Mr. Kretschmer, were you surprised that the distribution system operators involved, as well as Amprion and 50Hertz, discontinued the test operation of balancing within the framework of Redispatch 2.0?
Yes, “surprised” is a good word. We were surprised in several ways. First of all, we were surprised by the announcement to discontinue the test operation and to return to the “BDEW transition solution” as such. We were also irritated by the choice of communication via the distribution system operator and the loud silence of the BNetzA and BDEW. What surprised us most, however, was that the communication as such did not provide any perspective on how the transmission system operators intend to implement the statutory requirements for balancing redispatch measures within a reasonable period of time.
How do you assess the transitional solution developed by the BDEW from your perspective as a direct marketer?
It is important to understand that the “transitional solution” born out of necessity in October 2021 was only intended to apply until June 2022 at the latest.
The planned settlement method “balance sheet compensation” was not available on day one of Redispatch 2.0 and yet the DSOs had already implemented a considerable number of measures. So that plant operators could be compensated quickly for the loss of revenue, we as direct marketers set up a parallel billing structure at lightning speed and only for a manageable period of time. Of course, this means that it is not a fully automated billing process, but that a lot of personnel are still tied up with processing the financial compensation, especially on the direct marketing side.
In addition, the transitional regulation assumes that the direct marketer is informed in advance of redispatch measures by the transmission system operator and can therefore manage its balancing group accordingly. Based on this, the BNetzA has not demanded the actual balancing energy price for the transitional solution, but a mixed price as the basis for financial compensation. In fact, however, such advance information is still missing to a considerable extent. As a result, the direct marketer is not able to manage its balancing group accordingly and has to bear the difference between the operator payment and compensation from the distribution system operator out of its own pocket.
These are just two reasons why the idea of continuing the status quo indefinitely is not an option for us and why the lack of an alternative solution proposal “surprises” us, to use your words.
How did this decision specifically affect your business as a direct marketing company for biogas plants?
This is another reason why the status quo is not a permanent option.
Fortunately, we have observed in recent years that more and more biogas plant operators are opting for a more flexible and market-oriented operation of their plants and have also made corresponding investments. The intention of many existing plant operators to participate in the tender for a second funding period and to make their own plant more flexible as part of this has also become more firmly established recently. In order to best harmonize the redispatch measures of the DSOs with the schedules of such plants and also with the provision of balancing energy for the TSOs, they should participate in the redispatch process in the so-called planned value model. However, an essential prerequisite for the planned value model is a functioning balancing system.
Without the perspective that balancing in the planned value model can also be implemented by the transmission system operator, the direct marketer has no basis on which to make the necessary investment decisions for the introduction of the planned value model. The plant operator bears the brunt, as the alternative forecast model ignores what the plant would have done according to the schedule. Instead, only the work status that prevailed at the plant at the start of the redispatch measure is updated.
How do you perceive the current attitude of plant operators towards Redispatch 2.0: Is there a great deal of uncertainty?
Uncertainty among operators is greatest where redispatch calls occur frequently, i.e. particularly in the north and center of Germany. Fortunately, we have been able to relieve our operators of the administrative challenges in the redispatch process, as well as in prompt compensation, quite quietly by taking over the tasks of the deployment manager for our operators from the very beginning. Regardless of whether the DSO has been financially compensated, we make payments to our operators as soon as the outage work caused by the redispatch measure is available.
The expectations of flexibilized operators in particular for a rapid introduction of the planned value model are understandably high, as lost revenues due to redispatch rightly feel like losses for plant operators. Redispatch 2.0 will not find support among RE plant operators as long as they repeatedly discover in practice that they are not compensated after the measure as if the measure had not existed. I would therefore like to emphasize once again that we expect the transmission system operators as well as the BNetzA and the BDEW to come up with a concrete implementation plan in the near future on how the balance compensation can still be realized on the grid operator side.
The questions were asked by Julian Korb
Kurt Kretschmer is responsible for energy policy at e2m – a subsidiary of EDF SA. He has been with e2m since 2016 and is now responsible for energy policy at German and European level. Kretschmer studied commercial law at the Faculty of Law at TU Dresden, specializing in regulated markets and energy law. He is the spokesperson for the direct marketing working group of the German Biogas Association.
With kind permission of the ZfK
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