Allocating a significant proportion of EU funds, notably the Recovery Fund, to behind the meter, smart energy assets, o Removing tax barriers to the deployment of active building installations, o Promoting innovative fiscal and financing schemes, such as Energy Performance Contracting, on-tax or on-bill programmes, o Incentivizing Member States to remove administrative barriers to decentralised energy resources and EV smart charging in buildings (e.g. planning and building rules, electric code, safety rules, …). Particularly households with limited sources of capital will need financial support to invest in decentralised energy resources and comply with regulations phasing out carbon-intensive devices as natural gas heating systems. • Require all new buildings and renovations from 2025 onwards to include an interoperable Energy Management System (EMS) that integrates buildings with the grid to enable automated flexibility, and favour a greater digitalisation of buildings. • Foster the direct electrification of smart and active buildings and the cross-sector integration behind the meter. • Promote the smart integration between buildings and transport sectors by mandating increased cabling and ducting requirements and by supporting the installation in buildings of normal-power, smart charging infrastructure for electric vehicles, as already foreseen in UK, France and Finland. • Foster access to data of energy assets. • Bundle smaller/individual renovation projects into aggregated ones, including by leveraging the innovative role of energy communities, as foreseen by both the Electricity Directive and the revised Renewables Directive or, in the medium-term, through the revised TEN-E Regulation to support a pool of small-scale, decentralised projects on the demand side. Integrating renovation concepts on the district and city level should aim at increasing system efficiency. • Leverage other bottom-up initiatives targeting energy consumers, notably the European Climate Pact, to engage citizens in the clean energy transition, notably through the smart renovation of their homes and offices. • Avoid developing new “renovation labels”, but streamline existing certificates and indicators as currently investigated by DG GROW under the Building Digital Logbook initiative. The Renovation Wave Strategy should also foresee in the medium-term the definition of an actual performance quantification to trigger renovation upgrades.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

smartEn welcomes the launch of a consultation phase with stakeholders in view of the revision of the Alternative Fuels Infrastructure Directive (AFID). We would like to highlight the following inputs on the published Roadmap/Inception Impact Assessment: • the scope of the identified Objectives and Policy Options to tackle Problems n. 1 and 2 on the lack of a comprehensive network of charging points should be expanded. While the current AFID focuses only on infrastructure along nodes and the Trans-European Network, the revised legislation should focus more on urban areas as well as buildings where the vast majority of charging will take place, whether in public (streets, public parking) or private space (at work, at home), and possibly adapt the requirements to the nature of the charging place; • the identified Problem n. 4, i.e. the lack of a proper integration between energy and transport sectors, is a crucial one. Building-up an EV charging infrastructure network will be an important enabler for the transition to a carbon-neutral economy not only if it is dense, widespread, reliable and easy-to-use, but also if it is integrated with the grid to allow the power system to benefit from the TWhs of capacity of batteries on wheels in parking lots, garages and streets. And vice-versa, to allow EVs to benefit from green energy when it is cheap and abundant. In order to overcome Problem n. 4, smartEn supports the identified Objective and Policy Option to enable deployment of “smart recharging infrastructure”. However, smart charging infrastructure should be future proof and not preclude future evolution, for example bidirectional flows of energy with the grid. Vehicle-to-grid services should be possible wherever the driver plugs in Europe. The transition to a climate-neutral economy requires a robust policy framework that must keep open to future innovations. Avoiding lock-in, stranded assets and avoiding deployment of non-future-proof infrastructure should be a key objective of a revised AFID. To conclude, smartEn believes that given the fundamentally new nature of EV charging infrastructure, an Implementation Plan to provide guidance to Member States for implementing key provision will be required.
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

12 Mar 2020 · Energy initiatives in the Commission work programme, upcoming tertiary acts. Flexibility, energy efficiency, systems efficiency in the climate neutrality transition

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6 Nov 2019 · Keynote speech : powering the European Green Deal

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

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14 Nov 2016 · Retail Markets

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

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

10 Jun 2016 · Market Design

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

21 Mar 2016 · upcoming initiatives to implement the Energy Union Strategy

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