Date 20 October 2021
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RENEWABLE ENERGY SOURCES: Photovoltaic/ solar installations: the procedure of licensing and disposal of the produced energy in Greece

From 1.1.2016, the Greek Law 4414/2016, restructured the institutional framework for the new support regime regarding electricity generation stations from Renewable Energy Sources (hereinafter RES) in Greece, as well as the general regime regarding the production of electricity from RES and cogeneration in high-efficiency electricity and heat. At the end of 2019, the final National Plan for Energy and Climate was formed, setting a higher target of the contribution of RES at least 35% in the gross final energy consumption, by 2030. Similarly, in the middle of 2020, the boundaries concerning the Reference Prices were defined, both for the projects willing to enter the State aid scheme for the disposal of their produced energy, and for those that will not participate in it.

The new investment environment for the photovoltaic installations in Greece:

According to the existing legislation, the licensing procedure for natural persons or legal entities interested in investing in photovoltaic stations is the following:

  1. 1. In the first ten days of February-June-October, applications are submitted to the Energy Regulatory Authority (RAE), as this is the Licensing Authority. Due to the health crisis, this deadline was postponed by two months, so the last applications of 2020 were completed last December. The application is filed digitally with some attached supporting documents and a one-time application fee of 60 euros / MW.
  2. 2. Within 5 days from the submission of the application, the latter is posted on the RAE Website.
  3. 3. Within 15 days after the end of the above five days, objections are submitted by anyone who has a legal interest.
  4. 4. After this, another 15 days are provided for the submission of the applicant’s views on the objections.
  5. 5. Finally, within 20 days after the last 15 days, the relevant Certificate of the Electricity Generator is issued, for which a one-time issue fee of 1000 to 3000 euros / MW is required, depending on the power of the production unit.

* The same licensing procedure is followed for onshore wind farms and RES hybrid stations.                    

This certificate, issued within approximately 2 months by a fully digital procedure, is issued for 25 years and can be extended for an equal period of time. Besides, systems not exceeding 1 MWp are released and exempted from the obligation to issue the Electricity Generator Certificate.

Once the issuance of the Certificate is completed, the holder has the option to either install a self-generating system to cover part or all of the electricity consumption at his disposal or to sell all the generated energy to the Electricity Distribution Network.

Disposal of all the produced energy on the network:

In regards to the producers who wish to contract with the Electricity Distribution Network, it is possible to sell the total of their generated energy as follows:

  1. 1. The producing units that are exempted from the issuance of the Generator Certificate simply issue a certificate of exemption from the Approval of Environmental Terms by the relevant Peripheral Region office, approval of small works by the Town Planning and after an offer of connection with HEDNO, contract with the Greek RES Manager (DAPEEP).
  2. 2. Those units that maintain a power greater than 1 MWp after the issuance of the Certificate, must also issue an installation permit from the relevant Decentralized Administration, approval of small tasks by the Town Planning office and a connection agreement with the Operator of the Hellenic Electricity Distribution Network (HEDNO) and the Independent Electricity Transmission Operator (IPTO) (if their voltage is too high). They also contract with the Official Administrator for RES and Origin Guarantees, so that their operating license is finally issued by the Decentralized Administration’s office.

Projects participating in competition procedures regarding the disposal price:

At the end of last year, a Joint Competitive Bidding Procedure was announced (auction) for RES power plants and high-efficiency cogeneration of electricity and heat, which concerns wind and photovoltaic installation technologies, for the conclusion of an operating contract. The submission of offers lasts from 07-01-2021 until 22-03-2021, through the digital platform of RAE.

Regarding photovoltaic stations:

A. Installed power plants from 500 kW up to 20 MW can participate in the competitive process (auction), to be included in the operating State aid scheme, with a maximum allowable bid price of 53.86 euros / MWh and a participation fee of 1000 euros.

B. If a unit does not wish or does not meet the conditions to participate in the competitive process for inclusion in operating aid, the reference values ​​for connection to the Electricity Distribution Network are set as follows: until 30-04-2021, at 65, 7 euros / MWh and from 01-05-2021 to 63 euros / MWh.

* Similar conditions apply to wind farms.

Activation of the connection after the completion of the competitive process (tender):

Following the completion of the competitive process and to ensure the effective implementation of the RES support scheme and the achievement of the national objectives, as described above, the activation of the connection to the Electricity Network (put into trial or normal operation) of the stations selected on the basis of the auction, must take place within a specific deadline from the announcement of the final results. The connection time ranges from twelve (12) to eighteen (18) months concerning the photovoltaic stations depending on their power; and from twenty four (24) to thirty six (36) months for wind farms. An extension of this time by six (6) additional months is also foreseen in case a construction of a new Substation or extension of the existing one is required.

Due to the modernization of environmental legislation and the incorporation into Greek Law of the relevant European Directives, the issue of RES is of increasing interest and especially the last few years, there is investing interest not only from Greek, but also from foreign potential investors. Nexus Law Firm participates as a legal consultant in several competent projects in Greece and acquires the updated knowledge and experience regarding the licensing procedures of RES stations and interconnection with the Electricity Distribution Network.