EASE Recommendations for the Ownership of Energy Storage

EASE is happy to announce its recommendations for the ownership of Energy Storage (ES). The European Union should provide a clear legislative framework on ownership for the ES industry in order to support investment in the sector.

The rising share of electricity produced by renewable energy sources (RES) in the EU increases the need for innovation in the electricity grid and the need for new RES integration and flexibility tools, such as ES. The lack of a definition of ownership of ES devices, together with a lack of a broader definition of ES, will have to be resolved in order to allow their use as an ancillary service provider in the electricity system.

EASE has developed five recommendations and is calling upon the EU institutions to take these into account in the upcoming revision of the Renewable Energy Directive, the Energy Efficiency Directive, and especially the New Energy Market design legislation (Winter Package):

• For energy storage applications deemed to be market services, e.g., arbitrage, only market players should be allowed to own or operate energy storage facilities for their provision. The market should reflect the system needs, which would provide for efficient solutions.
• Therefore, one cannot talk about ownership of energy storage by regulated entities in the abstract; instead, positions can be expressed only relative to energy storage applications or services.
• Energy storage applications deemed to be infrastructure services, i.e., fulfilling services which are today already used by regulated entities with other technologies (e.g., by building a line), should be able to be delivered also with energy storage devices.
• Regarding the ownership of energy storage by regulated entities (e.g., for the provision of system services) in the absence of competitive supply, i.e. if shown that a market- based service procurement is not feasible, such ownership should be exceptional and on a temporary basis, subject to a periodic review of the situation. Unjustified market barriers for energy storage should be removed.
• And, as a general rule, regulated entities could be allowed to own energy storage in this context only upon the approval of the relevant national regulatory authority (NRA). In the longer term, the underlying reason for the market failure should be identified and properly addressed.

EASE supports the efforts of the European Commission to reform the energy market in order to create a competitive market place and a level playing field, which, along with a definition of ES ownership taking into consideration the recommendations listed above, will make it fit for ES as an ancillary service provider. Additionally, this will enhance the investment in ES technologies.