Αρχική Ρυθμίσεις για την εξυγίανση ειδικού λογαριασμούΆρθρο 01: Επανακαθορισμός στοιχείων τιμολόγησης ηλεκτρικής ενέργειας λειτουργούντων σταθμών ΑΠΕ και ΣΗΘΥΑΣχόλιο του χρήστη Θοδωρής Θεοδωρόπουλος | 13 Μαρτίου 2014, 13:11
  • Σχόλιο του χρήστη 'Θοδωρής Θεοδωρόπουλος' | 13 Μαρτίου 2014, 13:11

    To: Gabriella.SZIJ Cc: paula.abreu-marques Sent: Sun, Mar 9, 2014 4:12 pm Subject: Proposed Legislation in Greece breaking existing contracts on Renewable Energy European Commission Directorate General for Energy DM24 4/138 B-1049 Brussels/Belgium Dear Ms President, I am writing to you to inform you and kindly to request your intervention regarding the following proposed Law, undergoing public consultation in Greece, until 13/03/2014. Such intervention could include, but not be limited to, your request for clarification from the Greek Ministry responsible for Energy and the Environment. http://www.opengov.gr/minenv/?p=5730 This legislation contravenes multiple aspects not only of the Greek Constitution but also of European Law: - It attempts a blatant one-sided break of existing 20-year/25-year contracts on electricity sales to public sector vehicles such as LAGIE (http://www.lagie.gr/) and DEDDIE (http://www.deddie.gr/). It introduces tariff reductions to the tune of up to 60% of annual Photovoltaic plant turnover. Such contracts were drafted by the Greek State itself, with no investor intervention, aiming to provide the intensely advertised guaranteed returns that would help develop the renewable energy market at the time. - It attempts to modify competition using a model aiming to cross-subsidise PV electricity producers to equalise their returns retrospectively. Further, the model is to a great extent inaccurate as well. It uses, among other factors, the date of connection to the grid, which was not under the investors’ control. In addition, one-day delay in connection years ago, can now take the investment to the next quarter in the calendar year, introducing a tariff difference of 0.2 Euro/Kwh or more for the life of the plant. - It provides for a compulsory refund of 35% of last year's PV plant turnover (2013). This amount has already been invoiced and will be taxed multiplied by a factor of 1.8 in the case of most investors. This is because taxable income of 2013 is used as a yardstick for the taxable income of 2014, which needs to be prepaid at the rate of 80%. The investors should somehow fund all this in a business environment where banking loans are unavailable at reasonable interest rates. - It differentiates investors with identical power plants of the same cost and age in the same area, increasing the tariff by 10% if someone simply declares himself a farmer and reducing the tariff by 10% if a farmer sells the plant to a non-farmer. Beyond the legal issues, the proposed law is also fundamentally misguided, and does not address the main reasons behind the inability of the aforementioned entities currently to make timely payments to producers: - The accounting deficit of LAGIE, the special purpose vehicle set up to fund the renewable energy market, is no longer increasing but its liquidity deficit is. The suspension of payments is caused partly by a severe lack of liquidity of the Public Power Corporation, owned by the Greek State. PPC suffers from its distribution operations, due to the inclusion of significant real estate taxes on the electricity bills it issues to consumers. Many cannot afford to pay these bills. In addition, there is need for a complete rethink of what LAGIE is responsible to pay for: Only half of its historical income has in fact found its way to Electricity Producers using renewable energy. The other half has been directed to natural gas, etc. - DEDDIE does not even have a deficit. It is the contractual counterparty to the producer when energy is sold on Greek islands not connected to the mainland country grid. The renewable energy mix there, combined with the relevant tariffs, costs the same as the energy production technologies it replaces, which are using diesel fuel, etc. However, renewable energy investors there are similarly penalised in the proposed law as those on the mainland. Many thanks in anticipation and kind regards,