By Dimitris Assimakis
Partner, Reed Smith LLP
Overview of the main legislative proposals for the further streamlining of the process for the licensing of renewable energy projects that are under consideration by the Greek Ministry of Environment and Energy:
- Establishment of a single point of contact for RES investors and digitalisation of the whole licensing process up to the award of the Operation Licence.
- Limitation of the requested documentation and data for the granting of the Grid Connection Offer, the conclusion of the Grid Connection Agreement and the award of the Installation Licence and the Operation Licence. Abolition of the non-binding (preliminary) Grid Connection Offer licensing step.
- Submission of a bank guarantee upon the application for the granting of the Grid Connection Offer and not upon the acceptance of the offer, as it is the case now.
- Limitation of the cases necessitating the modification of the Grid Connection Offer, the Grid Connection Agreement, the Installation Licence and the Operation Licence.
- Introduction of a more flexible application framework for the granting of the Gird Connection Offer and a more flexible process for the energisation of the connection of new power plants to the grid.
- Land titles audit from external lawyers in case the land wherein a project is going to be installed is owned by a private party.
- Breaking up of the Grid Connection Agreement in two distinct parts i.e. the Main Part and the (project specific technical) Supplement; and partial disassociation of this agreement from the Installation Licence.
- Introduction of exclusive deadlines for the filing of an application for the award of the Installation Licence as from the time of issuance of the Grid Connection Offer.
- Possibility to extend the term of the Grid Connection Offer and the period within which the developer has to apply for the award of the Installation Licence against the payment of a relevant fee.
- Periodic publication of data from the competent grid operators (TSO /DSO) on the status of the applications for the granting of Grid Connection Offers, as well as of the status of the Grid Connection Offers granted and the Grid Connection Agreements signed, together with adequate info relating to the local grid and the development of the grid connection works associated with any such offers and agreements.
- Introduction of a special framework for the licensing of energy storage units.
- Addressing various issues relating to forestry legislation and their interface with the RES licensing process (e.g. intervention permit, reforestation process, forestry road network).
- Introduction of a simple notification scheme for the licensing of micro power generating facilities that are connected to the distribution network.