Αρχική ΕΚΣΥΓΧΡΟΝΙΣΜΟΣ ΤΗΣ ΑΔΕΙΟΔΟΤΙΚΗΣ ΔΙΑΔΙΚΑΣΙΑΣ ΑΝΑΝΕΩΣIΜΩΝ ΠΗΓΩΝ ΕΝΕΡΓΕΙΑΣ -Β’ ΦΑΣΗ, AΔΕΙΟΔΟΤΗΣΗ ΠΑΡΑΓΩΓΗΣ ΚΑΙ ΑΠΟΘΗΚΕΥΣΗΣ ΗΛΕΚΤΡΙΚΗΣ ΕΝΕΡΓΕΙΑΣ, ΠΛΑΙΣΙΟ ΑΝΑΠΤΥΞΗΣ ΚΑΙ ΕΙΔΙΚΟΤΕΡΕΣ ΔΙΑΤΑΞΕΙΣΜΕΡΟΣ Β’ – ΕΚΣΥΓΧΡΟΝΙΣΜΟΣ ΤΗΣ ΑΔΕΙΟΔΟΤΙΚΗΣ ΔΙΑΔΙΚΑΣΙΑΣ ΑΝΑΝΕΩΣΙΜΩΝ ΠΗΓΩΝ ΕΝΕΡΓΕΙΑΣ – Β’ ΦΑΣΗΣχόλιο του χρήστη Fabian Hafner (Tesla) | 10 Μαΐου 2022, 17:56
  • Σχόλιο του χρήστη 'Fabian Hafner (Tesla)' | 10 Μαΐου 2022, 17:56

    Article 59: Definitions The definition of “(p) Energy Efficiency/Demand management” lacks a notion of self-consumption. Self-consumption, for example on residential buildings, should be treated as a means to reduce the final demand of energy of that building. It therefore contributes to the efficiency of that building. By that way, for example on-site PV applications can serve as an alternative to building insulation. Precedent can be found in Germany, for example. The definitions lack a definition for “fully integrated network components”. Given that the European Union had designed Art 54 of the (EU) Directive 2019/944 as an exception to a service-based understanding of storage (as opposed to an asset-based approach), the use case for a “fully integrated network component” should be defined by law with a positive list of applications. Article 61 and 62: Taxes, fees and levies Article 60 and 61 only regulates stand-alone storage and misses the important case of self-consumption for co-located storage alongside a renewable energy source (“prosumers”). This use case is relevant for residential storage with rooftop PV, as well as large scale industrial prosumers. In this case, storing self-produced renewable energy for the purpose of consuming the electricity later should be exempt from any taxes, fees, and levies. Especially for generators below 30kWp, this is set out in the provisions of the (EU) Directive 2018/2001, Article 21. The value of prosumer self-consumption becomes apparent in areas of high solar irradiation such as Greece, where network constraints and excess PV generation will arise quickly. Article 63: Grid Charges To incentivize flexibility and system-efficient storage bahaviour, dynamic network charges should reflect the scarcity of grid capacity at all times. This means that unit charges should vary by the time of the day and the level of grid utilization. We suggest mentioning the dynamic element more explicitly in the request to RAE to define the calculation methodology of use and access tariffs. It also should be noted that excessive grid access payments (based on power) do not sufficiently pay tribute to the ability of storage to reduce stress on the grid. Grid access costs are a static price component which are independent of when the grid is being used. We explicitly support the proposed tariff regime where storage is charged only to the extent that it contributes to the formation of the peak of the electricity grid system. Article 64 – Ownership of Energy Storage Facilities Generally, Article 109A should refrain from tendering a storage asset but rather aim at tendering a specific storage use case. To maximize efficiency, storage should never be utilized for a single use case but rather be able to address multiple energy services at the same time. Furthermore, Article 109A does not mention the right for third party storage operators to operate the tendered storage asset use case alongside other market activities. Successfully tendered storage assets should have this option to increase efficiency and ultimately decrease the cost of the asset. Concerns of market dilution can be dispersed if the tendered storage use case is described in detail within the tendering material, so market players will factor in market revenues and accordingly lower their bid. Finally, Article 109A 2. (ba) insufficiently specifies the term “reasonable cost”. It should be clarified that these costs should not be deemed “reasonable” based on the assessment of the TSO. Given easier access to capital markets, regulated entities cannot be compared to market players and comparisons between the two types of bidders would be skewed. Article 70, 71, 72 and 110: Licensing and permitting framework Tesla finds the licensing and permitting regime to be a well-defined and designed framework. It should be noted that strict permit conditions in terms of revenues studies and technical competence might lead to an exclusion of smaller developers but provides a higher chance of project completion. In light of tight deadlines set out by EU financial support frameworks we see the proposed requirements to be justified to ensure fast deployment.