Overcoming RES Permitting and Grid Access Barriers in Greece
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1 GREEK ASSOCIATION OF RES ELECTRICITY PRODUCERS Overcoming RES Permitting and Grid Access Barriers in Greece A short presentation for the 9 th Workshop of the International Feed-In Cooperation Friday, 27 January 2012
2 LARGE SCALE INTEGRATION OF RE POWER INTO THE GREEK ENERGY SYSTEM According to the EU Directive 2009/28/EC in reference to the promotion of Renewable Energy Sources (RES), Greece has agreed to achieve at least an 18% share of RES in the national final energy consumption by the year The Law for the acceleration of the development of RES in order to deal with the climate change, which was approved by the Greek Parliament in June 2010, sets the actual target at 20% and further specifies that RES electricity should account for at least 40% of the gross national electricity consumption by Wind power is expected to contribute heavily towards reaching these targets. A total of 7,500 MW of wind capacity will have to be installed by By comparison the installed wind capacity in Greece was in the vicinity of 1,500 MW at the end of 2011.
3 LARGE SCALE WIND POWER INTEGRATION : CRITICAL ISSUES The prospective large-scale integration of RES wind farms in the Greek energy system, will require extensive upgrading/expansion of the national electricity grid. Various studies have shown that the upgrading/extension works, already under way on the interconnected electricity grid (mainland), can accommodate the integration of about 5,000-5,500 MW of wind parks into the national electricity system by 2013, without any major operational stability problems. However, further expansion of the grid, in order to accommodate the 2020 national RES targets, especially the 7,500 MW of wind farms, will require major changes in the structure and operation of the entire national electricity production and transmission system, such as : i) Interconnection of the windy, electrically autonomous islands of the Aegean Sea to the mainland (already planned to be carried out in the period) coupled with the installation of large wind farms in selected islands; ii) Selection of the type of new fossil fuel plants, to be built and connected to the national electricity system, based -at least in part- on their capacity to collaborate effectively with the stochastic, time variable, wind energy production (e.g. gas turbines, hydro plants, etc.); iii) Large-scale development and utilisation of new and efficient-technically and economically-energy storage systems, such as pumped storage hydro, RES hybrid units, etc.; iv) Application of new technologies such as deep sea offshore wind farms, floating wind turbines, etc.; v) Upgrading the national Grid, at least in part, to the smart level; vi) Significant increase in the number and transmission capacity of the interconnections between the Greek and the European electricity grids (e.g. Greece-Italy, Greece-Central Europe, Greece-Turkey, etc.).
4 KEY BARRIERS TO THE FURTHER DEVELOPMENT OF RES PROJECTS a. The licensing procedures remain complex, involving a multitude of central, regional, prefectural and local authorities. Efforts to simplify them and to reduce the time required to successfully navigate through the procedural maze are on-going. b. The limited capacity of the power transmission grid, especially in regions of high wind potential (Thrace, Evia, Lakonia, Cycladic Islands). Plans for upgrading the transmission grid have been drawn by the national Transmission System Operator (DESMIE) and the PPC but their materialization is slow due to difficulties in land expropriation and the construction of HV power lines passing through environmentally sensitive areas or laid on sea beds. Grid saturation, in addition to causing delays in the installation of licensed wind capacity, forces a shift towards development of areas and sites with moderate or low wind potential. c. Delays and problems with the application of the recently adopted National RES Space Planning Provisions usually associated with judicial appeals to the Council of the State. d. Environmental and socio-economic concerns of the general public in reference to renewable energy. Despite an overall positive public perception of renewables and the implementation of information/dissemination campaigns sponsored by the State and relevant stakeholders, a strong NIMBY ( Not In My Back Yard ) component is still evident.
5 OTHER BARRIERS RELATED TO THE APPLICATION OF THE NEW NATIONAL RES SPACE PLANNING FRAMEWORK The national RES space planning framework went, for the first time, into effect at the end of 2008 (CMD 49828/ ), following four (4) years of relevant studies, deliberations and final preparation. Many appeals to the Council of the State (CS) have been launched already, challenging the constitutionality of certain provisions of the framework. This has increased the ambiguity as to the actual time frame for the application of its provisions and has further undermined RES investment security. Difficulties in the application of the specific, detailed provisions of the new RES space planning framework do exist, because of the lack of detailed geographical data bases, required to accurately estimate and apply allowable distances of RES installations from the so-called incompatible uses. As a result, the investor/developer is forced to carry out all relevant work himself and then to get the approval for it from the various opinion-granting Authorities. This is associated with the more general problem of the national Administration, namely the ill-defined land uses and areas (lack of Land and Forest Registries). Other difficulties are related to the national and local Archaeological Services who raise objections related to the visual intrusion and the aesthetic degradation caused by RES installations and to the Ministry of Tourism, which is unable to supply the required GIS and other data on existing touristic infrastructure.
6 SCHEMATIC DIAGRAM OF THE LICENSING PROCEDURE FOR RES PROJECTS UNTIL JUNE 2010 (Critical steps only) Major Characteristic : Sequential processing of applications SES or Region Ministry of Agriculture or Region Applications P.E.I.A. R.Α.Ε. R.A.E. Opinion Ministry of Development Intervention Approval S.E.S. or Region E.T.A. Request for Installation Ministry of Development or Region Installation Generation N.T.S.O. Connection Offer Ministry of Development or Region Data submission Installation P.E.I.A : Preliminary Environmental Impact Assessment R.A.E. : Regulatory Authority for Energy S.E.S. : Special Environment Service N.T.S.O.: National Transmission System Operator E.T.A : Environmental Terms Approval Result : Huge Delays
7 SCHEMATIC DIAGRAM OF THE LICENSING PROCEDURE FOR RES PROJECTS AFTER JUNE 2010 (Critical steps only) A hybrid sequential / parallel application processing scheme Applications R.A.E. (Technicoeconomical evaluation / Consistency with RES SPF) N.T.S.O. (1) Preliminary Connection Approval Opinion giving Authorities and Prefectural Council Request for Installation M.E.N.E.C. and Region Installation Award (MD or R.G.C.D.) Generation M.E.N.E.C. Notification S.E.S. / Region E.T.A. Submission of E.I.A. Final Connection Offer Regional Forestry Division Intervention Approval Submission of request for Intervention Approval N.T.S.O. (2) Request for Final Connection Offer M.E.N.E.C : Ministry of Environment, Energy and Climatic Change R.A.E. : Regulatory Authority for Energy S.E.S. : Special Environment Service N.T.S.O. : National Transmission System Operator E.T.A : Environmental Terms Approval E.I.A. : Environmental Impact Assessment R.G.C.D. : Regional General Secretariat Decision S.P.F : Space Planning Framework Installation Protocol and Urban Planning Should reduce the required licensing time by months (3.5-4 years)
8 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (1) Barrier Lack of objective criteria in reference to the content of the opinion giving / permitting authority PERMITTING Suggested Practice to Overcome The opinion giving / permitting authority should be required to fill out a simple, pre-specified questionnaire Significant delays in the responses of the opinion giving and permitting authorities despite binding response times which are clearly defined in the Law Unknown!!! Exercise political will?
9 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (2) Barrier PERMITTING Suggested Practice to Overcome A lot of paperwork is required to revise the various acquired permits and licenses even for minor changes in the station s layout Lift the requirement to revise the station s installation license for non major changes within the licensed installation area. Request the full notification of the responsible authorities instead A variety of contradictory legal provisions concerning the protection of the environment in combination with the lack of a land and forest registry The creation of an environmental legislative umbrella which will supersede all other legal provisions Give the authority to the Assistance Office for RES investments to interpret and apply all the legal provisions related to RES projects
10 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (3) GRID ACCESS Barrier Blocking of available networks by projects whose implementation is delayed Suggested Practice to Overcome Review problematic projects and wave on a case by case basis their connection agreement with the TSO (licensed projects) Award initially preliminary, non binding connection agreement terms. Award binding connection agreement terms when the project reaches licensing maturity (new projects)
11 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (4) GRID ACCESS Barrier Delayed network reinforcement and expansion Network Design Suggested Practice to Overcome Switch design philosophy from how should I integrate the incoming new RES capacity into the existing system to how should I change the system to achieve the specific high RES penetration targets set Expedite required studies on pump storage, interconnections, grid expansion, new networks
12 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (5) GRID ACCESS Barrier Delayed network reinforcement and expansion Network Construction Suggested Practice to Overcome Increase the administrative and technical personnel of the responsible public authorities Reinforce the participation of the private sector in all aspects of the construction of the networks Financing of new networks at a time of crisis Pursue private co-financing of the public networks in exchange for shares in the new TSO, etc Allow for BOOT schemes
13 OVERCOMING ADMINISTRATIVE AND PLANNING BARRIERS (6) GRID ACCESS Barrier Suggested Practice to Overcome Cost definition and allocation for the construction of infrastructure and use (substations / HV lines) which are shared by groups of users Switch from a case-by-case management philosophy to setting more general, fair rules
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