Dear Victron,
It seems very likely, from the email below (names and some details omitted) that the docs you submitted to ENA in early October will not be sufficient to gain compliance "due to important information being either incorrect or missing altogether".
Please could you provide some kind of timescale for when you will be able to provide updated documents? I note that NGED are, helpfully, willing to liaise with you in order to speed up the process.
Providing a response on this forum would, I'm sure, be very welcome by customers like myself.
Thanks
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Good afternoon,
I have been asked to contact you, to explain the current compliance status, with regard to ENA EREC G99/1-9, for the Victron Multiplus II 48/5000/70-50 and Victron Multiplus II 48/5000/70-50 GX (which share a common compliance report).
As you may already be aware, as of 1st September 2022, any device that is recognised as an Energy Storage System (ESS) had to meet the full technical requirements of ENA EREC G99/1-8 (and subsequent revisions), where they were previously exempt from some of the newer requirements, that were introduced by the European Network Code: Requirements for Generators (RfG). This requirement was communicated well prior to September 2022, and was published in EREC G98/1-5 and EREC G99/1-7 in August 2021.
Many manufacturers pre-empted this change, and made their ESS compliant before need. Others waited until the deadline to submit renewed compliance documentation.
Where an ESS device had not met the requirements on 1st September 2022, it was marked as ‘non-compliant for new installations’, by WSP, in the ENA’s Type Test Register, and manufacturers were pushed to renew their compliance documentation.
The ENA, WSP and DNOs have the authority to determine Generating Unit compliance under (to name just one document, to avoid confusion) ENA EREC G99, which is an Annex 1 document of The Distribution Code of Great Britain (DCode).
DNOs have a statutory obligation (and licence condition) to abide by the DCode and (in particular) its Annex 1 documents.
As the Victron Multiplus II 48/5000/70-50 (ENA Type Test Register reference: VICEN/02689/V2) Energy Storage Device’s current status is ‘awaiting assessment’, in the ENA’s Type Test Register, I have conducted an in-house assessment, in order to provide our customers with a response sooner than we would be able to if we were to wait for WSP’s assessment. My assessment is based directly upon the requirements within EREC G99/1-9 alongside prior assessments by WSP (what they will be looking for), and my own experience.
I have assessed the Victron Multiplus II 48/5000/70-50 and Victron Multiplus II 48/5000/70-50 GX as being ‘non-compliant’ with ENA EREC G99/1-9, as things currently stand, due to a number of shortfalls in the compliance form. As Victron have made their form publicly accessible, via the ENA’s Type Test Register (i.e. it’s not a restricted document), I believe that I can elaborate upon this:
Advisory and failure points:
[information which could be considered commercially sensitive omitted]
Hopefully, you will be able to see that this compliance status has not come about due to minor inaccuracies, which could be forgiven, but due to important information being either incorrect or missing altogether.
As a consequence of these findings, National Grid cannot accept the connection of the Victron Multiplus II 48/5000/70-50 or Multiplus II 48/5000/70-50 GX, in parallel with our Distribution Networks, until such a time that Victron have provided alternative or additional information that demonstrates compliance with the latest version of ENA EREC G99.
I am comfortable with you informing Victron of the above, either directly or indirectly (through your equipment supplier), so that they may complete and provide alternative or additional evidence of compliance. They should do so primarily to the ENA, but National Grid Electricity Distribution would also be willing to take an early look at any documentation, should Victron see this as desirable.
I am confident that, given time to complete the documents accurately, Victron will be able to make these devices compliant (perhaps with another firmware update) but, unfortunately, we will have to wait until they have demonstrated this before we may accept these on our networks.
Kind regards,
Engineering Policy
nationalgrid
