Dear PRIME MINISTER, Dear MINISTER, in the context of the public electronic consultation of the Law: "MODERNIZATION OF THE LICENSING PROCEDURE FOR RENEWABLE ENERGY SOURCES - PHASE 2, ELECTRICITY PRODUCTION AND STORAGE LICENSING, DEVELOPMENT FRAMEWORK OF PILOT MARINE FLOATING PHOTOVOLTAIC STATIONS AND SPECIAL PROVISIONS FOR ENERGY AND ENVIRONMENTAL PROTECTION », we present to you our suggestions for its improvement.
Western Macedonia and its inhabitants pay a heavy price (economic and social) because of de-lignification and are entitled to actively participate in the new environment concerning the development of RES in the region.
So, The RES sector and especially the photovoltaic sector was a choice for thousands of small investors in our area, who either individually, or through Energy Communities, rushed to submit hundreds of applications to HEDNO, to provide even one grid connection offer for projects up to 1MW.
However, due to the saturation of the HEDNO network, the individual micro-investors (for projects up to 500 Kw) and Energy Communities (for projects up to 1MW), have already received a negative response from HEDNO to their requests.
The only solution after the inability of HEDNO to satisfy the requests, was the submission of joint group requests to IPTO for the issuance of a Final Connection Offer in accordance with article 135 of law 4685/20120, with the possibility of connection to the High and Ultra High Voltage through private substations. As is well known, grouped RES stations requests consist of many small projects of local individuals and energy communities, who have been active in the area for years and support their place.
However, this process of issuing connection offers is delayed for many months, creating a climate of uncertainty and frustration for potential small investors.
Given the fact that, the active participation of the local community in the energy transition, will curb the tendency to leave the area and will give immediate and satisfactory financial results,
We propose and request that the activities and initiatives of the local community be strengthened in every way, concerning RES development projects in demilitarization areas.
- By legislation or ministerial decision to ensure that: "In the areas of de-lignification (Western Macedonia and Megalopolis), grouped requests of RES and SITHYA stations that are exempted from the issuance of a Production License / Producer Certificate and submitted to IPTO for issuance of a Final Connection Offer in accordance with article 135 of law 4685/20120, to be examined with absolute priority by HEDNO and IPTO.
In particular, this applies to requests from Energy Communities over 60 members (of which 50 members are at least natural persons, due to the many families involved)
- Energy Communities above 60 members, of which 50 members are at least natural persons, to have a guarantee (10,5) euros per Kw for the part of power up to (1) megawatt (MW). All other Energy Communities have a guarantee 21 euros per Kw for the part of power up to (1) megawatt (MW) .
- Division of private land. In the same plot of low or high productivity to allow the construction of power stations up to 2 MW from different Energy Communities over 60 members and only in the areas of Kozani, Florina, Megalopolis due Depoliticization and lack of land.
- Division of public and private forest areas. In the same area to allow the construction of stations by Energy Communities above 60 members and only in the areas of Kozani, Florina, Megalopolis because of Depoliticization and lack of land.
- Energy Communities above 60 members, of which 50 members are at least natural persons, who have projects virtual net metering, to be able to include them in the Development Law. Announce a special energy clearing program (Net metering) for de-ligation areas, which includes Photovoltaics on the roofs of businesses-agricultural installations and houses with simultaneous installation of modern heating and cooling systems (eg heat pumps).
- All Energy Communities (especially those above 60 members of which 50 members are at least natural persons) in the areas of Kozani, Florina, Megalopolis because of Depoliticization, have an extension of one additional year for the reference prices for non-competitive projects, compared to the rest of the country.
- The Ephorate of Antiquities to allow the construction of photovoltaic works at a distance 500 meters from the Archaeological site.
- To allocate sufficient space in the former mines (Depoliticization zone) to develop power projects of at least 400MW through local energy communities, with virtual energy offset (Virtual Net metering) to meet the energy needs of the Regional Authority, of the Municipalities, of farmers, businesses and households. At the same time to enable the connection of these projects to the existing substations of the lignite plants.
- Immediate upgrade of all substations and Medium Voltage networks in the depoliticization areas, to create additional electrical space to absorb the energy produced, to enable the approval of the hundreds of applications pending at HEDNO by small local investors.
- Suspension until 31/12/2022 in the petrification areas 5 of observations, of Annex X of the group 10 of the article 4 of N. 4014/2011 as it was added with by 24/02/2022 decision of RIS (ΥΠΕΝ / ΔΙΠΑ / 17185/1069 / 24-02-22), so that new grouped requests of the article can be submitted 135 of N. 4685/2020 to IPTO based on the prevailing provisions.
All the inhabitants of West. Macedonia we want and we can reverse the negative data of the time. We can immediately address the negative effects of violence de-lignification of our area, as a unique opportunity to create a new dynamic industry that will produce useful clean energy and will consist of hundreds of small investors and employees.
However, we also ask the political leadership to take the necessary measures to enable such a development..
The D. Σ.
THE PRESIDENT THE SECRETARY