KEY MESSAGES
- Eurelectric welcomes the initiative to introduce a storage order in the Single Day-Ahead Coupling (SDAC). An enriched set of bidding products improves market efficiency by allowing market participants (MPs) to adequately represent their asset portfolios. By allowing MPs to submit bids without defining a detailed execution profile, the storage order reduces exposure to price forecast errors, while improving allocation across market time units.
- The storage order should be seen as an additional, voluntary option for MPs and should not result in the restriction of any other order types. If implemented, NEMOs should coordinate their approach to preserve a level playing field.
- We regret the lack of information shared by the all-NEMO Committee about the algorithmic performance impacts of the envisaged storage order. Transparency about the implications of different storage order types should be ensured to rule out knock-on effects on the availability of complex products.
- Eurelectric underlines that the current design of the storage order is suited only to battery energy storage systems, as it does not adequately reflect the operational constraints of pumped hydropower storage systems, and specifically their inability to rapidly switch between consumption and production.
- More generally, some product parameters would benefit from refinement to reflect storage assets’ real operational behaviour (non-linear ramping, efficiency losses), and to enhance opportunities for multi-market optimisation (declaring asset availability on 15-minute basis). Such changes should be balanced against the risk of algorithmic performance degradation.
- Eurelectric can accept a minimum size threshold of 5 MW for storage bids if needed to preserve algorithmic performance, while reiterating that performance impacts on EUPHEMIA in relation to the different thresholds should have been made transparent.