Energy Storage NL: NFA proposal creates uncertain business case for batteries
The ACM has recently organized a broad consultation around the proposal of Alternative Transport Rights and 'Use It Or Lose It' (UIOLI). In this proposal, the contract form 'Non-Firm ATO' (NFA) has been further developed. Through an NFA, batteries no longer receive a fixed transmission right, but a flexible transmission right whereby stored electricity may only be fed back to the extent that capacity is available on the grid.
Critical of NFA proposal
Energy Storage NL endorses the thinking behind the consultation proposal from the ACM around the Non-Firm ATO. This is because the industry association for the Dutch energy storage sector is also a strong supporter of promoting efficient grid use. Batteries should also be used to promote efficient grid use. Nevertheless, the industry association sees that the current NFA proposal wants to achieve this by no longer offering transport security to batteries.
The NFA literally means that batteries have "0" transportation rights. This significantly affects the business case for batteries. This is because the revenue side - due to the absence of transport duty - is unpredictable for the short, medium and especially the long term. Energy Storage NL already sees in the current situation that financiers are reluctant to invest in batteries because of unpredictable fixed revenues. Connecting batteries through the NFA thus increases this problem. This will slow down the battery rollout in the Netherlands, while we need to accelerate now!
Energy Storage NL is therefore critical of the current proposal: the benefits of the alternative transmission rights (: escaping the queue and discount on transmission tariffs) are disproportionate to the high risks this form of contract entails due to the uncertain access to the grid.
Joint work on implementation framework
Specific agreements on feed-in must be made between the individual market party and the grid operator based on the current proposal, but this is too unclear and should be framed in advance. The industry association would therefore like to sit down with the ACM and grid operators to jointly work on a clear implementation framework with sufficient certainty. The main priority in this implementation framework is to make concrete long-term guarantees for battery transport - for example, agreements on the maximum number of hours for which a restriction applies - possible in advance. Only then does the industry association expect enthusiasm from market participants for the NFA proposal.
See below Energy Storage NL's entire response to the consultation.
