A network crisis, a transport empire and an unknown solution
Romania has the third largest international road transport fleet in the European Union, after Poland and Lithuania. The transportation and warehousing sector contributes about 6% to GDP, and the road transport market reached €19 billion in 2023 (of which €17 billion in the freight segment alone), with an average annual growth rate of 8.5% over the last five years (UNTRR, 2024). International transport represents over 771TPTP3T of the total volume. These figures describe not just an economic sector, but a critical infrastructure of national competitiveness.
But the sector is approaching an inflection point. The Alternative Fuel Infrastructure Regulation (EU) 2023/1804 (AFIR) requires the installation of Megawatt Charging System (MCS) charging stations every 60 km on the TEN-T Core corridors and hydrogen refuelling hubs every 200 km, with mandatory deadlines in 2025, 2027 and 2030. Without compliant refuelling infrastructure, heavy vehicles of Romanian operators will not be able to run on European corridors. This is not just about compliance with a directive, but about the survival of EUR 19 billion of the economy.
At the same time, Romania has to support an exponentially growing industrial demand: data centers (needed for artificial intelligence and cloud computing), production of green hydrogen and renewable ammonia for the chemical and fertilizer industry (Power-to-X), green steel, massive battery storage (BESS). All these sectors have one common denominator: they consume massive amounts of clean energy and need access to the grid.
The problem is that the distribution networks are not ready. Dobrogea, the region with the largest wind and solar potential in Romania (and with plans for nuclear units 3 and 4 at Cernavodă, plus offshore wind projects), is already an area with significant energy surplus, where Transelectrica periodically applies curtailment to RES producers. Southern Oltenia (Dolj, Olt, Teleorman) is facing a solar overproduction that exceeds the discharge capacity of 110/20 kV substations. The same problem is reproduced, at different scales, in each region with high RES penetration.
According to an impact analysis developed in a geographically isolated ecosystem by the Association for Sustainable Fuels (ACS), in the concession area of a regional operator, the cumulative electricity loads imposed by AFIR alone amount to 108 to 146 MW, distributed over a minimum of 15 locations (hubs on corridors and urban nodes), not including adjacent industrial demand. The classical grid reinforcement scenario (construction of new 110/20 kV substations and high-voltage lines) would imply a CAPEX of EUR 100 to 150 million for that perimeter alone, in a 3 to 5 year implementation timeframe per substation. The AFIR deadlines for 2027 become, mathematically, impossible to meet with reactive approaches. Extrapolated at national level, across all distribution operators, the investment effort is multiplied.
Romania is thus facing a double threat: either it overloads the networks with loads for which they are not dimensioned (a shock to the energy system), or it does not install the necessary infrastructure and loses a transport sector that generates almost €20 billion annually, because the Romanian fleets will no longer be compatible with European sustainability requirements. Both scenarios are unacceptable.
The paradox: the consumers we fear are the solution we need
Distribution operators view massive new industrial consumers (data centers of tens of MW, electrolyzers, fast-charging hubs) with legitimate concern: each request for a Technical Connection Notice (TAN) for 10-50 MW appears as an additional strain on an already strained grid. But this perception, while intuitive, is fundamentally wrong if these consumers are strategically located.
A 10 MW electrolyzer, coupled with BESS and fed from local RES sources, located in a grid node with solar overproduction, does not add pressure on the grid. On the contrary: it absorbs the surplus that would otherwise be administratively limited, reduces the voltage on 110/20 kV transformers and eliminates the need for a €10 to €15 million investment in a new substation. A 50 MW data center with baseload profile, coupled with battery storage, behaves identically from a grid physics perspective.
What matters for the grid operator is not the energy destination (heavy vehicle charging, hydrogen production, data processing, chemical synthesis), but the consumption profile, dispatchability and the impact on the nodal balance. ACS has named this principle Functional Equivalence: any dispatchable bulk consumer, located in a RES overproduction node, provides a measurable decongestion service, regardless of its industrial nature.
This concept is known internationally as the Non-Wires Alternative (NWA): the use of flexible consumers as an alternative to physical extension of the grid. But it is essential to understand what we are and are not proposing. It is not about abandoning the reinforcement of distribution and transmission networks. Romania needs massive investment in the network, and this is indisputable. What we are proposing is a phasing and phasing strategy for the development of the grid, in which NWA industrial consumers act as immediate support tools, solving local congestion in nodes (on the model of the RFNBO cell, which is locally self-sustaining in terms of energy), and the physical extension of the grid is achieved gradually by integrating these cells into the national infrastructure. The network grows as an organism, not as a permanent emergency construction site.
The European rationale is sound. Directive (EU) 2019/944 (Art. 32) requires network operators (distribution and transmission) to use flexibility services as an alternative to physical extension of infrastructure. International practice confirms viability: Consolidated Edison (Brooklyn-Queens Demand Management Program, 2019), UK Ofgem (Flexibility Decision, 2021). Consolidation of projects under a common ATR, which treats the NWA hub as a single connection point integrating RES generation, storage and industrial consumption, simplifies the procedure and reduces connection costs for all parties.
Case studies: NWA consumers in Romania
The ACS proposal is not a theoretical exercise. The Romanian market is already generating projects that illustrate the full spectrum of NWA consumers.
Data centers coupled with RES production and storage. Monsson, one of Romania's leading renewable energy developers, has announced a pilot investment in a 50 MW data center, part of a wider strategy aiming for a 500 MW grid connection, integrating RES generation, battery storage and data processing capacity under the same connection. „We are currently designing and authorizing about 50 MW of data centers. This would be the pilot project,” said Sebastian Enache, Head of Mergers and Acquisitions (M&A) at Monsson, at the International Approach London conference organized by Energynomics [11]. At the Mireasa site in Constanța county, the integrated wind-solar-battery system is already delivering 10 MW in continuous operation (24/7), with battery efficiencies of 92-93% based on Prime Batteries technology manufactured in Cernica, Romania. Monsson and Prime Batteries have signed a memorandum for 1,070 MWh of additional storage capacity.
This model demonstrates exactly the NWA mechanism: a massive baseload profile clean energy consumer located at the RES generation source, locally absorbing the surplus and reducing pressure on the distribution grid. Monsson and Prime Batteries need a regulatory framework that recognizes this service and gives them incentives commensurate with the amount of avoided CAPEX they generate for distribution operators. To quote from the same Enache statement: „For artificial intelligence, five years is too long. We don't have time to wait.”
Green hydrogen production and renewable chemistry (Power-to-X). TDP Partners, an associate of ACS and author of the Blue Paper 2026 study series, has identified Power-to-X as one of the strategic directions for investors in the Romanian energy market. The series of 8 case studies planned for 2026 includes the financial analysis of the conversion of RES surplus into green hydrogen (RFNBO), green ammonia and, by extension, renewable fertilizers.
The value chain is straightforward: water electrolysis produces hydrogen, which, combined with nitrogen extracted from the air by cryogenic separation, generates green ammonia (NH3). About 801TPTP3T of the world's ammonia production (more than 170 million tons per year) is used to make fertilizers, while conventional production, based on steam methane reforming (SMR), emits about 500 million tons of CO2 per year. Replacing SMR with RES-powered electrolysis eliminates these emissions and creates a product with full traceability through Guarantees of Origin.
From a grid perspective, a 10 MW electrolyzer located in a node with solar overproduction functions as an ideal dispatchable consumer: it starts up at solar peak hours (10:00-16:00), absorbs the otherwise limited surplus, and can modulate consumption according to the operator's SCADA signals. The hydrogen produced is stored and used later, temporarily decoupling production from consumption. This inherent flexibility makes Power-to-X plants perhaps the most valuable type of NWA consumer.
Battery Industrial Storage (BESS). The TDP Partners analysis (Blue Paper, March 2026) estimates that the BESS market in Romania can reach a plateau of around 11 GWh by 2030, with a target IRR of around 18% (equity) in the current phase, converging to 12% at maturity. About 16 GWh of storage capacity would be needed to realize the effective transfer of surplus mid-day solar to evening demand. Standalone or co-located BESS projects with RES generation provide direct peak shaving, N-1 security criterion maintenance, and voltage fluctuation mitigation, all without physical grid upgrades.
The critical role of Guarantees of Origin: from energy certification to virtual renewable energy export
Guarantees of Origin (GOs) are not a technical detail, but the economic backbone of the whole NWA model. Applied research carried out under the aegis of ACS (Stoicescu, V., Vasiliu, C., Goldiș, A., „The Sustainable Organization Design for Transport Services: Guarantees of Origin (GOs) via Intelligent Transportation Systems”, PICBE 2024, DOI: 10.2478/picbe-2024-0242) has developed a conceptual framework in which the Guarantee of Origin is transferred from the energy sector to the products and services generated by the economic units that consume certified RES.
The evolution from classical Guarantees of Origin (annual, as per Directive 2018/2001/EU) to Granular Guarantees of Origin (GGO), at hourly or sub-hourly level (standardization coordinated by AIB and EnergyTag, with ongoing adoption by ACER), fundamentally changes the equation. GGO demonstrates the exact temporal correlation between local RES production and actual consumption, providing two simultaneous functions.
For end-users (fleet operators, data processing customers, green hydrogen buyers), GGO demonstrates that the energy consumed comes from renewable sources at the granular level, satisfying the 24/7 Carbon-Free Energy (CFE) requirements and the criteria of the RFNBO delegated act (EU Delegated Regulation 2023/1185, Art. 3-6).
For grid operators and ANRE, GGO provides measurable and auditable proof of the decongestion service provided: the temporal correlation between local RES production and certified consumption demonstrates that the NWA hub has effectively absorbed the energy surplus.
But the truly transformative dimension is another. Under the PPA (Power Purchase Agreement), renewable energy is no longer just an operational cost, but becomes a structural investment in the energy asset of the economic unit. The product or service that leaves the economic unit (green hydrogen, data processing, renewable fertilizers, industrial components) carries a proportionate share of the GO of the RES energy consumed, constituting an energy traceability stamp with measurable economic effects. The direct consequence: when these products and services are exported, Romania de facto exports renewable energy in virtual form, incorporated in the added value of the exported goods. CFE certified data processing services, hydrogen with full traceability, components with verifiable carbon footprint: all generate a product premium that improves bankability and attracts investment capital.
Legal background: what the law allows, what has changed and what needs to be changed
The Romanian legislative framework has made significant progress in the last two years. GEO 134/2024 (MO no. 1179/26.11.2024) amended Law 123/2012 in the context of the transposition of Directive (EU) 2019/944 on the internal electricity market, introducing regulations on energy storage and the definition of storage service providers. Subsequently, GEO 59/2025 (MO No. 1035/7.11.2025) transposed the RED III Directive (EU Directive 2023/2413 amending Directive 2018/2001 on the promotion of the use of energy from renewable sources), in the context of the infringement procedure No. 2021/0333. GEO 59/2025 introduces, among other things, acceleration zones for renewable energy (with authorization deadlines of 12 months onshore and 24 months offshore), single points of contact for authorization procedures and provisions on Guarantees of Origin (Art. 19).
What can be done now. Energy Law No. 123/2012, as updated (Art. 59-67, distribution; Art. 72, tarification of network services), allows distribution operators to contract services from third parties in the framework of regulated activity. Operators can enter into bilateral flexibility contracts with NWA consumers that commit to absorb excess RES in congestion nodes, based on a negotiated price reflecting avoided CAPEX. These contracts do not require a formal flexibility market, but the commercial will of the parties and ANRE's validation of the cost as a regulated operational expense.
ACS has proposed to the distribution operators to launch a NWA pilot project at a priority congestion node with a 12 to 18 month horizon, including a minimum 5 MW consumer integrated into the SCADA/DMS system, with monitoring of actual congestion impact.
What requires legislative intervention. Three modifications are essential for scaling the solution.
First, the introduction of zonal or nodal tariffs (Nodal Pricing) in ANRE's tariff methodologies. NWA consumers locating in RES congested areas and providing flexibility services should benefit from the reduction or elimination of the extraction and injection tariffs (TG/TL). The economic rationale is straightforward: if a consumer eliminates the need for a € 10-15 million investment, the cost of the tariff reduction is negligible by comparison. The updated tariff methodologies following the transposition of RED III should explicitly include the recognition of the costs of acquiring NWA flexibility services as justified OPEX, fully recoverable through pass-through tariffs, as an alternative to capitalizing investments in the Regulated Asset Base (RAB).
Second, creating local flexibility markets by fully transposing Art. 32 of Directive (EU) 2019/944 into national law. Future amendments to Law 123/2012 must explicitly recognize the right of network operators (distribution and transmission) to contract and remunerate NWA consumers and the obligation of ANRE to approve the inclusion of these costs in the distribution tariff. The GO/GGO framework is the tool to verify and audit the service provided: without granular certification, the network operator cannot demonstrate that the flexibility service has actually been provided and ANRE cannot validate the cost.
Third, the use of the Industrial Accelerator Act (IAA), proposed by the European Commission on March 4, 2026 (COM(2026)100), as a tool to accelerate authorization. The IAA introduces Industrial Acceleration Areas (IAA) with fast-track permitting, tacit approval at intermediate stages and one-stop-shop digital procedures with a maximum time limit of 18 months. Coupled with the Net Zero Industry Act (NZIA, EU Regulation 2024/1735), which recognizes BESS, solar PV and electrolysers as strategic net-zero technologies, this framework can compress permitting timelines from 3-5 years to under 18 months, unlocking the respect of the AFIR timetable.
Incentivizing investors: not subsidies, but recognition of a system service
Companies developing data center, industrial storage or green hydrogen production projects in Romania are currently doing so without any tariff or contractual benefit for the decongestion service they implicitly provide to the grid. Monsson and Prime Batteries, who are investing in the integration of RES production, storage and data centers under the same connection, are exactly the type of investors that Romania needs to encourage, not through subsidies, but through the correct recognition of the service they provide.
Every megawatt consumed locally in a RES surplus node is a megawatt that does not require investment in grid expansion. Reduced nodal tariffs, priority access to RES and fast-track authorization procedures are not forms of state aid, but the fair price of a system service that these consumers provide. The measures are mutually beneficial: the investor obtains a competitive energy cost and simplified procedures, the network operator avoids reinforcement CAPEX, and the national economy gains industrial capacity, jobs and high value-added exports certified by Guarantees of Origin.
The alternative is clear and costly: without NWA consumers, distribution operators will be forced to invest hundreds of millions of euros in physical reinforcements of the network, with deadlines that exceed the AFIR compliance windows, and the transmission sector, with its €19 billion, will become incompatible with European requirements. Administratively curtailment in Dobrogea, Oltenia and other RES overproduction areas represents a direct economic loss that NWA industrial consumers can turn into hydrogen production, data processing, storage and exportable chemicals.
Conclusion: a closing window of opportunity
The legislative convergence between AFIR, RED III, IAA, NZIA and the revision of Law 123/2012 creates a window of opportunity that will not remain open forever. ACS has proposed a structured action plan to the energy sector and decision makers: bilateral flexibility contracts on the existing framework (initializable in Q2 2026), NWA pilot projects at priority congestion hubs and, simultaneously, promotion of the three legislative changes (nodal tariffs, local flexibility markets, designation of NWA hubs as Industrial Acceleration Zones).
Romania can choose between treating industrial clean energy consumers as a grid problem or as a system solution. Technical data, the European legal framework and investment realities converge towards the same conclusion: RES certified industrial consumption, strategically located and verified through Granular Guarantees of Origin, is the fastest, most efficient and least costly tool available today to reinforce the power grid.
Vlad Stoicescu is the President of the Association for Sustainable Fuels (ACS), an organization that brings together companies and investors active in the alternative fuels, energy storage and clean transport infrastructure sectors in Romania.