Energy Storage Systems In Kazakhstan: Time For Regulatory Changes.

Regulatory barriers

Recommendations

Out of date state programs
 

• several programs, roadmaps and other strategic program documents aimed at the development of the electric power industry and the industrial and innovative development of the country as a whole were adopted, but energy storage systems are mentioned only in passing (i.e. briefly):
 

• in the State program for the accelerated industrial and innovative development of the Republic of Kazakhstan for 2010-2014, it is indicated that technologies for the production of new generation batteries, among others, were identified as critical technologies in the electric power industry. 7
 

• in the same program but for 2015-2019”, the Centre for new energy and clean technologies (focus on energy storage systems and hybrid elements) was mentioned, and in the list of priority sectors of the manufacturing industry, the production of batteries and accumulators was indicated.8
 

• according to the KEGOC Development Strategy for 2018-2028, the introduction of energy storage systems, along with many others, is one of the key areas of technological development of KEGOC.9
 

• doctrine (strategy) on achieving carbon neutrality by 2060 highlights the importance of energy storage systems in enabling renewable energy into conventional energy system. 10
 

• current policies and regulations were created before new forms of energy storage were developed, and they do not recognize the flexibility of energy storage systems or allow them a level playing field. 
 

• adopting new state programs, roadmaps and other strategic documents that take into consideration all actual peculiarities of energy storage systems.

Lacking definition of energy storage.
 

• the Kazakhstan legislation lacks the proper and unified concept of "energy storage system", as well as the concept of "energy storage device", which prevents the regulation of the use of energy storage in the electricity markets. 
 

• according to the Law On Electric Power Industry, electric power industry11 is the sphere of production, transmission, supply and consumption of electric and thermal energy. This definition does not mention the field of energy storage system, and thus does not include a model for the participation of energy storage system in the wholesale and capacity market
 

• the definitions of “system services” and “ancillary services” in the Law On Electric Power Industry12 , also do not specifically mention the field of energy storage. 
 

• battery electric storage systems can be used to provide system services, and may become participant in the ancillary services market
 

• enable storage to be classified as generation, load or transmission and distribution infrastructure.

• make the necessary adjustments that would impact energy storage such as access/connection/network tariffs and charging, market rules/ grid code/ network development plans etc.
 

• properly define battery electric storage systems in the primary and secondary legislation of electricity sector in Kazakhstan. 

Lack of standardisation and technical requirements (including depending on the type of storage, etc.)
 

• this concerns safety and capacity requirements, testing processes. For example, in terms of safety standards, there are uncertainties whether and to what extent the safety regulation applicable to electrical systems of the same power and voltage class will apply to the energy storage systems. 
 

• introduction/adoption of standards needed for energy storage system’s metrics (such as efficiency, capacity, power ratings, system inefficiencies, etc.) as well as testing methods, safety standards, etc.

Absence of tax and other preferences, subsidies
 

• considered by the developers as another barrier that may slow down the development of the energy storage systems projects.
 

• direct funding programs for research, development and pilot projects 
 

• indirect incentives by hanging pricing rules for end consumers (for example, the introduction of strongly hourly differentiated tariffs) and the development of markets system services

Double charging of network usage​
 

• imported and exported energy from the storage device may be viewed as another issue that may make the business case challenging.
 

• the issue of charging the network each time you move the energy back and forth is not regulated in Kazakhstan. As a result, the developer may have to pay double price.

• this issue shall be specifically regulated in the legislation of Kazakhstan.