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FUSION Consultation Form

Please complete the form below, answering as many questions as possible.

Is your response confidential?

Q1: Flexibility value chain - Independent aggregation in wholesale markets

Q1a: Provided appropriate arrangements for wholesale energy and imbalance settlement for affected suppliers are in place, do you agree that aggregators should be able to provide their services in the wholesale energy markets without a supply licence or an agreement with the supplier of the customer?

Please select from the following options:

Q2: Market Organisation - Congestion point repository

Q2a: Should there be a standardised publication of congestion points and associated connections, flexible assets and active aggregators, which market participants have access to?

Q2b: If yes, do you think this should be a regulated entity (e.g. operating under licence, and regulated by Ofgem)?

Q3: Market Organisation: Central data hub

Q3a: Do you agree that there should be a central data hub to record flexibility volumes and transactions to allow consistent settlement of flexibility and create transparency?

Q3b: If yes, do you think this should be a regulated entity (e.g. operating under licence and regulated by Ofgem)?

Q4: Market Organisation - Constraint management service provider

Q4a: Would it be beneficial to formalise the responsibilities and the role of the constraint management service provider (CMSP) similarly to the BSP role?

Q5: Market Design - Operating regimes

Q5a: Do you think that there is need to create transparency on network limitations that restrict the free trade of flexibility services by market participants?

Q5b: If yes, do you think that Operating Regimes recommended by USEF are a feasible solution for this issue?

Q5c: Do you think that clear rules should be defined to regulate when DSOs move from one state to the other?

Q6: Market Design - Information exchange

Q6a: Do you think that further coordination of flexibility deployment between suppliers/aggregators and the ESO/DSOs is needed to facilitate efficient and reliable flexibility markets?

Q6b: If yes, do you agree that information exchange (i.e. D-programs) between suppliers/aggregators and ESO/DSOs, concerning flexibility contracts and flexibility activations, limited to congested areas, should be mandatory?

Q7: Market Design - Flexibility Platforms

Q7a: Would you consider that it is beneficial to have a standard interface between (1) flexibility service providers and flexibility platforms; and (2) TSO/DSO platforms and third-party commercial platforms?

Q8: DSO Flexibility Transactions - DSO flexibility procurement

Q8a: Do you agree with USEF recommendation to allow free bids in a DSO congestion management product, even when DSOs requirements are met by the existing availability contracts?

Q9: DSO Flexibility Transactions - DSO flexibility products & processes

Q9a: Do you agree that a common mechanism for all DSOs and the ESO to procure flexibility and interact with the market would be beneficial?

Q9b: If yes, would you consider the USEF approach to be suitable for providing this mechanism?

Q9d: Do you consider it beneficial for GB processes to align with European processes for DSO flexibility mechanisms?

Q10: Market access requirements - Aggregator implementation models

Q10a: Do you consider that aggregators should have balance responsibility for the flexibility they operate in all flexibility markets and products?

Q10c: Do you agree that the open supply position of the supplier should be corrected through defined mechanisms?

Q11: Market access requirements - Re-dispatch responsibility

Q11a: Who should be responsible for the re-dispatch in a DSO congestion management product? Please select among the options a-e above

Q12: Market access requirements - Flexibility value stacking

Q12a: Do you agree that dynamic pooling in flexibility services should be supported?

Q13: Market access requirements - Sub-metering arrangements

Q13a: Should sub-metering be allowed in all markets and products, including wholesale market and DSO constraint management service?

Q13c: In the case of independent aggregation, should sub-metering also be used as input for the quantification of the Transfer of Energy, which, in turn, will impact wholesale settlement?

Q14: Privacy and cyber security - Congestion point publication

Q14a: Is the publication of congestion points using connection identifiers in line with GDPR requirements on security and privacy?

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