Curtailment obligations in the form of operational restrictions were originally introduced by virtue of article 10 of Law 4951/2022 (the “Law”) on the modernising of RES licensing process, published on 4 July 2022. As of 19 May 2023, part of the secondary legislation necessary for the implementation of the provided operational restrictions for RES projects and Storage Stations has been enacted, by virtue of Ministerial Decision no. “ΥΠΕΝ/ΔΑΠΕΕΚ/53563/1556” (the “MD”).[1] The MD critically quantifies the applicable curtailment obligations for photovoltaic stations (“PVs”), windfarms and storage stations, in accordance with article 10 of the Law. The key aspects of the MD are briefly analysed below:
By way of background, it is reminded that article 10, para. 2 provides for the following curtailment obligations:
- a permanent reduction of the station’s maximum capacity vis-à-vis the installed capacity thereof;
- predefined limitations of the station’s maximum capacity within given time periods within each day of infeed;
- limitations set by the competent grid operators based on the local grid’s operational status; and
- limitations activated in real time and in emergency situations through the use of automated systems which may even lead to the station’s disconnection from the grid.
Options (i) and (ii) may not result in a reduction of more than 5% of the station’s annual injected power production. The 5% reduction is calculated based on the annual generation capacity of stations of corresponding technology. Additionally, options (iii) and (iv) may not result in a redistribution of the injected power of more than 5% of the overall annual generation capacity of RES stations installed in the affected area. The calculation basis for these points, again, relies on the annual generation capacity of corresponding technology stations.
Curtailment obligations for PVs
According to the MD, and in implementation of point (i) above, PV stations connected to the transmission system (operated by the Independent Power Transmission Operator, i.e. “IPTO”) or the distribution network (operated by the Hellenic Electricity Distribution Network Operator, i.e. “HEDNO”) are subject to permanent maximum installed capacity limitations, as per the following table (in percentages):
The MD also provides that, in case of an increase in the station’s installed capacity following the issuance of its grid connection offer (“GCO”), the maximum injected power shall be calculated anew on the basis of the increased installed capacity, unless the latter is below 10%, in which case the curtailment obligations already imposed will remain intact. Same applies in case of reduction of a station’s installed capacity, in which case the maximum generation/injection capacity shall be calculated on the basis of the new installed capacity.
Curtailment obligations for windfarms
In implementation of point (ii) of article 10 of the Law described above, windfarms connected either to the transmission system or the distribution network, will be subject to intermittent curtailment which will apply only within given time periods each allocation day, as follows (in percentages):
Similarly to the curtailment calculation mechanism applied to PVs, the MD also provides that in case of an increase or a decrease in the station’s installed capacity following the issuance of the GCO, the maximum injected power shall be calculated anew on the basis of the increased or the decreased installed capacity.
Curtailment obligations for storage stations
For storage stations connected to the system or the network, hourly restrictions on the maximum injection power are applied during predefined time periods within each allocation day, in accordance with article 10, para. 13 (a) of the Law. The maximum injection capacity of the storage station during these periods (maximum permissible injection power), as a percentage of the maximum injection capacity specified in the storage licence, is defined as follows:
Similarly to the above related obligation for windfarms, in all cases where the maximum injection power of a storage station increases after the issuance of a GCO, the maximum permissible capacity of the station must always be recalculated, based on the new maximum injection power of the station. Notably, however, the MD does not specify if a recalculation must also follow the reduction of the maximum injection power of the storage station.
Pump storage stations, storage stations connected to the transmission system of Crete and the interconnected Cyclades islands and certain storage stations connected to the transmission system of South Evia are exempted from the curtailment obligations outlined above.
Conclusions
The abovementioned percentages for PVs and windfarms have been determined, according to the MD, in an effort not to result in a reduction of more than 5% of the station’s annual injected power production, based on the annual generation capacity of stations of corresponding technology, per the provisions article 10 of the Law. It is worth highlighting, however, that said curtailment obligations are independent from those prescribed by cases (iii) and (iv) described above (local and emergency limitations); hence, producers are obliged to financially re-evaluate the generation output of their respective stations, based on the potential parallel application of both curtailment scenarios.
[1] Government Gazette B’ 3328/19.05.2023
