Energy Storage NL warns: ACM feed-in tariff should not undermine value of energy storage

The ACM announced this week to further elaborate on the gradual introduction of the feed-in tariff. With this, the ACM is responding to the consultation on the feed-in tariff, which ran through the end of 2025. Energy Storage NL emphasized then that an input tariff should not provide an incentive that discourages the deployment of energy storage or leads to less system-efficient behavior. The ACM says it will take these signals from market participants into account in its further elaboration.

ACM sees added value of system efficiency and level playing field

The ACM wants to introduce the feed-in tariff for large feeders in stages starting January 1, 2032. In particular, the tariff should provide the incentive for efficient use of electricity from large generators. Energy Storage NL endorses the importance of careful use of electricity. Energy storage can help with this by storing generation at appropriate times and feeding it in later. At the same time, it is crucial that the feed-in tariff does not lead to less feed-in due to excessively high costs, because that could actually be at the expense of system efficiency. This leaves the question of how the tariff can simultaneously (i) maintain production and feed-in levels and (ii) stimulate more efficient use.

The ACM says it takes the consultation responses seriously. Energy Storage NL appreciates that concerns about an uneven playing field are included. Alignment of the feed-in tariff with neighboring countries within the EU is important to maintain the Dutch competitiveness of storage and generation as much as possible.

ESNL call: prevent feed-in tariff from undermining social value of storage

In the context of security of supply and the optimal development of a sustainable energy system, ESNL again calls for explicit valuation of the social benefits of storage. The storage sector risks soon paying both high grid tariffs and an input tariff. This double pricing further worsens the investment climate, as storage system costs are expected to increase by 4% to 19%. This could slow the rollout of an important system efficiency measure in the electricity market.

To avoid this, ESNL asks the ACM to investigate whether a separate connection category or a discount within the feed-in tariff is possible for bi-directional systems. It is currently insufficiently transparent how the ACM will incorporate these concerns. EU Directive 2019/944 offers room to explicitly value deferred supply through storage. In the UK, Germany, Spain and Belgium, this space is used to charge storage appropriately. Also from the principle of non-discrimination, it is difficult to explain how to treat storage differently from other techniques, resulting in disproportionate costs.

Considering system efficiency and non-discrimination, as well as calls from Members of Parliament and the European Commission and best practices in other European countries, ESNL calls on the ACM to explicitly consider the potential negative effects of an input tariff on storage. This is important both for storage investments and for the functioning of the electricity system as a whole.