There are still major regulatory uncertainties regarding smart metering systems. In theory, the interim model for market communication took effect for smart metering systems in October 2017. But the technical requirements for smart meter gateways are not final, and no target model has been finalized for the so called “wheel communication”. After all: It’s crystal-clear in which cases a smart meter gateway has to be installed. Right? The Metering Point Operations Act (MsbG) and Energy Industry Act (EnWG) leave plenty of room for interpretation. Kiwigrid and the enviaM Group have provided answers to the most important questions.
As a general rule, the following applies: Installation of a smart meter gateway at a metering point becomes mandatory based on the annual consumption, the installed power generation capacity or the possibility to control consumer devices for so called “network flexibility” purposes. All metering points of consumers with an annual power consumption of over 6,000 kilowatt hours or a controllable consumer device in accordance with paragraph 14a of the Federal Energy Industry Act must be equipped with a smart metering system. All generating plants with an installed capacity exceeding seven kilowatts fall under this mandatory installation specification. But what exactly do these requirements – “6,000 kWh”, “paragraph 14a” and “power capacity 7 kW” – mean? When is a battery storage device a “system” according to paragraph 14a of the Federal Energy Industry Act? Does installation become mandatory when the average consumption reaches 5,998 kWh or the power generation capacity is 6.98 kW?
Paragraph 14a of the Federal Energy Industry Act considers battery storage devices, electric vehicles, heat pumps and night storage heating to be “controllable consumer devices,” for example. But this begs the question of whether installation becomes mandatory for all these system types without exception. For example, are there any power generation capacity limits? Thoralf Ehnert, Head of Product Development/Management at enviaM, explains: “Mandatory installation for all paragraph 14a systems does not necessarily apply to all heat pumps, EV charging stations or battery storage devices. Instead, this is an individual decision that takes economic factors into consideration, along with the question of whether it is at all possible to intervene with the control in order to reduce the network load. There are no power generation capacity limits.”
Another example: A renewable energy system has a power generation capacity of 6.96 kWp. Is this value rounded up? “Paragraph 29 of the Federal Metering Point Operations Act (MsbG) is very clear on this: no rounding. The exact installed performance of the generating plant applies. If the value exceeds seven kilowatts, installation becomes mandatory,” Ehnert explains.
Annual consumption is a little more complex, despite the fact that legislature has reached a relatively clear agreement: The average of the past three annual consumption values applies. If this value exceeds 6,000 kWh, installation becomes mandatory. The true difficulty lies in validating these values. “Of course, the average value may include an estimate of the metering point operator or an incorrect number provided by the customer. Generally, however, many metering point operators carry out check readings. With the 3-year average value, legislature seeks to ensure that consumption points can be accounted for correctly, preventing frequent replacements,” Thoralf Ehnert states. What about new systems? “If the building is new and three values are not available yet, an assessment based on the standard load profile of the consumer or comparable consumer groups is used as a basis,” says Ehnert.
Legislature clearly indicates that small, privately operated systems such as heat pumps, charging stations for electric vehicles or PV systems in conjunction with battery storage devices should also make a major contribution to the energy transition. The previous formulation in paragraph 14a of Energy Industry Act has already been changed from “interruptible” to “controllable” devices. These controllable devices also include electric vehicles. Many other aspects are not yet defined – just one of the reasons why concrete regulations and provisions are to follow. An incentive system for network flexibility and technical specifications are expected to be included.
“Paragraph 14a of EnWG contains the power to issue statutory instruments as well as a reference to the simplified legislative process by the federal government. We look forward to the content. We see major potential for our customers to make a valuable contribution to a sustainable energy system. It is important to make adapting one’s own energy needs to external specifications and providing renewable energies worthwhile for private households and small business customers. In total, the energy transition must not bring about additional costs,” Thoralf Ehnert concludes.