Legal Status And Licensing Processes Of Electricity Storage Facilities

Introduction

The weather-dependent and intermittent generation profile of renewable energy sources creates serious technical challenges in maintaining the instantaneous balance between supply and demand across electricity transmission and distribution grids. Playing a pivotal role in ensuring grid flexibility and mitigating frequency oscillations, electricity storage facilities display the characteristics of a generator when injecting energy into the grid, and a consumer when withdrawing energy from the grid for storage purposes. Positive energy law has historically been built upon a rigid fourfold vertical division consisting of generation, transmission, distribution, and consumption; this framework falls short of accommodating the bidirectional physical and commercial dynamics of storage. Failure to properly position this sui generis nature within the legislation gives rise to the issue of "double charging and double taxation"—where stored electricity is repeatedly subjected to