ESNL welcomes draft Capacity Control Contract (CSC) decision and calls for elaboration of market-based fees

Energy Storage NL (ESNL) has submitted its views on the draft Capacity Control Contract (CSC) code decision published by the Authority Consumer & Market (ACM). ESNL endorses the importance of the CSC as an instrument to structurally deploy flexibility from energy storage to relieve grid congestion, but asks the ACM for clarification and adjustments on a number of crucial points.

Key points of the view highlighted:

1. Transparency of process and reimbursement ESNL emphasizes that the value of flexibility must be remunerated in a transparent and market-based manner. It is now unclear to market parties how network operators determine whether an offer is acceptable and where the room for negotiation is in the model contract. ESNL calls on the ACM to work with the industry to establish standard principles for a compensation structure.
2. Effective compensation structure Current fees for non-gas-based flexibility are independent of market prices, leading to uncertainty for operators. ESNL advocates for a fee that partially moves with day-ahead prices and calls for compensation for additional costs, such as transportation costs and missed revenues due to preparatory actions.
3. Clarity on activation and availability of transmission capacity ESNL requests advance clarity on the activation of the CSC and its relationship to other obligations, such as aFRR. ESNL also wants confirmation that the time of reservation will be no later than 07:00.
4. Availability of transmission capacity and technical constraints According to ESNL, it is unclear whether grid operators provide guarantees on the availability of sufficient grid capacity for preparatory actions. ESNL also calls for flexibility in the provision of capacity, as technical limits for battery cooling, among other things, must be taken into account.
5. Contractual status congestion softener ESNL believes that entering into a CSC or an alternative transportation right with a bidding obligation contract should be sufficient to qualify as congestion mitigation without additional contractual conditions.

Call for cooperation

ESNL stresses the added value of the CSC as a new instrument and offers to contribute its expertise in the further elaboration of the final decision. The organization calls on the ACM to stay in close contact with the industry during implementation so that the CSC can be used effectively and transparently.

The full view can be read here