Our improvement proposals to Austria’s implementation of renewable energy communities

Austria is currently working on implementing the EU directive 2019/944 regulating the EU electricity market. The draft for the related Austrian law which contains legislation for renewable energy communities, named “Erneuerbaren-Ausbau-Gesetz” (EAG), was published a few weeks ago on the website of the parliament.
The Austrian legislative procedure allows the public to comment on such draft laws and to propose specific changes. We have made use of this opportunity and made 3 such change proposals:

1. Grid operators need to answer requests about where in the grid a requesting entity is located.
   We proposed a change which would require such requests to be answered without delay in a machine readable way. The idea here is that interested entities should be able to figure out easily and without long waiting for a response (e.g. with one click) if they could join a specific (planned or existing) renewable energy community.
2. The clarifying comments to a paragraph suggested that any change in the configuration of a renewable energy community may require the founding documents to be updated. This could result in a slow, bureaucratic and expensive process – depending on the legal form chosen by a renewable energy community.
   We propose a change which would be more specific about requiring all necessary information to be documented either in the founding documents or in contracts between the organization and its members. Additionally we propose that renewable energy communities should provide information relevant for grid operators in machine readable form, in order to allow for the implementation of fast, efficient and automated processes on the side of grid operators.
3. Grid operators are required to provide their customers with their usage data.
   We propose an addition which would require that data provision to be free and through an digital interface, with machine readable data.

The proposed change in full detail can be read in this PDF (German).

The draft law contains many more paragraphs which are probably not perfect, but we wanted to focus on a few which we deem most important in order for this law to become a useful instrument. The common topic of our improvement proposals was language that mandates use of digital technology. We’re worried that without such language, at least some system participants may implement the required processes in a way which would make it slow and cumbersome to form and grow renewable energy communities, resulting in this model to have less appeal and thus gain less adoption.
We believe that using digital tools for building such systems would benefit all involved parties and thus hope for our suggestions to be picked up.

In general we believe that legislation should start to mandate the use of digital technology much more and even go a step further and mandate or at least recommend specific open protocols and standards where those exist, in order to improve interoperability and in order to get the efficiency gains enabled by digitization.