The Ministry for Ecological Transition and the Demographic Challenge (MITECO) has submitted to public consultation the project that modifies Royal Decree 738/2015, the regulation that governs the production of electricity and the dispatch procedure in non-peninsular systems.
The reform introduces storage within a regulation originally designed around conventional and renewable generation, but which until now did not comprehensively consider the participation of independent or hybrid batteries, so it defines how bids must be presented, price per charge and discharge, and under what criteria they will be incorporated into the economic and security dispatch.
The main economic signal is directed towards stand-alone installations of more than 0.5 MW and certain hybrid batteries with manageable generation, which will buy the energy needed for their charging at a price equivalent to 25% of the value they have offered for their discharge.
Thus, if a battery has a sales offer of 100 euros per MWh and is scheduled, it will acquire the energy to charge at 25 euros per MWh.
New categories to incorporate batteries into the office
The project modifies article 2 of Royal Decree 738/2015 and expands from two to four the categories of facilities included in the non-peninsular regime.
Thermal plants, dispatchable hydroelectric plants and pumping stations will remain in category A, while non-dispatchable renewables and certain cogeneration facilities will remain in category B.
Two new groups will be added to them.
Category C will cover storage facilities that are not part of a hybrid project, with the exception of pumped storage plants, which will continue to be classified as manageable generation.
Category D will include batteries integrated into hybrid installations and will be further divided into two subgroups.
D0 facilities will be those hybridized with Category A assets, while D1 facilities will correspond to storage associated with Category B facilities, mainly non-dispatchable renewable projects.
This classification will determine both the form of participation in the dispatch and the economic regime applicable to each battery.
Stand-alone batteries will be able to set the discharge price.
Stand-alone storage facilities larger than 0.5 MW must inform the system operator of their hourly availability and the price at which they are willing to discharge energy.
For daily scheduling, intraday scheduling and deviation management, holders will submit a daily offer expressed in euros per MWh the day before.
The weekly schedule must include the corresponding price two weeks in advance.
The system operator will incorporate the batteries into the second dispatch, which combines economic and safety criteria, considering the charging and discharging offers submitted by their owners or representatives.
The scheduling model will seek to minimize the system's variable costs, although it must also maintain a minimum level of generation capable of providing inertia, regulation reserves and sufficient coverage.
Therefore, integrating energy storage will not automatically lead to the decommissioning of thermal power plants. The operator will continue to keep the necessary units connected to ensure the stability of each isolated system.
When a battery is dispatched, it will receive the price it has offered for the energy fed into the grid.
To load, you will only pay 25% of that same value.
The rule will also apply to D0 batteries , hybridized with Category A manageable installations. In these cases, each module of the hybridization will be dispatched and settled independently according to its category.
A different regime for batteries up to 0.5 MW
The project establishes a regulatory separation based on power.
Stand-alone installations up to 0.5 MW will not participate through the same bidding system as larger batteries.
For the energy discharged, they will receive the general hourly selling price applicable in the corresponding isolated system.
When their net balance is a purchase, they will acquire electricity at the hourly price of demand, linked to the average final daily price of the peninsular market and the consumption profile of the non-peninsular territory.
Therefore, the load signal at 25% of the discharge price will be reserved for stand-alone systems exceeding 0.5 MW and for D0 installations.
The difference can be decisive for the design and sizing of new projects, since exceeding that threshold will allow access to the bidding scheme and the regulated arbitration provided for in the reform.
The thermal gap will determine the return on hybrid projects
Batteries associated with category B renewable installations will receive different treatment.
Instead of offering their discharge individually, the D1 facilities will be programmed in a manner analogous to a non-dispatchable renewable plant.
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Its sale price will be calculated based on the peninsular reference and a new factor called thermal gap pointing.
The thermal gap represents the part of the demand that remains after discounting the expected production of category B renewable facilities.
Thus, the economic signal will increase when the system needs to cover a greater proportion of its demand with thermal generation and will decrease when there is a high availability of renewable energy.
The pointing factor will initially have a maximum value of 2 and a minimum of 0.5, although the Directorate General for Energy Policy and Mines may modify both limits by resolution.
D1 facilities will also acquire the energy intended for charging for the equivalent of 25% of its sale price.
With this formula, the Government intends to direct the discharge towards the hours when storage can replace a greater amount of conventional generation.
The permits and the measure will affect the revenue of hybrids
Access to the specific D1 battery regime will depend on the technical and administrative configuration of the installation.
Differential remuneration will only apply when the hybrid project has access permission to consume energy from the grid or, in the absence of that permission, has verified measuring equipment for each of its modules.
When a facility without access for consumption has a single meter for the entire complex, the remuneration will be applied to the combined net production of the plant.
In that case, the regulation will not fully distinguish between the energy produced directly by the renewable installation and the electricity subsequently discharged by the battery.
The measurement architecture and the scope of access permission thus become variables capable of modifying the revenues of hybrid projects.
Insufficient revenue will be recognized as an extra cost.
The reform also introduces a guarantee for storage settlements.
When the income obtained through the sale of energy in the dispatch is not sufficient to cover the collection rights of the batteries, the outstanding balance will be considered an extra cost of the production activity in the non-peninsular territories.
The mechanism reduces the exposure of the holders to the risk that the firm's ordinary resources will not be sufficient to cover all settlements.
This also implies that part of the cost of integrating the batteries can be incorporated into the regulated scheme with which Spain covers the difference between the generation costs of the non-peninsular systems and the income obtained from their operation.
The project expressly includes the costs associated with downloading categories C and D among the items recognized in the system settlement.
Renewable energy will have a shield against negative prices
The modification of Royal Decree 738/2015 also changes the economic signal for renewable installations.
Until now, its selling price was linked to the average daily price of the peninsular market, corrected by a specific adjustment for each territory.
The growth of hours with zero and negative prices on the peninsula began to send an adverse signal to electrical systems with a different mix and operational needs.
To mitigate this effect, the project replaces the daily reference with the average price of the peninsular daily market corresponding to the last rolling year by full months, weighted by the energy sold.
The formula will continue to apply a time factor linked to the demand of the territory, but will prevent a specific day of negative prices on the peninsula from being directly transferred to the remuneration of a renewable plant located in the Canary or Balearic Islands.
The Government thus seeks to reduce volatility, offer a more stable reference point and prevent the saturation of renewable energy on the Iberian Peninsula from discouraging new clean generation in isolated systems.
Three months to adapt operating procedures
The introduction of storage into the dispatch will require additional changes to the system's technical rules.
The project grants the operator a period of three months from the entry into force of the royal decree to submit to the Ministry a proposal for the revision of the operating procedures linked to the integration of batteries in the non-peninsular territories.
The proposal must subsequently be submitted to a public hearing and approved by a resolution of the State Secretariat of Energy.
These procedures will need to address issues such as the communication of offers, the scheduling of loads and discharges, the management of deviations, network restrictions, and the coordination between batteries and conventional generation.
The project stipulates that all storage facilities must register their main technical data in the administrative register.
These include the maximum and minimum charging and discharging powers, the energy duration at maximum power, and the efficiency of the installation.