Is a Hydro Storage Virtual Power Plant deal considered to be a contract for the supply of electricity and therefore reportable as a non-standard transaction under REMIT?
An example term sheet for such a deal would be:
Delivery Point: French Power
Storage Volume: 50,000 MWh
Max Storage Level: 50,000 MWh
Min Storage Level: 0 MWh
Initial Storage Level: 30,000 MWh
Final Storage Level: 30,000 MWh
Inflows: 150,000 MWh – These would have a Hourly MW profile
Outflows: 50 MW – Daily nomination
The holder of the contact would then effectively be able to take physical power from the writer as long as they operated within the above constraints. The power taken would be at zero price in return for a premium paid upfront.
In the draft FAQ's issues after the Dec-15 ACER roundtable meeting, we note that Virtual Gas Storage contracts are not considered contracts for the supply of gas and therefore not reportable.
Based on this, we do not deem a Hydro Storage Virtual Power Plant deal to be a contract for the supply of electricity due to the significant similarities between this type of transaction and that of a Virtual Gas Storage transaction.
Could ACER confirm this view is correct?
If the holder of the contact is able to take physical power from the writer, this is a contract for the supply of electricity. This is a reportable contract pursuant to Article 3 of Commission Implementing Regulation (EU) No 1348/2014.