The Institute for Renewable Energy sent a position to the Senate on the currently pending amendments to the act on renewable energy sources. While the debate on changes to the rules in prosumer billing focuses on the need to launch investments in home electricity storage, IEO emphasizes the need to pay more attention to energy storage, such as hot water buffers. At the same time, the Institute defends the necessity to change the rules of prosumers’ settlements.
In its position on the changes to the rules of prosumers’ settlements, which appeared in the amendment to the act on renewable energy sources adopted by the Sejm and currently being processed by the Senate, the Institute for Renewable Energy emphasizes that the need to implement new regulations – in line with EU law – was obvious from 2016.
Apart from the draft of the Winter Package, the Commission regulation (the so-called NC RfG) of 2016 was known, indicating the possibility of disconnecting prosumer installations from the grid in the event of exceeding the voltage levels, and since 2018 the content of the RES and market directives were known, which make it impossible to settle the energy introduced by a prosumer to the network and downloaded from the network at the same price – we read the position of the Institute.
IEO emphasizes that the current provisions of the RES Act are inconsistent with the directive, inter alia, because they do not give the prosumer the right to sell surplus energy, while EU regulations indicate that in the event of exceeding the installed capacity in prosumer installations above 15 percent. power in the National Energy System (such a situation will take place in Poland at the end of this year), the legislator in a Member State may stop supporting prosumers.
– Therefore, it is difficult to have general objections to the governmental draft amendment to the WEU only in this narrow scope, the more that (so far) it does not undermine the principle of rights acquired by current prosumers. For the prosumers themselves, the greatest risk of not changing the regulations and developing the prosumer market under the current rules is the risk of shutting down their installations at production peaks (in accordance with the NC RfG regulation), and therefore the system of accounting for energy from micro-installations should be changed. – assesses the IEO.
At the same time, IEO adds that reservations may be raised by “neglect and late commencement of work on the implementation of the relevant provisions into the national law (no previous discussion) and the “ambitious” implementation method – selling surplus energy every hour at the current electricity price specified at the day-ahead market quotation session ”.
Assessing the current discussion on the changes in the rules of prosumers’ settlement, IEO points out that the blockades are in different places than indicated by the current course of the debate.
The Institute led by Grzegorz Wiśniewski emphasizes the need to amend the Energy Law by imposing on the operator companies (DSOs) a new legal obligation to perform the transmission capacity assessment defining the possibility of connecting new consumers and distributed sources at the level of all nodes and medium voltage (MV) stations, taking into account peak load periods in summer and winter peaks and power quality at the points of delivery.
According to the IEO, it is also necessary to promote the installation of heat storage tanks in the homes of prosumers as electric boilers with hot water storages “allowing for very cheap storage of surplus energy during the day and longer ”.
In this context, the Institute proposes to change the definition of energy storage, which, according to the IEO, is currently inconsistent with the EU directive as it applies only to electric batteries – and to promote seasonal storage in heating plants. In this way, it is to be possible to transfer the “peaks” of the solar generation during summer to winter, when the energy can be used for heating.
At the same time, in the opinion of the Institute, it is necessary to introduce multi-zone and dynamic tariffs as soon as possible, which results from the EU market directive – and which, in the opinion of IEO, additionally justifies and makes the above solutions less expensive.
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