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Legal Regulation of Electrical Energy Storage Systems
 
PIIS231243500022359-2-1
DOI10.18254/S23124350021650-7
Publication type Article
Status Published
Authors
Konstantin V. Moskvin 
Affiliation: JSC SO UES Compliance Department
Address: Russian Federation, Moscow
Journal nameEnergy law forum
EditionIssue 3
Pages66-70
Abstract

Electrical energy storage systems contribute to the integration of generating facilities operating on the basis of the use of renewable energy sources into the energy system, the gradual decommissioning of traditional generation equipment, optimization of the cost of energy supply, ensuring reliable and sustainable operation of the energy system. The Energy Strategy of the Russian Federation for the period up to 2035 provides for the need to ensure energy storage systems for the circulation of electrical energy (capacity) and the provision of related services. However, fundamental issues related to the legal status and qualification of storage systems as a separate type of equipment remain open. The paper presents approaches to changing the regulations of the Government of the Russian Federation in order to establish the legal regulation of electrical energy storage systems.

Keywordsenergy law, energy strategy, laws on electrical energy industry, electrical energy storage systems
Received30.06.2022
Publication date30.09.2022
Number of characters18404
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1 The objective of the electrical energy industry within the framework of the Energy Strategy of the Russian Federation for the period up to 2035 is to increase the reliability and quality of energy supply to consumers to a level comparable to the best foreign analogues, while ensuring the economic efficiency of such services [1].
2 In accordance with the action plan for the Energy Strategy implementation, in order to solve this problem, it is necessary to ensure the involvement of electrical energy storage systems (hereinafter the “EESS”) in the circulation of electrical energy (capacity) and the provision of related services [2].
3 The preparation of a regulation of the Russian Government aimed at establishing the legal grounds for the participation of EESS owners in the trade of electrical energy and/or electrical capacity in the wholesale market and retail electrical energy markets is also provided for by the updated action plan (roadmap) to improve laws and eliminate administrative barriers in order to ensure the implementation of the EnergyNet National Technology Initiative [3]. The specified regulation must contain the concept of ‘electrical energy storage system’ and ‘electrical energy storage system owner’.
4 Currently, the industry has developed a situation in which projects related to the integration of EESS into the energy system are already being implemented by market participants (large-scale launch of storage systems in the regions of presence of PJSC Rosseti Center; implementation of the ‘EESS-Based Commercial Dispatching’ Pilot Service Project by RENERA LLC and JSC Atomenergopromsbyt; development of an innovative hybrid energy storage system by PJSC RusHydro, an increase in the cases of operation of EESS as part of generating facilities operating on the basis of the use of renewable energy sources).
5 At the same time, the conceptual issues of the legal status and qualification of storage systems as a separate type of equipment remain open.
6 In accordance with Article 3 of the Law on the Electrical Energy Industry [4], electrical energy facilities include facilities directly used in the process of generation, transmission of electrical energy, operational dispatch control and sale of electrical energy, including electric grid facilities.
7 The functions of EESS in the electrical energy industry differ depending on their use by the electrical energy industry entities that own electrical energy generation facilities or electric grid facilities.
8 For generating companies, the EESS, located within the boundaries of the balance ownership of the electrical energy generation facility, is able to increase the efficiency of the power station, and the accuracy of the load schedule. The storage system can be part of a ‘system’ power station, a small or local station, as part of a generating facility operating on the basis of the use of renewable energy sources (SPS/WPS) [5].
9 For electrical energy generators, EESS are attractive due to their wide control range compared to power units of thermal power stations, substitution of peak generation, the possibility of optimizing fuel costs, maneuverable power for NPS, SPS, and WPS [6].
10 The use of EESS by a grid operator can improve the reliability of power supply, reactive power compensation, compensation of higher harmonics, reduce losses in grids, and increase equipment throughput capacity. A typical situation for the use of EESS by a grid operator is to cover the peaks of an overloaded substation during periods of maximum loads, that is, peak loads that occur at certain hours and periods, to provide a backup power source in the event of an accident according to the N-1 Criterion (covering the peak load in the event of a transformer failure during the peak period).
11 In general, the use of EESS in the electrical energy industry also contributes to the integration of generating facilities operating on the basis of the use of renewable energy sources into the energy system, the gradual decommissioning of traditional generation equipment, optimization of the cost of energy supply, ensuring reliable and sustainable operation of the energy system.
12 It should be noted that an EESS includes the following three main elements:
13
  • Li-ion storage subsystem (specifically, stands with storage cells that store energy);
14
  • Conversion subsystem (inverter); and
15
  • Control subsystem that allows you to control the state of the EESS subsystems and transmit information about their current technical condition.
16 The above elements of the EESS are technologically connected by a process that ensures the storage of electrical energy for the purpose of its subsequent use (delivery to the power system).
17 The national standard, GOST 58092.1-202, states that an electrical energy storage is an installation capable of absorbing electrical energy, storing it for a certain time and giving off electrical energy, during which energy conversion processes can occur. In turn, an EESS is defined as an electrical installation with certain boundaries, including engineering structures, energy conversion equipment and related auxiliary equipment connected to the electrical network, including at least one electrical energy storage (ESS) that extracts electrical energy from the electrical energy system, stores this energy inside itself in some form and gives it back to the electrical energy system.

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1. Russian Government Decree No. 1523-r, dated June 9, 2020, “On Approval of the Energy Strategy of the Russian Federation for the period up to 2035”. Collection of Legislation of the Russian Federation, June 15, 2020, No.24, Article 3847.
2. Russian Government Decree No. 1447-r, dated June 1, 2021, “On Approval of the Action Plan for the Implementation of the Energy Strategy of the Russian Federation for the period up to 2035”. Collection of Legislation of the Russian Federation, June 14, 2021, No. 24 (Part II), Article 4530.
3. The Action Plan (Roadmap) for Improving Laws and Removing Administrative Barriers in Order to Ensure the Implementation of the EnergyNet National Technology Initiative, approved by the Russian Government Decree No. 402-r dated March 3, 2022. Collection of Legislation of the Russian Federation, 2022, No. 11, Article 1725.
4. Federal Law No. 35-FZ, dated March 26, 2003, “On Electrical Energy industry”. Collection of Legislation of the Russian Federation, March 31, 2003, No. 13, Article 1177.
5. Application of Energy Storage Systems in Russia: Opportunities and Barriers (expert and Analytical Report of the EnergyNet Infrastructure Center), Moscow, 2019. Available at: https://www.eprussia.ru/upload/iblock/1b8/1b83729ddd27beaeb629e380293a4585.pdf 
6. All-Russian Conference “Industrial Electrical Energy Storage Systems”. Available at: https://www.youtube.com/watch?v=gyngcMs3cwo  [Accessed May 22, 2022].
7. Electrical Energy Systems. Training Manual for Dispatching Personnel. Under the general editorship of M.N. Govorun, the chief dispatcher of JSC SO UES. Moscow, ENERGY TECHNOLOGIES, CJSC, 2021.

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