Energie-Nederland has submitted an opinion on ACM’s draft decision on the non-firm transport agreement. This is a first version of a flexible right to transport. A party that concludes a non-firm transport agreement can only use the electricity grid at those times when the grid operator deems this possible given the available space on the grid. This is offset by a discount on transport rates.
Energie-Nederland welcomes the proposal and believes that there should be more variants for a flexible right to transport, for example where grid users have the right to transport during certain fixed hours per day. These alternative rights to transport are particularly important for flexible customers and therefore also for storage.
A grid user that is flexible and can deal with non-firm transport can also participate in congestion management. That is why Energie-Nederland advocates that priority be given to implementing congestion management as completely as possible. It is important to clarify further whether network operators are permitted to offer non-firm transport rights if the offering of normal transport rights is no longer permitted because the limits for applying congestion management have been reached.
