There is no separate legislation on electricity storage facilities in Germany. German law regards electricity storage facilities as consumers of electricity. This would imply that storage facilities, when withdrawing electricity from the distribution or transmission system for storage purposes, need to pay all fees, charges, etc. which normally are associated with the consumption of electricity. However, there are several exemptions in place, which aim to facilitate the use of storage facilities.
The German Federal Energy Industry Act (EnWG) exempts storage facilities which were built after 31 December 2008 and were put into operation within 15 years on or after 4 August 2011 from the duty to pay network tariffs for a period of 20 years when withdrawing electricity from the distribution or transmission system for storage purposes. The exemption only applies if the electricity withdrawn is stored in an electrical, chemical, mechanical or physical storage facility and the electricity is re-fed with a delay into the same distribution or transmission system. Special rules apply to pumped hydro storage plants. Whether the exemption from network tariffs also means that other charges and levies, such as concession levies, which are to be paid together and on top of network tariffs, do not have to be paid either is disputed.
Furthermore, the German Renewable Energy Sources Act (EEG) exempts electricity supplied for the purpose of being temporarily stored in an electrical, chemical, mechanical or physical electricity storage facility from the EEG levy if the electricity stored is only withdrawn to be fed back into the same network from which it was withdrawn.
According to the current electricity tax regulation, electricity tax does not need to be paid on the generation of electricity. Pumped hydro storage facilities are regarded as generators of electricity. Thus, they are exempted from the duty to pay electricity tax. However, other electricity storage facilities are not mentioned in the regulation and thus not exempted. Therefore a legislative amendment has been proposed. According to the proposal, the respective administrative body could, on request, allow stationary battery storage facilities to be regarded as part of a network if electricity is stored only temporarily and fed back into the network. In this case the battery storage operator would not need to pay electricity tax.
To open up the market for balancing energy to more suppliers, such as storage facilities, the German Federal Network Agency has proposed some changes to the balancing energy regulations. Amongst others, it proposes exemptions from the minimum size of products on the secondary and tertiary control market. Storage facility operators would prefer to have the conditions on the primary frequency response market changed to open it up for battery storage. However, changes are not expected on this market yet.
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