Source - Submetering for Flexibility Services Comillas (2024)

Academic journal article on submetering — dedicated measuring devices (DMDs) installed on individual circuits or appliances behind the customer connection point — as enabling infrastructure for flexibility services. Covers EU regulatory basis, international practice, a BeFlexible practitioner survey, and technical requirements for flexibility-grade measurement. Part of the BeFlexible Horizon project.

Bibliographic details

• Title: “Submetering: Challenges and opportunities for its application to the flexibility services”
• Authors: Chaves, J.P.; Davi-Arderius, D.; Troughton, J.; Cianotti, I.; Gallego, I.; Faure, M.
• Institutions: Comillas (IIT), Enel, Iberdrola
• Journal: Current Sustainable/Renewable Energy Reports
• DOI: 10.1007/s40518-024-00235-8
• Year: 2024 (published online)
• Funding: BeFlexible project (EU Horizon, grant no. 101075438)
• Raw file: raw/submetering-extracted.txt

Summary

Reviews the role of submetering as measurement infrastructure for flexibility services, establishing the EU regulatory hook (Art. 7b EMD Reform Regulation 2024/1747), surveying international practice, reporting BeFlexible practitioner survey results on current use and barriers, and specifying technical requirements for flexibility-grade DMDs. Introduces the conceptually useful distinction between settlement-grade and indicative-grade submetering, and notes Sweden as a country with existing submetering pilots for DSO congestion management.

Key claims

EU regulatory hook: Art. 7b EMD Reform

Art. 7b of Regulation 2024/1747 (Electricity Market Design Reform Regulation, in force July 2024) introduces a customer right to install dedicated measuring devices (DMDs) for individual circuits, loads, or appliances. Key points:

• DMDs are distinct from smart meters: smart meters measure total consumption at the connection point; DMDs measure specific loads behind the meter (EV charger, heat pump, battery, specific industrial circuit)
• Art. 7b creates the EU legal basis; implementation rules (technical standards, data format, access rights, cost recovery) remain pending at member-state level
• The right is for customers and aggregators to install DMDs, not a DSO obligation to provide them

Why submetering matters for flexibility

Without a DMD, a DER sharing a connection point with other loads is functionally invisible to the market. The whole-building meter sees only aggregate consumption. Submetering enables three things:

1. Attribution — identifying which specific DER contributed what to a flexibility dispatch
2. Baseline accuracy — actual pre/post consumption for the specific device, not a whole-building average prone to confounding load changes elsewhere in the building
3. Small DER participation — making individually sub-threshold resources (a single EV charger, a small battery) observable, verifiable, and market-eligible; enabling aggregators to verify DER-level dispatch without modifying DSO metering infrastructure

This connects to the independent aggregator role (Aggregation): the aggregator can contract with and dispatch individual DERs in multi-DER premises without needing access to the DSO’s metering data.

BeFlexible practitioner survey findings

Current use of submetering for flexibility is limited — most DSO pilots rely on whole-building meters or proxy measurements.

Key opportunity identified by practitioners: submetering enables aggregators to verify DER-level dispatch without modifying the DSO’s AMI infrastructure — keeping the aggregator and DSO layers technically separate.

Most practitioners see submetering as a short-term enabler bridging the period until next-generation smart meters with sub-circuit reading capability are deployed at scale.

Technical requirements for flexibility-grade submetering

Settlement-grade vs indicative submetering — key conceptual distinction

Settlement-grade: tamper-proof, calibrated, legally defensible for billing and settlement; highest cost and compliance burden; regulated metering standards apply.

Indicative: sufficient for flexibility verification and baseline calculation; lower accuracy requirements; appropriate for most flexibility service applications.

Policy implication: most flexibility applications need indicative-grade only. Requiring settlement-grade for all submetering would impose disproportionate costs and slow adoption. Regulatory frameworks should distinguish the two tiers explicitly.

International practice and Swedish context

• Sweden: noted as having existing submetering pilots for DSO congestion management; pilots are DSO-initiated rather than customer/aggregator-initiated, raising data ownership questions; the next-generation AMI reform (Ei smart metering) is the context within which submetering must fit
• UK: Ofgem trials; some regulatory allowance for DMDs in certain BSC contexts
• Spain: limited regulatory allowance
• Cross-national pattern: practice is heavily concentrated on whole-building meters even where submetering would be technically beneficial

Relevance to wiki

Directly enriches:

• Baseline Methods — submetering as enabling infrastructure for attribution accuracy in mixed-DER portfolios; settlement-grade vs indicative distinction is directly applicable to method selection
• Aggregation — Art. 7b as the EU right that enables aggregators to measure DER-level dispatch independently; links to NC DR single-CU site registration concept
• Network Code on Demand Response — Art. 7b feeds into NC DR baseline and settlement framework; DMD right is part of the regulatory package NC DR T&C must reflect
• Electricity Market Design Reform 2024 — Art. 7b is part of Regulation 2024/1747; this source provides the full treatment of that article
• Distribution System Operator — data ownership: when DSOs control AMI and customers/aggregators install DMDs, access and governance questions arise

New concept page created: Submetering

Data gaps

• Swedish regulatory implementation status of Art. 7b DMD right — has Ei issued guidance or included DMDs in its smart metering reform work?
• Cost benchmarks for DMD hardware and installation in Swedish residential context
• Which Swedish DSO flexibility pilots use submetering, and for what specific flexibility application?