ACER REPORT ON TRANSMISSION AND DISTRIBUTION TARIFF METHODOLOGIES IN EUROPE
41
distortions (regarding cost efficiency of the network) in decisions around investments in
generation and storage because the true cost of using the network is not signalled to them.
(137) Commission Regulation (EU) No 838/2010 sets a range for the annual average value of
transmission charges (excluding connection charges, charges related to ancillary services and
specific system loss charges) paid by producers (i.e. G-charges). ACER acknowledges that the
cap provided by the Regulation can mitigate the potential negative impacts arising from
differences of injection charges between Member States. At the same time, it also creates a
barrier for effective cost signals coming from network tariffs. In its ACER Opinion No 09/2014 on
the appropriate range of transmission charges paid by electricity producers, ACER considered it
unnecessary to propose restrictions on cost-reflective power-based and on lump sum G-charges,
while energy-based injection charges should not be used to recover infrastructure costs.
(138) ACER recommends the following:
a) Increasing interconnection and integration of the European electricity market implies an
increasing risk that different levels of injection charges could distort competition and investment
decisions in the internal market, if injection charges are not set in a cost-reflective way across
Europe. In order to ensure cost-reflectivity and avoid market distortions, the cost caused by a
network user should be properly reflected in its tariffs. If a network user only withdraws from or
only injects into the transmission or distribution grid, in principle, only the costs relevant for
withdrawal or the costs relevant for injection should be attributed to this network user.
b) In order to avoid discrimination across network users connected to the transmission network
and those connected to the distribution network, the injection charges should be consistently
defined in the transmission and the distribution tariff methodologies. Network tariffs should not
incentivise generation to connect to the transmission network, instead of the distribution
network (or vice versa), unless justified by the associated network efficiencies.
c) Due to the potential cross-border impact, NRAs should consult at least the NRAs of the
neighbouring countries of any substantial change regarding injection charges in advance.
d) When setting injection charges, all network-related cost-burdens on the concerned network
users should be considered, including those recovered via withdrawal charges, connection
charges, or other means (e.g. in-kind payments or mandatory free services provided by the
producers to the system operators), to avoid any double-charging (i.e. recovery of costs which
have been already recovered via other means).
e) Since different system operator costs show correlation with different cost drivers (e.g.
infrastructure costs show correlation with peak capacity, while losses and system costs show
correlation with injected energy), energy-based injection charges (expressed in €/MWh) should
not be used to recover infrastructure costs from network users, while they can provide efficient
signals for recovering the costs of losses and system services. Power-based injection charges
(expressed in €/MW) or lump sum injection charges (as defined in this Report), as long as they
reflect the costs of providing transmission and distribution infrastructure services to network
users, can be appropriate, to better reflect their main cost drivers. Costs, which do not show
correlation with neither capacity nor energy, but rather with the number of network users or the
number of meters (e.g. billing, metering or administrative costs), in principle, should be
recovered via lump sum charges.