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Commentary of the Union of Entrepreneurs and Employers on the Communication from the Commission to the European Parliament, the Council, the Economic and Social Committee and the Committee of the Regions…

Warsaw, 5 December 2022 


Commentary of the Union of Entrepreneurs and Employers on the Communication from the Commission to the European Parliament, the Council, the Economic and Social Committee and the Committee of the Regions. Digitalising the energy system – EU action plan


  • The European Commission has stepped up its efforts to develop a common European energy data space;
  • with the implementation of an appropriate energy data sharing framework, we could gain more than 580 GW of flexible energy resources by 2050;
  • the implementation of the digitalisation will improve the demand for flexibility in the EU’s electricity grids.

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: Digitalising the energy system – EU action plan is a long-developed action plan, formulated and recently submitted by the European Commission for consultation, and intended to define actions for the coming years in the area of digitalisation of the European energy system. The Ministry of Climate and Environment is coordinating the preparation of the Polish government’s position on the proposals set out in the communication. Comments on the document had to be submitted by 23 November this year. We hope, however, that these are not the final provisions of the document, and it will be widely consulted with the public.

According to the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: Digitalising the energy system – EU action plan the EU’s overarching goal for the coming years is to become independent from non-EU fossil fuels. According to the Commission, the only way to achieve this goal is

  • to install photovoltaic panels on the roofs of all commercial and public buildings by 2027 and on all new residential buildings by 2029,
  • to install 10 million heat pumps in the next five years,
  • to replace 30 million cars on the road with zero-emission vehicles by 2030,
  • to reduce greenhouse gas emissions by 55% and to achieve a share of renewables in the energy consumed of 45% in 2030, among other things.

All these objectives can only be achieved if the energy system is ready for it. Energy efficiency, resource efficiency, decarbonisation, electrification, sector integration and decentralisation of the energy system require a massive digitalisation effort. Without digitalising the energy system, it will be difficult, if not impossible, to achieve the goals set by the European Green Deal and the European 2030 programme ”Path to the Digital Decade”.

Between 2020 and 2030, around EUR 584 billion will need to be invested in the electricity grid, particularly in the distribution system. A substantial part of this investment will have to focus on digitalisation, as digital communication with energy consumers will help avoid the need for USD 270 billion investment in new electricity infrastructure.

Modern technology will help to visualise our energy consumption in real time and get tailored advice on how to reduce it. Digital tools can automatically control room temperature, charge electric cars and manage appliances so that energy is used at the same time when prices are at their lowest, while maintaining an optimal and healthy environment at home or at work.

Already 51% of all households and SMEs in the EU use smart electric meters.

The use of data across the energy value chain and linking this data with weather models, mobility patterns, financial services and geographical location systems through increasingly powerful computing capacity will enable the provision of innovative services at new levels of precision and adequacy and contribute to economic growth and job creation in the EU.

With the implementation of an appropriate framework for sharing energy data, more than 580 GW of flexible energy resources that take full advantage of digital solutions could participate in wholesale markets by 2050. It is estimated that this would cover more than 90% of the overall demand for flexibility in the EU electricity grids. Enabling smart and bi-directional charging of electric vehicles, the participation of virtual power plants in energy markets, and harnessing the potential of energy communities, smart buildings and smart heating with the use of heat pumps could contribute most to meeting this demand. In addition, car batteries can be used to store surplus energy and make it available when needed. This is achieved by keeping track of when the vehicle is in the garage, predicting periods of non-use and calculating how much spare capacity can be made available.

The aim of EU actions is to establish a common European energy data space and to ensure its robust governance in the form of a coordinated European framework for sharing and using this data. The preparatory phase is expected to be completed by 2024, with implementation starting immediately afterwards.

The EU’s research, innovation and digitalisation programmes will continue to play a key role in this context. Therefore, the Commission intends to support – through the “Digital Europe” programme – the implementation of a common European energy data space. Actions in this area will build on the demonstrations made by a number of projects funded by “Horizon Europe”.

To further support the digitalisation of the energy sector, the Commission will officially re-establish the existing Smart Grid Task Force (SGTF). Under this smart energy expert group, the Commission will set up, by March 2023 at the latest, the “Data for Energy” (D4E) working group. This group will include the Commission, Member States and relevant public and private stakeholders to contribute to the creation of a European framework for energy data sharing.

The Commission announces in “Digitalising the energy system – EU action plan” that it intends to support EU Transmission System Operators (TSOs) and Distribution System Operators (DSOs) in the creation of a digital twin of the European electricity grid, an advanced virtual model of the grid. The purpose of the digital twin is to make the grid, and with it the energy system as a whole, more efficient and smarter.

The sustainable design of digital devices and clear information on their environmental footprint and reparability and recyclability can, on the one hand, contribute to reducing the use of raw materials and facilitate a shift towards circularity, but on the other hand, can put an additional burden on fossil fuel-based economies.

Collective energy schemes that involve a whole community, village or town can allow such consumers to connect and scale-up their potential interaction with the electricity system. Such schemes can enable communities to, for example:

  • better monitor their performance as measured by energy consumption or
  • share photovoltaic panels or otherwise engage in power sharing or peer-to-peer trading of electricity generated by joint investment projects, which can reduce their dependence on high electricity prices set in the wholesale market.

The proposed framework for an Ecodesign for Sustainable Products Regulation[1] is aimed at:

  • establishing EU regulations to ensure that only “circular” products (i.e. products that are more durable, can be easily reused, repaired and recycled, and are made up of recycled materials as far as possible) are placed on the EU market;
  • creating a framework for digital product passports containing information on energy-related aspects (carbon footprint), among other things; and
  • setting mandatory minimum sustainability requirements on public procurement of products, for a selection of product groups including electronic and ICT products. To address the energy consumption of working ICT devices, the Commission will develop an energy labelling scheme for computers that takes into account the different uses of computers, such as (i) office work, (ii) gaming and (iii) graphic design and video editing, respectively.

The Commission will aim to establish an EU Code of Conduct by 2025, based on the work done to measure the environmental impact of electronic communications services. The EU’s Code of Conduct for the Sustainability of Telecommunications Networks can help guide investment in energy-efficient infrastructure.

Bearing in mind the content of the document submitted to the Union of Entrepreneurs and Employers for consultation, on 23 November this year we sent our proposals to the Department of Informatisation of the Ministry of Climate and Environment. We pointed out that such a wide-ranging document setting out policy directions cannot be over-regulated in terms of the energy transition, as the Polish energy market has its own specific characteristics that distinguish it from other countries on the old continent. On the positive side, there is a proposal to involve entrepreneurs in the work of future advisory bodies. We also emphasised the need to develop electricity grids in the context of problems with connecting new power generation installations.


[1] Proposal for a regulation establishing a framework for the setting of ecodesign requirements for sustainable products and repealing Directive 2009/125/EC, COM(2022) 142 final.

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