ARTICLE
17 April 2025

DGEG Authorises The Use Of Reserved Capacity For Electricity Storage

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Order n. 1859/2025 (Order) published on February 10 by the Portuguese energy ministerial authority (DGEG), established the procedures for licensing of electricity storage facilities with previously allocated injection...
Portugal Energy and Natural Resources

Order n. 1859/2025 (Order) published on February 10 by the Portuguese energy ministerial authority (DGEG), established the procedures for licensing of electricity storage facilities with previously allocated injection capacity in the Public Service Electricity Grid (RESP), for:

  • Change of technology in a solar power generation center with an injection capacity reservation title (TRC) that has not yet been built; and
  • Standalone/Autonomous storage or co-located storage with previously allocated injection capacity reservation in RESP for a renewable energy power plant.
  1. Technology Change

A TRC issued under the general access modality for a solar generation center can be changed to an autonomous storage installation, provided that, at the time of the request, the power station construction has not yet started.

The request for modification must be submitted by the TRC holder to DGEG along with the following documents: (i) Identification of the existing TRC; (ii) Summary of the intended operating conditions; (iii) Maximum injection capacity into RESP; and (iv) Maximum apparent power for charging from RESP.

DGEG will review the request and forward it to the relevant grid operator, who has 30 days to provide an opinion on the maximum charging power and any operational restrictions for the storage facility. After the grid operator's response, the request is sent to the system's global manager (REN), which has 15 days to issue an opinion on the same matters.

If favorable, the grid operator must issue the modified TRC within a maximum of 10 days after DGEG's authorization.

  1. Use of Allocated Capacity

The injection capacity in a TRC granted to renewable energy power plants can now be simultaneously used to request a production license for autonomous or co-located storage installations, provided they are connected as follows:

  • For the National Transmission Grid: at the same grid connection point;
  • For the National Distribution Grid: on the same circuit.

The production license request must be submitted by the TRC holder to DGEG (with the explicit authorization of the storage installation holder) along with the required documents listed in Annex I of Decree-Law 15/2022, as well as:

  • A summary of the intended operating conditions for the storage installation, including maximum injection and charging power through RESP; and
  • A written agreement between the storage installation holder and the power plant holder to coordinate operations and inject the produced energy into RESP.

DGEG will review the request for compliance and forward it to the grid operator and the system's global manager for their opinions on the maximum charging power and potential operational restrictions for the storage facility.

If the opinions are favorable, DGEG will issue the production license within a maximum of 30 days.
The storage installation holder must ensure that the coordinated power plant is not simultaneously coordinated with other autonomous storage facilities. However, the storage installation may benefit from the injection capacity of multiple power plants.

This order came into effect on February 11, 2025.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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