Αρχική ΕΚΣΥΓΧΡΟΝΙΣΜΟΣ ΤΟΥ ΠΛΑΙΣΙΟΥ ΤΩΝ ΥΠΗΡΕΣΙΩΝ ΥΔΡΕΥΣΗΣ ΚΑΙ ΑΠΟΧΕΤΕΥΣΗΣ ΚΑΙ ΕΠΕΙΓΟΥΣΕΣ ΕΝΕΡΓΕΙΑΚΕΣ ΚΑΙ ΠΟΛΕΟΔΟΜΙΚΕΣ ΡΥΘΜΙΣΕΙΣΜΕΡΟΣ ΣΤ΄ ΕΠΕΙΓΟΥΣΕΣ ΕΝΕΡΓΕΙΑΚΕΣ ΚΑΙ ΠΟΛΕΟΔΟΜΙΚΕΣ ΡΥΘΜΙΣΕΙΣ (άρθρα 70-79)Σχόλιο του χρήστη Sunrider S.A. (A wholly-owned subsidiary of Cero Generation Holdings Greece Limited) | 27 Φεβρουαρίου 2025, 18:39
  • Σχόλιο του χρήστη 'Sunrider S.A. (A wholly-owned subsidiary of Cero Generation Holdings Greece Limited)' | 27 Φεβρουαρίου 2025, 18:39

    We respond to this consultation on behalf of Sunrider S.A., a wholly-owned subsidiary of Cero Generation Holdings Greece Limited, a solar and battery developer with a large pipeline of projects in Greece. Given our position in the market, we appreciate the opportunity to provide feedback on the current consultation regarding grid curtailment proposals. However, having reviewed the proposals, we have serious concerns about their impact on the renewable energy market. These concerns are set out below, along with our suggestions for improvement, which we believe are essential for the fair and effective implementation of these proposals. 1. Financial Compensation We are very concerned by the proposals under Article 72, which would mean that IPTO and HEDNO shall not be obliged to provide any compensation for the energy that is not injected from RES projects due to Injection Curtailment Orders issued by IPTO or HEDNO, when such orders are imposed: (a) for the maintenance of necessary reserves or for other reasons related to the secure operation of the system or the grid, or (b) due to local congestion. Financial compensation is crucial to mitigate the economic impact on developers and ensure the viability of renewable energy projects. Without such compensation, the financial risks associated with grid curtailments will significantly deter investment in the Greek renewable energy and storage market,, thereby undermining our collective goals for renewable energy expansion and sustainability. In addition, broadly exempting IPTO and HEDNO from providing compensation to curtailed RES projects provides no incentive for them to minimise curtailments and manage the system in the most economically efficient manner. We would like to further draw the Ministry’s attention to Article 13 of EU Regulation 2019/943 (the Regulation). Article 13(7) states that “where non-market based redispatching is used, it shall be subject to financial compensation by the system operator requesting the redispatching to the operator of the redispatched generation, energy storage or demand response facility except in the case of producers that have accepted a connection agreement under which there is no guarantee of firm delivery of energy”. 2. Curtailment Methodology Furthermore, Article 13(1) of the Regulation states that “the redispatching of generation and redispatching of demand response shall be based on objective, transparent and non-discriminatory criteria”. The current methodology and decision-making process for curtailing transmission-connected renewable generation projects is unclear and lacks objective parameters which ensure transparency and equality in the implementation of power curtailments. We urge that this process be rules-based, with transparent criteria for determining which projects will be curtailed first, and by how much. Curtailments should not be left to the sole discretion of the system operators, as this risks creating a perception of an arbitrary and unfair decision-making process (inevitably increasing the likelihood of judicial challenges to such decisions). A clear, rules-based methodology will provide developers with the predictability and transparency needed to make informed investment decisions. For example, the implementation of the following measures could help to address some of our concerns: •⁠ The system operators should consider the flexibility of different RES technologies when applying curtailments. • The system operators should publish periodic curtailment records and provide justifications for each event, in order to improve accountability for their decision-making. • RAAEY should audit and publish reports on curtailments. • ⁠Market participants should have the right to challenge curtailment decisions. We strongly urge you to consider our feedback, and hope that our concerns and proposals will be considered in the finalisation of the proposed reforms. Addressing these issues is vital for maintaining investor confidence and ensuring the continued growth and success of the renewable energy sector. We look forward to further engagement on this matter and are available for any discussions or clarifications needed. Thank you for your attention to these important matters.