Response to Public Consultations

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 its capabilities 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 be remunerated.

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 that every 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 of overall 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.