E.ON Netz published its new connection rules, dated April 2006, in June, saying they apply to all new connections from the start of July. Existing connections are not out of the line of fire, however, since "provision is made for a transitional period for existing grid connections." The period of grace is not defined.
Moreover, E.ON Netz has introduced a set of basic technical connection requirements and a set of "additional requirements" that "must be fulfilled at the request of E.ON Netz in order to ensure reliable system operation above and beyond the basic requirements." The additional requirements will be contractually agreed between E.ON Netz and the operator of the generator plant. GGS says this two-tier system means it is not clear from the start what requirements plant must fulfil.
Black start capability
E.ON Netz also demands that all generating wind power plant be able to start-up from scratch, with no support from the grid. "The possibility for black start capability must be realised by the operator of the generating plant as an additional requirement if this is required by E.ON Netz," states the new code. But GGS points out that not all plant has black start capability.
GGS is also concerned about the company's stipulation that "as an additional requirement, participation in generation management may be necessary in order to ensure reliable operation and to protect equipment from damage." In other words, at the request of the network operator, generating plant must constrain or increase its output. Such generation management adds to an operator's risk, making project financing more difficult, says the law firm. It also notes that under Germany's renewable energy law, a load management agreement between generators and grid operators should be optional. E.ON Netz appears to be suggesting that in circumstances it deems appropriate such a agreement would be compulsory for grid connection. In response, GGS is advising wind operators signing a generation management agreement to take precautionary steps. They should officially demand that E.ON Netz fulfils its legal obligation to expand the network without delay to accommodate all renewable power, recommends GCS.
The law firm further points out that by defining connection points, E.ON Netz is contravening the renewable energy law, which stipulates that the technically and economically most favourable connection point should be chosen. Conflict over the law is on the cards, GGS concludes.