TES technologies integration: Regulatory constraints in the European union
A common challenge when trying to bring innovative technologies from lab to market is navigating an under-defined regulatory framework that is not clear enough to ensure a smooth demonstration in the whole EU territory. This is indeed the case on Thermal Energy Storage (TES).
Energy storage is still widely conceived as just electric energy storage, and this specific sector of energy storage has already well defined regulations and general guidelines at both EU and country level. However, there are not clear regulations specific to Thermal Energy Storage, so it is necessary to understand the relevant existing regulations and guides that should be somehow taken into consideration when installing this kind of technology.
The ThumbsUp project integrates advanced TES technologies into European buildings, with the goal of significantly improving energy efficiency through the use of renewable energy sources. The main technologies under development are SorTES (based on thermochemical storage) and FractLES (based on Phase Change Material, PCM). These technologies enable buildings to actively contribute to grid flexibility through the Power-to-Heat approach, allowing for more efficient balancing of energy supply and demand and optimising the usage of renewable energy peaks such as solar photovoltaic energy, by storing thermal energy for later use during periods of high demand.
Focusing at EU level, the Energy Performance of Buildings Directive (EPBD) sets out minimum requirements for the energy performance of buildings and their technical systems. It does not include specific technical instructions for member states - this is to be organised at member state level - but rather provides guiding principles. This directive mandates that facilities must be designed, installed and commissioned so as to ensure that they are energy-efficient and sized according to the actual heat demand of the building, covering the installation and operation of heating, cooling, and Domestic Hot Water (DHW) systems in residential buildings. Wellness and hygiene requirements of these devices are also covered by this Directive.
In terms of security requirements there are several EU directives and regulations that cover these kind of technologies such as the Ecodesign Directive (2009/125/EC), the Low Voltage Directive (LVD) 2014/35/EU, the Machinery Directive 2006/42/EC, the Pressure Equipment Directive (PED) 2014/68/EU, the Electromagnetic Compatibility Directive (EMC) 2014/30/EU, the Drinking Water Directive (DWD) 98/83/EC, the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU, the General Product Safety Directive (GPSD) 2001/95/EC or the Energy Labelling Regulation (EU) 2017/1369. Other additional regulations of interest in terms of environmental impact are the Energy Efficiency Directive (EED) 2012/27/EU and the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation (EC) 1907/2006.
These regulations and directives are implemented by EU member states through national legislation, which may include additional requirements or specifications. And here it is the key: depending on the specific country, a plethora of different regulations that can somehow affect or imply these technologies can be found.
Three of the four pilots which conform the validation and demonstration campaign of the THUMBS UP project are located in Spain. In light of this, it is of the utmost importance to have a clear understanding of how the existing regulations on this country can affect the TES framework.
In Spain, the general regulation on thermal facilities is governed by the “Reglamento de Instalaciones Térmicas en los Edificios” (RITE), which establishes different requirements depending on the thermal power installed. Some additional key aspects also covered by the RITE are the maintenance, usage and inspection requirements of thermal systems, as well as their related energy efficiency, renewable energy and waste. What is more, this regulation also covers aspects such as wellness and hygiene requirements, security requirements and environmental impact.
Due to the behaviour of the ThumbsUp technologies it is of the utmost importance to also consider electrical regulations. In Spain there is no differentiation among electric facilities of tertiary or residential buildings, which are legally governed by one regulation or other depending on their voltage level (low or high). Low voltage facilities are governed by the “Reglamento Electrotécnico para Baja Tensión” (REBT), which is applied to those facilities generating, distributing or consuming electricity.
Last but not least, one of the objectives of the ThumbsUp project is to enhance the flexibility with the electric grid, by optimising the electric self-consumption and taking advantage of low-prices-periods of electricity. In Spain and Portugal, the electricity prices are regulated by the OMIE, which manages all the existing electricity markets in such a way that it fixes the price per kilowatt hour on a daily basis.
All things considered, the situation in every EU country faces similar challenges. Independently of the EU level regulations and directives, the member states have dedicated legislations that directly govern TES-related installations, with varying requirements. This highlights the clear necessity of having a good understanding of the regulations and legislations that should be considered when installing TES related technologies, especially as long as no specific regulation is worded for their implementation.
Authors:
Guillermo André Nieto, Research Engineer, and Project Coordinator at Veolia Spain.
Juan Carlos Del Castillo García, Research Engineer, and Technical Coordinator at Fundación CARTIF, Spain.
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