The HSE Group welcomes the draft of the new Electricity Supply Act as it transposes some of the key acts of the European energy legislation from the winter package. It is one of the several new thematic acts which are set to replace the existing Energy Act (EZ-1).
Since it is a fundamental act that is expected to have a significant impact on the future functioning of the HSE Group, we have prepared several proposals for the legislators which would bring its provisions even closer to its purpose: ensuring a competitive, secure, reliable and accessible electricity supply.
Let us highlight some of them:
- The Just Transition Principles, in the opinion of the HSE Group, are the key elements that also need to be taken into account regarding electricity supply and are the foundation for a socially, environmentally and economically acceptable transition to a zero-carbon society. Because a national coal phase-out strategy on the basis of Just Transition Principles, which is part of the commitments made under the National Energy and Climate Plan, is being drafted, it is also necessary for these principles to become part of the Energy Supply Act.
- The HSE Group advocates the long-term stability and predictability of the business environment. The exemptions for energy storage facilities from paying the network charge for the assumed electricity intended for storage are currently regulated at the level of implementing regulations in the Legal Act on the methodology for determining the regulatory framework and network charges for the electricity system, which is changed and updated by the Energy Agency every three years. Because energy storage in Slovenia will increase in importance, as it ensures the safe and stable functioning of the power system, as in other EU member states, the conditions for the operation of energy storage facilities, including pumped-storage hydro power plants, must be predictable and clear for a longer period of time, instead of being subject to potential changes every three years. The status of energy storage facilities in terms of exemption from payment of the network charge for the assumed electricity intended for energy storage and later conversion of this energy into electricity should thus be regulated in a more permanent manner, in the Electricity Supply Act, which will represent the umbrella regulation in the field.
- We propose that, in the event that a concession for the use of a renewable source is obtained, the requirement in the Act that an energy permit needs to be obtained is eliminated, as this is an additional administrative measure which is not in compliance with the EU guidelines regarding the elimination of administrative barriers and facilitation of procedures to obtain permits for renewable energy source (RES) projects.
- We propose that aggregation may be implemented also at the level of multiple final producers and/or providers of flexibility or balancing services, and not only of consumers, as the legislator has not included this option in the draft Act.