New energy regulations in Greece
Introduction
(Article by Mira Todorovic Symeonides – Partner and Alexandra Daniil – Associate, published in the Energy & Natural Resources Newsletter of the ILO on October 4, 2021)
In July 2021 Law 4819/2021 (OJ A’ 129/23.7.2021) (the Law) introduced certain immediate regulations into the Greek energy sector.
These measures particularly provide for:
- the suspension of new applications and licences for renewable energy source (RES) hybrid plants and RES plants with storage;
- the obligation of RES production certificate holders to provide letters of guarantee;
- amendments regarding the priority of applications for connection to the grid; and
- exceptions for connection to saturated grids.
Suspension of new applications and licences
Up until 31 December 2024, the Law suspends submitting applications to the Regulatory Authority for Energy (RAE) and issuing new production certicates for hybrid RES plants on the interconnected islands or islands that are to be connected to the interconnected system in 2019–2028. In addition, up until 31 December 2021, the Law suspends submitting applications and issuing production licences, environmental approvals and binding offers for the connection to the grid to RES production plants with storage system. Plants with pumping storage are excluded. The above suspension does not apply to applications amending already issued production licences, and certificates for projects on Crete and other non-interconnected islands.
Obligation to provide to letter of guarantee to RAE
The Law introduces the obligation to provide the RAE with a letter of guarantee as a condition of the issuance of a producer certicate or a special projects production certicate. The amount of the guarantee required depends on the capacity of the future plant for which the production certicate is issued, and it is equal to €35,000 per
megawatt. The amount of guarantee may be amended by a decision of the minister of environment and energy.
This obligation also applies to holders of RES production certicates that were issued before the Law entered into force if such holders did not manage to submit the application for issuing the nal connection terms to the grid operator for up until 28 February 2022. If the holders fail to provide the letter of guarantee for up until 28 February 2021, the respective production certicates will automatically be invalidated.
The main exceptions from this obligation are:
- plants with a maximum production capacity below or equal to 1 megawatt;
- plants that were, before the Law entered into force, approved to be strategic investments in compliance with Law 3894/2010 (Α’ 204) or Law 4608/2019 (Α’ 66); and
- certain local government authorities and entities fullling publicly benecial purposes, other than energy communities, such as hospitals, health centres and all schools.
The above guarantees are returned to the production certicate holder following:
- the holder submitting an application for issuing the final connection terms with all of the required documents to the grid
operator, which should be conrmed in writing by the grid operator; or - the production certificate holder applying for the return of the letter of guarantee; in which case, the respective production certificates will automatically be invalidated.
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