Renewable Electricity and Liberalised Markets REALM. JOULE-III Project JOR3-CT GREECE ACTION PLAN. By ICCS / NTUA K. Delkis

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1 Renewable Electricity and Liberalised Markets REALM JOULE-III Project JOR3-CT GREECE ACTION PLAN By ICCS / NTUA K. Delkis October 1999

2 INTRODUCTION AND BACKGROUND Background to Renewable Energy in the Electricity Sector Electricity from hydro and wind energy is generated in Greece by PPC, Autoproducers (APs, that is entities generating electricity for their own needs but also selling any surplus back to the grid), and Independent Producers (IPs, that is entities generating and selling it directly to the grid). Concerning renewables, PPC is the owner of the total large-hydro installed capacity and most of the small-hydro installed capacity (in the order of 2,800 MW) as well as of about 25 MW (62 %) of the installed wind capacity, totaling 40 MW in Under PPC ownership are also about 250 kwp of photovoltaics Two small hydro plants (totaling 1.5 MW) belong to municipalities. Several others also owned by municipalities are under construction. It is expected for 1999 the commitment of additional 55 MW wind and 9MW small hydro, belonging to IPPs and APs, while next year more than 150 MW wind will be put in operation. The total generation from renewables covers about 10% of total electricity demand of Greece, the bulk of which relate to large hydro. Since the early 80s new renewable energy technologies (NRETs, mainly PV, wind, geothermal), but also small hydro, became of concern to PPC, mainly because of environmental reasons but also because of the possibilities provided by the new energy conversion technologies to further exploit indigenous energy resources. Notice that for the autonomous systems of small and medium size islands, wind energy is among the least cost options for electricity generation (high wind potential at high cost of electricity production from oil). From a utility s perspective, wind energy was considered as a near to commercial maturity technology. During the 80s and until mid-90s, PPC installed more than 20 MW of wind capacity, mainly in the islands. Most of these installations were co-funded by various EU Programmes (Demonstration, Mediterranean Integrated Programmes, VALOREN, THERMIE) and investment subsidies were provided by the Greek Government. The current attractive buyback tariffs for renewable energy in Greece and subsidies for related investments (see below) also implied a growing interest for private investments in the area of RES. Legislative framework Until 1985, PPC had the exclusive right for generation, transmission and distribution of electricity in Greece. The Law 1559 of 85, gave to some entities the right to generate electricity ( Autoproducers ), in order to cover their own needs. Any surplus of electricity generated by the grid-connected APs was sold to the grid. On the other hand, PPC was obliged to buy that excess energy, unless technical reasons did not allow the transmission and distribution of this energy to consumers. The selling prices provided to the autoproducers for their excess energy were calculated on the basis of avoidance cost for PPC, in other words relating to the operation cost of the marginal power station during typical days. Apparently, the values of these selling prices were not attractive to potential autoproducers, since in the years following the enactment of Law 1559/85 no investments were materialised 2

3 in the area of RES. It was evident that since in a free market environment the prices reflect the marginal operation cost, the utilisation of RES was not economically justified and therefore new measures had to be introduced in order to facilitate the desired penetration of RES to the generation system of Greece. In 1994 Law 2244/1994 substituted for L.1559/85. The current legislative framework for promoting RES applications is defined as follows: The Law for regulation of electricity generation from RES (2244/94), allowed entities other than the Public Power Corporation, such as auto-producers (APs), Independent producers (IPs), and Local Authorities, to generate electricity under the restriction of selling all electricity produced to the PPC at a pre-specified price. The regulatory instrument / incentive scheme is obviously Feed - in tariffs based on a fixed level set by authorities. The Economic Development Law - EDL 2601/98 allows for a maximum subsidy of 45% applied to investment in generation from renewables. The subsidy can be direct or take the form of reduced loan interest rates, tax credits, increased depreciation rates etc. The regulatory instrument / incentive scheme is Fixed investment subsidies. An additional instrument for the RES development is the 2nd Framework Support Programme ( ) based on the Community Structural Funds. The Operational Sub-Programme for Energy foresees financing by 240 MEURO (EU, national funds and private funds) of RES projects (130 MW wind, 73 MW small hydro). The main provisions of L.2244/94 are as follows: Two categories of electricity producers are defined: autoproducers (APs), and Independent producers (IPPs) Capacity limits for IPPs are set to 50 MW APs compensate electricity consumption from the P.P.C. network with production from RES (up to 80-90%) Licensing procedures are simplified Tariffs are correlated with the kwh selling prices (70-90% of the retail price). In practice under this law, highly attractive tariffs are introduced. P.P.C., under 10-year contracting, has the obligation to purchase all energy produced, except if technical constraints of the system do not allow for. Due to stability and operating constraints of the conventional oil units used for electricity generation, the penetration of intermittent RES in island grids is limited to 30% of peak load of previous year. P.P.C. remains the exclusive supplier of third parties with electricity. Currently the Law 2244/94 is under revision, within the process of establishing the new legislation to implement the electricity liberalisation directive. There are also concrete plans to continue financing investments in RES under the 3rd Framework Support Programme ( ) based on the Community Structural Funds. Market Liberalisation The relevant legislation dealing with the major issue of energy market deregulation / liberalisation in Greece is not foreseen to be established before the end of year According to a preliminary version of the legislation, which is under discussion within relevant bodies (Ministry, PPC, etc.), market liberalisation will be introduced on the 19 th of February 2001 (involving opening up of 30% of the market). This will affect the entire system of the mainland system, whereas in involving open market plant procurement the autonomous island 3

4 systems liberalisation will be restricted to the generation system only. According to the initial version of legislation the following comments can be made: access to the grid Access to the grid will be provided by a new entity, the Independent System Operator (ISO). Access can have all owners of license for electricity generation or electricity trade. ISO will have access to the Transmission System. degree of vertical integration of utilities Public Power Corporation (PPC) will administratively split in separate and independent entities. PPC will lose the exclusive right to generate electricity from conventional fuels in the mainland system of Greece. At the same time PPC will continue to own the transmission system as well as to own and operate the distribution system. The transmission system will be operated by a separate independent entity, the ISO. In the autonomous islands systems, PPC will continue to have exclusive rights on the transmission and distribution systems. number and type of consumers who are free to choose their suppliers From 19/2/2001, eligible consumers, that is 450 industrial consumers consuming over 2 GWh/year (30% of the market), located within the interconnected (mainland) system of Greece, will have the right to enter in agreement with suppliers of electricity. degree of government intervention in the market (e.g., restrictions on adding new capacity of certain types of generation, supports to particular types of generators, etc.). The license for electricity generation will be awarded by the Ministry for Development, following recommendation by the Regulator, a new public entity. For electricity supply purposes, eligible consumers or producers will obtain license by the Ministry for Development, following recommendation by the Regulator. degree of openness to imports from and exports to other countries There is no explicit reference to imports and exports under the new regime. An eligible electricity supplier should demonstrate access to adequate generating capacity reserve installed within the EU member states. It is expected that the deregulation of the market will not strongly affect the exploitation of renewables in the islands (mainly wind energy) due to high wind potential and to high cost of electricity generation from conventional fossil fuels. In the mainland system concerns about the future of renewables arise due to the foreseen competition in generation and the generally lower generation costs. This situation might lead to the need for additional policy measures promoting renewables. These measures have generally to be compatible with the EC Directive 96/92 and the legislation of the other member-states in order to avoid market distortions. Industry and Utility perspective under the current regulatory regime Industry perspective Under the present circumstances, hence before market liberalisation, the current legislative framework is attractive to independent producers, either APs or IPPs. Following the enactment of L 2244/94, in conjunction with the 2nd Framework Support Programme ( ), many APs and IPPs submitted applications for licences to produce electricity from RES, mainly wind. These license applications represent total power of 1200 MW 4

5 corresponding to 12% of the total installed generation capacity in Greece. This total power is theoretical since many of these applications have not materialized into a licence. Already in 1999 and 2000 more than 215MW will be put in operation, belonging to IPPs and APs. The large number of licence applications indicate that the current legislative framework is highly effective as it ensures a stable economic environment with reasonable economic returns for private investors in the area of RES. However there are still barriers that have prevented some of the private investors to materialized their application for licence. These barriers relate to the following: There is insufficient infrastructure for transmission and distribution systems in areas with high wind potential (Evia, Lakonia and Argolida in Peloponisos) limiting because of bottlenecks, transferring large quantities of energy generated by RES to the load centers. The load centers usually are located far from areas with high potential of RES. In the autonomous systems of small and medium size islands with high potential in RES, grid operation constraints add limits to their further development. More specifically the main problems, which the IPPs face, are: Inability or high costs of PPC to connect wind parks to the grid due to lack of infrastructure. High connection cost of wind parks to the grid, due to land morphology since promising in RES sites are in the mountains and far away from the transmmission network. To alleviate this problem, network reinforcement and expansion is required. This problem is critical for RES exploitation in Greece. In islands, for technical reasons (stability, quality of power, and frequency control), PPC is obliged to put wind parks out of operation for certain hours during the day, especially in low demand hours. For the above reasons, the penetration of generation by RES is generally restricted to 30% of maximum annual demand of the previous year. This problem can be resolved if the autonomous system of the island were connected to the mainland. The complicated and time consuming procedure for legal permits also implied postponing or cancelling some of the investments in the area of RES. In general, Independent Producers have epxressed preference in favour of preserving the current policy setting and measures ("Direct Government Subsidies on Investments" and "Feed in tariffs" ). They have also asked for higher support in the area of the improvement of the infrastructure of the transmission and distribution systems and the simplification of the licence permits. Utility perspective Until recently, PPC was shown a small interest in investing into RES, except small islands, where the production cost from conventional units is high. This policy was also dictated by the time consuming procedures required for site selection, call for tenders, etc. To alleviate these problems, PPC recently established a limited company, titled PPC RENEWABLES S.A, for the development of RES in Greece (design, construction, operation and management of power stations). The new company can also participate in joint ventures with others companies active in the area of RES. PPC is facing the following problems under the current legislative framework: PPC is requested to face development of high cost infrastructure in transmission and distribution systems in areas promising in RES. PPC is hesitant to assume the cost for this development since the required amounts are considerable and the risk of not profitable pay back. 5

6 Any fast and large penetration of wind parks might imply underutilization of some of the existing PPC s generation units. Also in certain cases, the installation of a large number of small hydro units might affect the operation and the development of large hydro projects sharing the same water basin. PPC is obliged to purchase from the independent producers the whole energy generated at prices often higher than the avoidance cost of PPC, in particular when RES operates in the interconnected system. In the future, under the liberalised market regime, such an obligation is expected to be transfered from PPC to the independent systems operator. As inofficcially expressed PPC is not generally against the continuation of the existing policy, incentives for RES but asks for support in financing the infrastructure and manage under more competitive terms the gradual penetration of RES in the interconnected system. 6

7 RECOMMENDED CHANGES TO THE CURRENT REGULATORY REGIME Current energy policy and targets for RES The development of RES applications constitutes one of the highest priorities for the Greek energy policy. The exploitation of the high RES potential is expected to contribute substantially to the protection of environment, to regional development and employment. In the medium term, it is anticipated that the current policy for incentives and measures will continue promoting further penetration of the most efficient RES technologies, and sites. Under the new regulations framework, it is also expected that legislation will adapt these policies and measures so as to minimize adverse effects and market distortions. The prevailing policy principle is however to continue providing private investors with highly attractive conditions. The objective is to obtain by % of total demand for electricity from new and small RES. More specifically, the intentions are: The development through public and community funds of infrastructure in transmission and distribution networks in the areas having high wind potential in order to increase the capability of transferring wind energy to load centers and at the same time to reduce the connection cost of the wind parks to the grid. It should be noticed that the new regulatory environment facilitates the implementation of other measures to support RES, such as the system of biddings and green certificates. The improvement of the utilization of the installations by gradually reducing the subsidy of the investments and the compensation of costs through the selling price of energy. The gradual incorporation of environmental costs in the prices of fuels would also promote RES. For the foreseeable future it is expected to give priority to the dispatching of wind energy under the ISO management. A series of measures that will simplify the procedures for licence permits. Liberalisation and regulatory regime to support RES It is well accepted that in a liberalised energy market protective measures should be taken to support penetration of RES. The major problem is the definition and implementation of those policy measures, which result into minimum distortions in the market. From the analysis of the current regulatory regime in Greece, the following comments can be made: a) The "Direct Government Subsidies on Investments" and the "Feed in tariffs" are the most attractive regulatory measures for the producers since they imply low financial risks and reasonable economic returns for private investors and small enterprises. However as explained these measures have adverse effect on other actors of the liberalised electricity market. b) Theoretically policies that reflect external environmental costs on the prices of fossil fuels have the least distortions of the liberalised market. Evidently such policies would favour 7

8 further penetration of RES. It is not however enviseagable to implement such policies in Greece, except if this decided at a European Union scale. c) Within the new regulatory regime it is impossible to envisage imposing policy constraints at the level of market regulation. For example, an overall obligation to produce a certain percentage of electricity from renewable energies is a possible constraint applicable on dispatching. Such a measure also does not imply distortion to the liberalised market. It is too early to consider such a measure for Greece, given that there is no experience about the operation of the Regulator and the ISO. d) As the second best, the application of the measure "Tradables and Quota on Consumers (Green Certificates)" contributes to the effective operation of the market, but has the disadvantage of price volatility, due to inflexible capacity adjustment in the short run. In a transition period until the effective operation of the market of Green Certificates takes place, this measure must be of low priority for Greece. Measures such as "Direct Government Subsidies on Investments" or with "Feed in tariffs" can help to define indirectly a bottom price of Green Certificates. It should be noticed that the application of the above measure assumes the maturity of the energy market, since it requires the definition of goals in generation by RES at community and national level depending also on the degree of interconnection of national grids. Also this measure is not appropriate in the following specific cases: For small autonomous systems, where the size of production by RES should be under control [for technical reasons, (stability, quality of power, and frequency control)]. The reason is that the market can lead to surplus or deficit, regarding the use of existing capacities. In countries such as Greece where land morphology imposes high additional costs and risks. It is inefficient in such cases to oblige small independent producers to unilaterally face those fixed costs. It is obvious efficient to exploit the economies of scale associated to those fixed costs by enabling, through public policy, industrial associations that will together assume the costs. When there are not strong interties with the grids of other countries to ensure the transfer of possible excess generation by conventional stations. In conclusion, for Greece and for a transition period it is recommended to continue the existing policy measures and at the same time adapt so as to comply with the introduction of competition, for example through bidding procedures or by the reduction in direct subsidy on investments and compensation by means of increased prices. The new revision of law 2244/95 should move to the above directions. Recommendations In view of the emerging liberalised electricity market and the need to adapt the current legislative framework, the following recommendations are proposed for the Greek case: a) In the small autonomous systems of Greece (i.e. islands) there is scope for applying the «bidding» measure to regulate the penetration of RES. In these systems the economics of electricity generation are such that RES production is competitive. Technical reasons related to the operation of the small grid and the variability of demand loads apply upper limits on the penetration of RES. The new regulatory regime as to be applied to the islands preserves the obligation of PPC (as owner of the grid of the island) to purchase RES electricity at prespecified prices. The bidding process will concern the producers of RES and will serve as a tool for managing the dispatching of the RES plants when demand load varies and technical constraints apply on system operation. The bidding process can be seen as providing incentives to RES producers for maintaining their systems in good operation conditions. It will also allow for investing in total above the upper technical constraint, further allowing for higher than presently exploitation of the potential of RES in islands. Under the new legislation the 8

9 bidding process will also concern the construction of new plants, including RES plants. In this context it should be envisaged that public authorities pre-specify the most promising areas and facilitate through land use legislation, the licensing procedure. b) For the interconnected system it is recommended to pursue current policies basically opting for direct government subsidisation of RES investments and feed in tariffs. The operation of the next programme of Community Structural Funds for Greece over the next 5-6 years will ensure funding of direct subsidies, which proved to be efficient for small-scale private investment. The feed in tariffs policy has also proved to be efficient primarily because it reduces the financial risks associated to RES investment and facilitates bank loans. The new regulatory regime will require that all electricity generators, not just PPC, bear the additional costs of the ISO in purchasing excess electricity generated by RES producers. It will be also required to allocate the additional cost burden to all consumer tariffs, including eligible (having direct contracts with producers) and non eligible (supplied by PPC s distribution system) customers. The determination of the tariffs in purchasing RES electricity must be a matter of periodic analysis at the level of the Regulator and ISO. This will allow dynamically adapting those tariffs to the varying conditions of RES supply and will permit evaluating the lower limits for green certificates whenever introduced in the liberalised market. c) Major importance should be attributed to the massive development of RES supporting infrastructure in the mainland of Greece. It is recommended that public authorities define and develop large areas at specifically promising sites (usually mountains) dedicated to the development of wind parks. For such areas, as semi-public managing company will have the authority to invest in the massive development of the RES-supporting infrastructure, including transmission/control systems and lines, roads, buildings, and other services. Funding can be obtained partially from the next Community Structural Funds for Greece. Given the size of such projects and the governmental guarantee, low interest loans can be also obtained. Individual private investors in RES production will be then called to offer for licencing small sites within the area for constructing RES (wind) systems. Such investors will face lower uncertainly than presently and significantly lower fixed costs. Instead they will have to pay licence fees that will add to their operation costs. The benefits from such a policy are numerous: The basic infrastructure will be constructed at least cost, exploiting economies of scale The PPC and ISO will face lower transmission costs and RES connection costs The economics will be such that (as explained) private investors will find higher than presently incentives for their business The structure of costs of private RES systems will be such that bidding at the level of ISO will be feasible and economically attractive The maintenance and good operation of the wind park will be greatly facilitated when managed at such a large scale d) Special care should be given to the problem of clearing the interference between small hydro and large hydro in Greece. A master plan for hydro developments in Greece is required for that purpose. Private investment initiatives in small hydro will be lilcenced once checked for compliance against the master plan. This will overcome the major obstacle that currently limits the development of small hydro in Greece, without obstructing large-scale hydro projects of PPC. Concluding remark The above recommendation aiming at further promoting renewable electricity in Greece are considered to be the most appropriate for immediate actions in the Greek case. Other EU member-states and regions facing similar conditions might also consider similar measures. 9

10 Such conditions involve lack of infrastructure in the transmission system, RES promising sites distant form the grid and load contents, autonomous systems on islands etc. 10

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