Response to Public Consultations
EASE responded to DG Energy's Public Consultation on a new Energy Market Design.
EASE would like to stress that the future governance framework of the Internal Energy Market needs to incorporate regulatory changes creating a separate asset category and rules for electricity energy storage systems. This is necessary due to their dual generation and demand nature. The new asset category should recognise the contribution energy storage systems will make to system security, loss reduction and the provision of other ancillary services on the T&D networks.
In terms of regulatory oversight and the future role of ACER, EASE thinks the procurement of ancillary services and the way tariffs for transmission network use of system charges are estimated and applied, must also be made transparent across Europe to provide the right investment signals for providers of flexibility (i.e. energy storage and DSR operators).
Read our full response here.
Network Code on Emergency and Restoration
EASE responded to ACER’s call for comments on the Network Code on Emergency and Restoration.
EASE, the European Association for Storage of Energy, calls for a level playing field for all the services energy storage can render to the system:
- through a definition that recognises energy storage as an own asset class in all electricity related regulations and that does not restrict its application to system balancing only;
- through the recognition of energy storage not only as a load but also as a power source capable to contribute to the Frequency Deviation management procedure;
- through a non-discriminatory consideration of and a fair treatment for energy storage at national level alongside other measures.
Read our full response here.
Retail Energy Market
EASE has responded to the Public Consultation of DG Energy on the Retail Energy Market.
Future retail energy markets should take into consideration the following principles:
- goals of increased empowerment of the consumer in a competitive, sustainable and secure energy system should be primarily attained through instruments designed in a market oriented, non-discriminating and technology-neutral manner;
- In particular:
- energy storage constitutes a special and important asset of the complete energy value chain. Therefore the current and future levy structure should not hinder the integration of energy storage;
- the use of energy storage must be technologically neutral: each case must adopt the most suitable technological and economic solution. Therefore any wording in this regards must be open and not technically discriminatory;
- the main challenge is related to the value of energy storage, being it monetary or socio-economic, as it can deliver a number of strategic services both to the regulated and to the deregulated parts of the power industry. Therefore the operator of such devices may differ;
- energy storage will play an important role in new market designs, especially with regards to flexibility markets;
- specific storage regulation and market mechanisms for flexibility in combination with a new market design will help to create energy storage markets and will contribute to the development of a competitive energy storage industry in Europe.
EASE therefore calls for:
- a non-discriminatory consideration of and a fair treatment for energy storage alongside other measures, such as demand side management and the increase of interconnection capacity, when considering possible solutions for enhanced grid flexibility, stability and quality;
- a market design that allows specialised energy storage operators to emerge, as long as this does not trigger market distortion.
Draft Guidelines on environmental and energy aid for 2014-2020
EASE, the European Association for Storage of Energy, welcomes the draft Guidelines on environmental and energy aid for 2014-2020, in particular the recognition that:
- climate and energy policy have become increasingly intertwined;
- a robust state aid control is a must if we are to achieve a well-functioning internal energy market;
- goals of increased environmental protection and a competitive, sustainable and secure energy system should be primarily attained through instruments designed in a market oriented, non-discriminating and technology-neutral manner;
- electricity storage will contribute to provide services and value to the entire energy system.
EASE also takes this opportunity to provide feedback, offer expertise and ask for a level playing field for all energy storage technologies in a constructive dialogue with the European Commission (EC).
The definition of storage should [...] not be restricted and should include a wider concept of Energy Storage, compared to the current reference to Electricity Storage. Different technologies and concepts are included in the concept of Energy Storage and the selection is expected to be mainly based on the device location and on the different services provided by the device. Moreover, the concept and the value of energy storage technologies must be considered comprising its capabilities in transferring energy between sectors (e.g. power to gas, hybrid electric vehicles, heat storage…).
Energy storage allows for the use of more RES by avoiding curtailment when there is too much intermittent generation (e.g. solar photovoltaic and/or wind). This service should therefore be remunerated.
EASE strongly believes that the use of energy storage must be technologically neutral: each case must adopt the most suitable technological and economic solution. Therefore the wording must be open and not technically discriminatory.
EASE [...] calls for:
- Equal consideration of energy storage as a solution for enhanced grid flexibility, stability and quality along with other technologies.
EASE [...] supports:
- a non-discriminatory consideration of and a fair treatment for energy storage alongside other measures, such as demand side management and the increase of interconnection capacity, when considering aid to generation capacity;
- that any measures to ensure generation adequacy, such as potential future capacity markets/payments, or to balance the energy system must be shaped in such a way that every energy storage technology is eligible to participate without discrimination, provided it is able to fulfil the technical requirements.
Click here for the full response.
Network Code on Electricity Balancing
The EASE response to the ENTSO-E public consultation on the Network Code on Electricity Balancing has just been published on our website.
EASE welcomes the Network Code on Electricity Balancing as a tool to foster effective competition, non-discrimination and transparency in markets. It will further help driving the way to a more harmonised pan-European balancing market.
However, EASE does use the opportunity of this public consultation to express some concerns about the points that we consider central in shaping the future balancing market:
- EASE believes that the Network Code on Electricity Balancing should ultimately lead to a harmonised framework for a pan-European Balancing Market. The Network Code should be designed as a driver for this evolution.
- In order to foster the participation of emerging technologies - such as energy storage and demand response - and renewable energy sources, aggregation should be facilitated for both load and generation entities.
- The evolution of the energy system is likely to trigger the need for balancing products with faster response times and particularly more accurate response curves. The Network Code should not hinder the development of products that are capable of delivering such services.
- Obligations for market players to put up their unused capacity for bids in the balancing market may prevent market entry of potential players, thus hindering rather than supporting the intended development of markets and competition. They risk enhancing rather than reducing market distortions.
Read our response here.
Green Paper on a 2030 framework for climate and energy policies
On 27 March 2013, the European Commission published a Green Paper presenting an overview of the issues that must be considered in the development of a 2030 Framework for Climate and Energy Policies.
This Green Paper served as the basis of a stakeholder consultation on the development thereof.
EASE responded to this public consultation and calls for:
- A 2030 framework that provides long term stability and clarity for investors;
- Binding targets for GHG emission reduction;
- A fair market design: the main challenges for energy storage are not only economic and technological but also regulatory as there is no clear EU framework to incentivise the building of storage capacity and provision of storage services;
- The recognition that energy storage is expected to greatly contribute to the achievement of overall socio-economic targets. For instance energy storage technologies not only ease the market and technical integration of variable RES, but also ensure a higher security of energy supply;
- Focused RD&D support for energy storage technologies, which aim at supporting a competitive, low-carbon economy;
- An optimisation of instruments such as the EU ETS to help driving investments forward provided that it can function efficiently (and thus deliver on its principle of a market-based and technology neutral means of CO2 reduction).
Read our response here.
THINK is an FP7-financed project that advised the European Commission (DG Energy) on a diverse set of energy policy topics (June 2010 until May 2013).
EASE responded to a public consultation on Topic 8: "Electricity Storage: how to facilitate its development and deployment in the EU?".
Read our response here.
Renewable Energy Strategy
EASE responded to the public consultation intended to help prepare a Communication to inform the EU's renewable energy policy for the period post 2020. This complements a Communication on the Internal Energy Market also planned for next year which will also help inform the evolution of the EU's wider energy policies following on from the Energy 2050 Roadmap.
Read our response here.