Submetering for Flexibility Services Comillas (2024)

Academic journal article on submetering — dedicated measuring devices (DMDs) installed behind the connection agreement point — as a complement to smart meters for flexibility services. Covers the EMD reform proposal’s DMD provisions, international practice, a BeFlexible DSO/TSO/retailer survey, and technical requirements for submeters. Part of the BeFlexible Horizon project.

Institutions: Comillas Pontifical University (IIT), e-Distribución Redes Digitales (Enel), Enel X, Enel Grids, i-DE Redes Eléctricas Inteligentes (Iberdrola)

Note: the raw file is a preprint of the journal article

Funding: BeFlexible project (EU Horizon 2020, grant no. 101075438)

Summary

Reviews current use, challenges and opportunities of submeters (DMDs) for flexibility services, in the scope of the upcoming European regulation. The paper cites the EMD reform proposal (European Parliament amendment text), not the adopted Regulation 2024/1747, and gives no article number for the DMD provisions. It sets out potential added value and technical requirements, reviews practice in seven jurisdictions, and reports a BeFlexible survey of DSOs, a TSO and a retailer. Conclusion: submeters can foster participation of small resources, especially where smart meters are not deployed or do not deliver the needed data, but standardization, certification, interoperability, data accessibility and reliability must be addressed; international experience is still limited.

Key claims

DMDs in the EMD reform proposal

• The paper describes the EMD reform proposal as introducing submeters as dedicated measuring devices (DMDs): a device linked to or embedded in an asset that provides flexibility services (e.g. demand response) to the market or to system operators.
• Where final customers have no smart meter, or the smart meter does not deliver the detail needed to measure demand response or flexibility services, TSOs and DSOs should, upon customer consent, use DMD data where available to settle flexibility services. Member States shall set DMD data validation requirements, including interoperability. Independent aggregators and other market participants may also use DMD data upon customer consent, subject to the Data Regulation (EU) 2023/2854.
• The definition of DMD does not prevent use of the data for other processes, e.g. local energy communities.
• Smart meters record flows at the connection agreement point (CAP); submeters monitor one or more flexibility resources (FR) behind the CAP. Submeter data should ultimately be consistent with the main meter, since the delivered flexibility, from the grid’s viewpoint, is the change of flow at the CAP. Submeter data excludes flows from other devices and losses behind the CAP (cables, transformers, inverters).
• Regulation (EU) 2023/1162 (metering-data access and interoperability) applies only to regulated meters, not submeters, so widespread submeter use needs new norms and standards.

Article-level treatment of the adopted text (Art. 7b of Regulation 2024/1747) is in Source - Electricity Market Design Reform Regulation (EU 2024-1747), not in this paper.

Potential added value (paper’s Table 2)

Submeters can help FSPs identify FR behaviour patterns for bids, improve baseline calculation complementary to CAP baselines, and enable real-time monitoring during delivery to minimize ex-post penalties. For SOs they can add observability, load-forecasting accuracy and planning value, under customer consent. The paper maps added value to five processes: product prequalification, baseline calculation, monitoring, activating, and observability/settlement of delivered flexibility.

Technical requirements (paper’s Table 3)

Standardization and certification; metrological requirements (in general the same as smart meters, at least for the same functionalities); data interoperability (standard formats and protocols, minimize vendor lock-in); secure data exchange and management (GDPR, authentication, consent, cybersecurity); data accessibility; affordability (hardware, communication and data-processing costs, plus procurement, installation and maintenance); reliability (traditionally DSO-owned metering gives standardized, reliable processes). The paper states no numeric thresholds (no sampling-rate, latency or protocol requirement).

Open issues the paper lists: losses between CAP and submeter, data validation and correction, time synchronization between smart meter and submeters, availability of submeter data for imbalance adjustment and settlement, GDPR responsibility, and customer willingness to accept installation. A new DMD operator role is also needed. The paper notes that unreflected use of submeters already compromises measurement, e.g. validating balancing services (an IBM audit of Elia’s Transfer of Energy process is cited).

International practice (paper’s Table 4 and Section 3.1)

• Explicitly specified in national regulation: UK, Belgium, France (also Portugal for EV chargers); allowed by exception or absent explicit rules: Australia, New Zealand.
• Australia: FCAS markets; provider must request AEMO approval to use submeters; metrological requirements specified, certification not.
• New Zealand: Transpower’s Instantaneous Reserve terms are silent on meter location, which opens the door to submetering.
• UK: Capacity Market, Balancing Mechanism and ancillary services; the CM requires documentation and manufacturer test certificates and allows on-site audits; BM code change P375 allows submeters to measure responses to dispatch instructions, with a new metering code of practice for cheaper meters in small assets; Elexon does statistical monitoring of asset independence.
• France: RTE pilot June 2021 to December 2023 on submetering for aggregator load reductions in the NEBEF mechanism.
• Belgium: Elia allows submeters in the Strategic Generation Reserve and Strategic Demand Reduction, with 15-minute active-power monitoring; the cited audit notes paid activations may not have caused a net load reduction.
• Nordics (Denmark, Finland, Norway, Sweden, Iceland): “in pilots”, small loads. Danish third-party aggregators have used submeters on heat pumps. NordREG regards submeter cost as a barrier, considers aggregators should pay, and recommends a cost-benefit analysis differentiating consumer sizes.
• California: submeters for balancing services and EV time-of-use tariffs. Portugal: submeters in EV chargers for billing under private supply points.
• The paper does not describe the Swedish pilots further, does not say who initiated them, and does not mention Ei or the Swedish AMI reform.

BeFlexible survey (Section 3.2)

• Respondents: DSOs from Austria, Greece, the Netherlands, Italy (two), Spain (two) and Sweden; the Italian TSO; one retailer.
• Current use: at DSO level, submeters are used in congestion management in Austria and Sweden and in voltage control in Austria; balancing services are not forbidden in some countries, e.g. mFRR in Spain. DSO use is described as still limited.
• Expected use: no consensus. Respondents generally consider submeters useful for need forecasting, monitoring and activation; less support for prequalification and bid collection, and least for settlement (only two DSOs see a settlement role).
• Installer: the TSO was chosen by only one participant; attitude to other options mostly positive, but the Austrian DSO did not favour DSO, FSP or manufacturer installing submeters for congestion management or voltage control.
• Requirements: almost all respondents say submeters must meet the same requirements as smart meters for all flexibility services; certification views vary (certification bodies, grid operators, or operator-specified lists); only a few object to submeters being embedded in devices; the majority accept using the smart-meter data infrastructure.
• The survey tables are figure-based (filled/empty circles) and per-respondent counts were not extracted.

The paper does not propose a settlement-grade versus indicative-grade distinction, does not rank cost, regulatory uncertainty and data-management complexity as survey barriers, and does not call submetering a “short-term enabler” pending next-generation meters.

Relevance to wiki

Directly enriches:

• Baseline Methods — submeters as a complement to CAP baselines (Table 2)
• Aggregation — DMD data usable by independent aggregators upon customer consent
• Electricity Market Design Reform 2024 — background on the DMD provision (article-level detail in the 2024/1747 source page)
• Distribution System Operator — DSO congestion-management use of submeters in Austria and Sweden

New concept page created: Submetering