Electricity storage facilities
9 July 2025 • Autor: Kancelaria Brysiewicz Bokina i Wspólnicy
Electricity storage facilities as a remedy for the ills of the National Power System
The volume of electricity generation from renewable sources, which is increasing every year, causes numerous overloads on elements of the electricity infrastructure. This is due to periods of surplus electricity and insufficient grid capacity to accommodate such a large amount of energy. The surplus of electricity in the system can cause interruptions in its supply and, in the worst case scenario, can lead to the collapse of the NPS. In Poland, solutions are being sought all the time to effectively improve the operation of the NPS (cable pooling, redispatching, etc.), but the greatest potential is shown by electricity storage facilities, which allow the storage of surplus energy and stabilise the power system.
In this article, we present to you what electricity storage facilities are and how they differ from energy storage. You will also find basic information on licensing, grid connection and registration with the President of the ERO. Unfortunately, URE has not published an information package on its website for entrepreneurs intending to conduct business in the field of electricity storage, so for assistance in obtaining a licence or legal advice in this area, please contact the Transformation and Energy team.
What is electricity storage?
Electricity storage, as defined in Article 3 para. 59 of the Act of 10 April 1997 – Energy Law (hereinafter: EP) means the deferral in the power system of the final consumption of electricity or the conversion of electricity drawn from the power grid or generated by a generating unit connected to the power grid and cooperating with the grid into another form of energy, the storage of this energy and its subsequent conversion back into electricity. It should be borne in mind that the storage of electricity is not the same as the storage of energy ( Article 3(59a) EP). At the same time, electricity storage is defined as an installation enabling the storage of electricity and its introduction to the power grid (Article 3(10k) of the EPP), a much narrower concept than the term energy storage (Article 3(10ka) of the EPP), which means an installation enabling the storage of energy, including the storage of electricity. The conceptual scope of energy storage is much broader, as exemplified by pumped storage power plants, which have been recognised as energy storage.
Process of obtaining a licence for the business activity of electricity storage
Obtaining a licence from the President of the ERO is required to carry out the business activity of storing electricity with a total installed electrical power of more than 10 MW (Article 32(1)(2)(a) of the EP).
In order to apply for a concession, an applicant must have, inter alia, a decision on development conditions, legal title to real estate, financial resources and constructed storage infrastructure, i.e. fulfil the so-called positive conditions for granting a concession listed in Article 33(1) of the EP. The concession may not be granted if the negative prerequisites specified in Article 33 (3) of the EP exist, such as bankruptcy proceedings, withdrawal of the concession, conviction by a final court verdict for a fiscal offence. An application for an electricity storage concession must include documents confirming the fulfilment of formal, legal, financial and technical conditions. The time taken by the ERO to process a concession application is, in practice, between 2 and 3 months. The concession is granted for a fixed period of not less than 10 years and not more than 50 years. The fee for filing a concession application is PLN 616. The concession takes the form of an administrative decision, which indicates the duration of the concession and the rights and obligations of the concessionaire.
Prior to the application for an electricity storage concession, it is possible to apply for a promise, which makes it easier for the company to obtain financing for the planned investment. The promise establishes the period of validity, except that it cannot be shorter than six months.
Connection of electricity storage facilities to the electricity grid as one of the concession conditions
In order to fulfil one of the concession conditions, it is necessary to obtain electricity grid connection conditions. In addition to data on the entity and location, the application for the determination of the terms and conditions for the connection of an electricity storage facility pursuant to Article 7, paragraph 3c of the EP shall also contain information specifying the parameters of the electricity storage facility, in particular the total installed electrical power of the electricity storage facility expressed in kW, the nominal capacity expressed in kWh and the efficiency of the electricity storage facility. In the event that the electricity storage facility will form part of a generating unit or end-user installation, the application shall contain the same information as for the electricity storage facility referred to in Article 7(3) EP. In the case of electricity storages directly connected to a power grid with a rated voltage higher than 1 kV, an expert opinion on the impact on the power system shall be drawn up pursuant to Article 7(8e) of the EP. The following are excluded from this obligation:
- electricity storage facilities with a total installed capacity of not more than 2 MW,
- a generating unit to be connected of which the electricity storage facility will form part, provided that the combined installed capacity of this storage facility and the generating unit is no more than 2 MW,
- a connected installation of an end-customer, part of which will constitute an electricity storage facility, provided that the total installed capacity of this storage facility and the connection capacity of the end-customer’s installation is no greater than 5 MW.
After obtaining grid connection conditions and a positive expert opinion on the impact on the electricity system, the transmission and distribution system operator shall be obliged to conclude an electricity storage connection contract. In the event of a refusal to conclude a connection agreement, the dispute under Article 8 of the EPP is resolved by the President of the ERO.
Registration
Pursuant to Article 49g of the EPE, electricity storage facilities connected to the grid, being part of the grid or forming part of a generating unit or installation belonging to a final customer connected to the grid, are subject to a register which is kept by the electricity system operator. An entry shall be made within 14 days of the date on which the electricity storage facility becomes operational. Electricity storages with a total installed capacity greater than 50 kW shall be registered. If an electricity storage facility is part of a generating unit or an end-user installation connected to the grid of a given electricity system operator, the owner is obliged to submit an application for entry in the register to the operator within seven days of the commissioning of the electricity storage facility.
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Agnieszka Górka |

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