EASE Student Award Winner 2024 Alexandre Rossignol

The European Association for the Storage of Energy (EASE) is proud to announce the winner of the 2024 edition of the EASE student award: Alexandre Rossignol.

Congratulations on winning the 2024 EASE Student Award! We were very impressed with your thesis on ‘Electricity Storage and the Mutation Electricity System’. Could you summarise the main focus and findings of your thesis?

Thank you for your support! It’s a great pleasure to receive this award! The thesis I defended in December 2023 at Paris Dauphine-PSL University analyses the legal framework applicable to electricity storage and proposes legislative changes to remedy the structural and functional brakes identified, to promote the efficient development of storage in France and Europe.

Clean Energy Package marked a major step forward, fully recognizing electricity storage. However, problems persist: inadequate legal rules, the absence of clear objectives and many interpretations. Numerous provisions remain focused on electricity production and consumption, with no explicit mention of storage, creating the risk of divergent interpretations and legal uncertainty for storage. The storage operator is the only power system operator that has not been legally defined. Why? Furthermore, the legal framework for network access is not fully adapted. European technical regulations, such as the Requirements for Generators (RfG) and Demand Connection Code (DCC), are not designed for storage or even exclude it. Finally, economic and political obstacles remain. Balancing markets are not fully open to storage operators, and costs such as dual network tariffs and taxation hamper their viability. Electricity stored and reinjected can be taxed twice, threatening the storage business model.

What are the most interesting insights from your work for the storage sector specifically?

The thesis showed that, despite recent legislative progress in the field, there are still fundamental issues to be resolved. For example, the very identification of electricity storage. You can’t build a solid legal framework for an activity without clearly defining it. In this context, I have been able to demonstrate that, according to the rules of the internal electricity market, the storage operator can be considered neither as a consumer nor as a producer, but as a distinct operator. This clarification is crucial to build the legal framework for electricity storage.

I have also shown that there is nothing in the current rules of the internal market to prevent the creation of a specific network tariff for electricity storage. Furthermore, it has been demonstrated that double taxation of electricity for storage facilities runs counter to EU law. These elements are crucial, as they have a direct impact on the business model for electricity storage. If the public authorities were to take these observations into account, this could encourage the development of storage facilities, which is vital to the success of the energy transition.

How did you get interested in the storage sector? What drove you to select this topic as your thesis?

That’s a question I’ve often been asked! With a keen interest in the field of energy, I decided to pursue my studies at the Université Paris 1 Panthéon-Sorbonne, enrolling in the Master in Energy Law. During my class in electricity law, I often heard that because electricity cannot be stored, the electrical system had to be constantly in balance. Intrigued by the fact that electricity cannot be stored directly, I began researching energy storage. Like any curious legal practitioner, I noticed the absence of a suitable legal framework in this field. Thus, was born the object of my research. To bring my project to fruition, I sought to engage in research funded by a company specializing in electricity storage. EDF, as the world’s leading operator of storage facilities and second largest electricity producer, was very interested in my subject and offered to fund my research, via a system called “CIFRE”.

You state that, for a long time, public authorities did not focus on storage. Has this changed? Why?

With the development of renewable energies, the need for flexibility increases considerably. For example, storage requirements are set to increase sixfold by 2050! Added to this are geopolitical tensions that directly affect the energy sector. The war in Ukraine has made public authorities aware of the need to accelerate the development of renewable energies in order to reduce Europe’s dependence on gas. This further reinforces the importance of developing flexibility solutions, such as storage, to manage the intermittency of these energy sources.

Today, awareness of the importance of energy storage is clear, with significant legislative advances. Since the adoption of the Clean Energy Package in 2019, the texts amending the rules of the internal electricity market (Regulation 2024/1747, Directives 2024/1711 and 2023/2413) as well as the draft Network Code on Demand Response, include several provisions relating to energy storage. This represents substantial progress. At an operational level, public authorities are introducing support mechanisms dedicated to electricity storage. In particular, France and Italy have set up specific calls for tenders to support storage. France is also considering special support for pumped hydro-electric energy storage (PHES).

You highlight that oftentimes energy storage is subjected to double charging of grid fees, hindering the business case. What do you think could be a feasible solution?

Regulation 2019/943 introduced a new principle : “The network charges shall not discriminate either positively or negatively against energy storage”. An irrelevant difference in treatment between storage operators and another category of users would therefore be contrary to the principle of non-discrimination. Article 18(1) of Regulation 2019/943 do not exclude the establishment of sui generis network charges for electricity storage. These provisions merely state that the regulatory authority shall ensure that these charges do not discriminate, either positively or negatively, against storage compared with other network users. Consequently, considering that these provisions exclude the introduction of a specific network tariff for storage is not in line with the spirit of Regulation 2019/943. Although the Article 18(1) of Regulation 2019/943 state that network charges must reflect the costs generated by each network user, the principle of cost reflectivity does not preclude the introduction of charges that aim to ensure a fairer approximation of the costs generated by certain network users.

The rules governing the internal electricity market would require the regulatory authority to strike a balance between different tariff principles. Consequently, sui generis network tariffs for storage could be established, if they guarantee to varying degrees the network tariff principles set out in Article 18(1) of Regulation 2019/943. In this respect, it should be remembered that electricity storage provides flexibility services and guarantees the security of the electricity system.

Several solutions can be considered. In Europe, a movement has been underway in recent years. Germany has put in place a specific regime that allows electricity storage facilities to be exempted from transmission and distribution systems tariffs for 20 years (absorption charge). French energy regulatory authority, the “Commission de Régulation de l’Énergie”, is currently considering a specific network tariff for storage facilities.

What are your future career plans? Do you see yourself working in the storage sector?

I recently joined the Legal Department of RTE, the French electricity transmission system operator. I’m delighted to be working for a company at the heart of the transformation of the French and European electricity systems. As such, I’m still very much involved in the flexibilities sector, since I’m involved in issues relating to interconnector, renewable energy planning, networks and flexibilities requirements. This puts me right at the heart of the legal issues surrounding flexibilities!

Disclaimer

Université Paris Dauphine-PSL does not intend to give any approval or disapproval to the opinions expressed in this thesis and article ; these opinions must be considered as the author’s own. EDF does not intend to give any approval or disapproval to the opinions expressed in this thesis and article ; these opinions must be considered as the author’s own. RTE does not intend to give any approval or disapproval to the opinions expressed in this thesis and article ; these opinions are to be considered as the author’s own.

Thank you for your interview with EASE. Congratulations again on the award, and good continuation in the energy storage field!