Response to the Feedback on the Roadmap on the Action Plan on the digitalisation of the energy sector

The electricity industry, represented by Eurelectric, welcomes the publication of the Roadmap for the Action Plan on the digitalisation of the energy sector. The digitalisation of the energy sector
contributes to economic growth and job creation, to boosting competitiveness and innovation, and to drive the development of innovative solutions leading to new sustainable energy products
and services for European citizens.
Eurelectric urges the Commission to focus its Action Plan on electricity, given the growing importance of electrification needed to reach the 2030 and 2050 climate and energy objectives.
Prioritising direct electrification is crucial to enable the decarbonisation of emerging and established industries, as well as the development of smarter, cleaner, and more integrated
energy systems. In addition, digitalisation - by redrawing boundaries and redefining relationships between consumers and utilities - enables the technological development and commercialisation of crucial flexibility, demand-side, storage solutions and services.
To foster the digitalisation and the sector integration of energy carriers, the Action Plan must foster active participation of end-users across energy systems. However, following actions are
essential to support the electricity industry on its path towards digitalisation:
• Developing a European data-sharing infrastructure (aligned with the interoperability requirements and procedures of Art.23/24 of the Electricity Directive) empowering network operators to ensure consistent and neutral data management practices.
Furthermore, timely data availability is essential to harness the full potential of digitalisation.
• Avoiding compulsory data sharing schemes that may lead to unfair competition: as recommended in the EU Strategy for data, to develop competitive markets for digital energy services, the sharing of privately held data should be done on a voluntary basis.
• Promoting the deployment of advanced metering infrastructure providing accurate consumption and generation data.
• Removing barriers to the development of digital tools enabling flexibility and local gridbalancing services, including requirements for the collection of non-personal data as defined in the ePrivacy Regulation.
• Ensuring a coherent and homogeneous implementation of the AI Regulation in the energy sector.
• Ensuring the cybersecurity and resilience of digital supply chains, aligned with the requirements and procedures of Art.51 of the Cybersecurity Act.
• Enhancing and ensuring a coherent and harmonised Cybersecurity legal framework for all stakeholders of the energy system - along with the development of the proposed NIS-2
Directive and the planned Network Code on cybersecurity of cross border electricity flows – to address the risk of cascading effects induced by growing interconnections of energy systems, supporting cyber assets, and related data.
Feedback on the Roadmap on the Action Plan on the digitalisation of the energy sector
• Facilitating the development and deployment of interoperability measures and European cloud offerings enhancing the scaling up and uptake of digital climate-neutral piloted solutions. To this regard, the SWIPO codes of conduct must be sustained to increase trust in European cloud offerings.
• Encouraging research ventures between the scientific community and the power industry harnessing the full potential of open data platforms and licenses.
• Promoting best practices and experiences from R&I projects developing new digital tools and services to facilitate active participation of actors across energy networks.
• Addressing social challenges highlighted by the Digital Economy and Society Index, in particular: citizens' trust in data-driven energy services, acceptance of new technologies,
data protection and privacy concerns, digital divides, and lack of adequate skills.