In delineating the integration paths for RES, experts see the future in clearing the cases with the EPCs and integrating the small energy communities

Energy legislation remains insufficiently amended and adapted, both from the point of view of electricity distribution companies and from the point of view of energy communities. In addition to the lack of an energy strategy, it is not in line with either the vision for the development of the economy or the technologies. This was commented by representatives of the energy sector in Bulgaria within the framework of the conference "RES and energy security: advantages versus risks", organized by the Bulgarian Energy and Mining Forum (BEMF). According to them, the probability of changes in the coming months is high, especially since the transport of the energy efficiency directive is also pending. As it became clear during the discussion, a distinction must be made between "big" and "small" self-consumption energy. This will also require intelligent management of networks.

The hope of the EPC is that the regulatory framework will clear up a large part of the problems with the connection of RES

After the changes in the energy legislation, especially after the publication of the Law on Energy from Renewable Energy Sources (LERES), electricity distribution companies (EPCs) are waiting for the new regulatory framework. In this regard, the manager of "Electrohold" Karel Kral commented that serious changes are necessary for the effective integration of green energy sources.

"The main changes from our point of view are related to the deadlines for issuing opinions. It's not that we don't want RES to develop, it's just that the grid capacity is like that," he explained, giving an example of the increase in connection applications, which have grown fivefold. "What we have been proposing with the ESO is to introduce a different process for these applications so that we group them together," he said. According to him, the grouping process makes it possible to consider the total number of applications for a given region, which accordingly provides a vision for the development of the network and, accordingly, of the investments.

"What we wanted was to group these applications so that it would be possible to say how long an application can be issued for a given region and they can be considered together and together issue technical prescriptions, what needs to be done in order to see the value of the investment and then divide it. At the moment, we, as a network operator, must consider each application individually," he pointed out, giving an example of the changing intentions of investors.

Karel Kral also commented on the increase in sanctions for operators for not joining renewable sites, being categorical that "whatever sanctions are issued - they do not help anything".

The manager of "Electrohold" also emphasized the difficulties that are emerging with the provision of information for investors. "Many of the network operators have to give information to investors. It's good to keep investors informed, but there should be realistic timelines that are possible. There is no way to introduce a geographic information system covering an entire region in 6 months, so that it is available at all times," he explained.

According to Karel Kral, the upcoming regulations regarding the implementation of the amendments in the legislation should clarify the connection of RES sites, both to the low-voltage network and to the medium-voltage network. "With a low-voltage network, for example, we are talking about the need to comply with technical standards," he justified. The problem is serious, especially from the point of view of the management of the low voltage network, which mainly affects household users.

According to him, it is the electricity distribution companies, for example, that should have the right to manage the photovoltaic installations built on the roofs for the purpose of balancing.

"The right approach for the general framework is to support the development of RES for self-consumption," he said, specifying that "it is better to have a regulation that allows the amount of electricity produced to be returned to the grid, but this must be accompanied and with remote control". The aim is not to connect excess capacities that would require significant investments for network development. Last but not least, Karel Kral raised the question of the tariffs concerning the connected relevant object. The manager of "Electrohold" was categorical in the company's intention to digitize the electricity distribution networks, without which the management of RES capacities will be impossible.

The representative of the Ministry of Energy Nikolay Nalbantov, for his part, explained that a large part of the current changes in the law on renewable sources were not initiated by the Ministry. According to him, the purpose of the amendments they proposed were aimed only at transposing the European directive and strengthening of the Recovery and Sustainability Plan. "We, for example, were in favor of canceling the preliminary contract (for the construction of RES), but it was not accepted," he commented. He specified that part of the by-laws has already been prepared by the teams of the Ministry of Energy and will soon be published. As it became clear during the discussions, it remains to be seen what the regulations of the regulator will be. In addition, in the near future, the amendments to the Energy Efficiency Directive will be introduced into the legislation, which in turn will require new legal amendments. The hope is that then a solution will be found to the problems that have remained unresolved.

A strategy for the integration of small energy systems comes first

Formal changes. This is how the chairman of the Chamber of Energy Communities, Stefan Abadjiev, defined the changes in LERES. According to him, the most important is the change in the way of thinking.

"The latest changes in the law are formal. From the point of view of the future of green energy, I must say that there is a need for a total change in the way of thinking. Indeed, operators work within certain frameworks, with certain financial means, which are determined by the overall framework of financial flows in the energy sector. To say that the EPAs are not doing something or that they are doing it in a certain way is incorrect because this framework and these parameters have been set by KEVR and they cannot do more," he said.

According to him, a distinction must be made between "big" and "small" energy.

"Actually, the problem is not in the EPC and ESO. We need to understand the simple fact that there are two sides to energy - large licensed energy, which is the energy of large power plants, of large parks, which flow into the energy system through the distribution and transmission network. There are also so-called smart energy, which is self-consumption energy. Karel Kral said it - in the law you currently have one limit - up to twice the installed capacity. For the construction of a photovoltaic plant on a roof, it is also absolutely illogical and unfounded. Why twice and not three times or 0.7 times?” he questioned. In this regard, he gave the example of the 55th school in the capital, on the roof of which a power plant of 550 kilowatts can be built, but the connected power is 30 kilowatts.

"Why shouldn't the school be able to build 550 kilowatts, and then not sell the excess power from the same school to owners of electric cars, or to neighboring sites?" he asked. From this point of view, he developed the thesis about the need to introduce the idea of "development of the smart energy sector". "This is the energy of the small, of the prosumers, of the energy that is not returned to the grid, the energy that is not loaded on the grids and that does not require the operators of the distribution networks and the ESOs to do what they cannot do," said he. Under one condition – if an intelligent way of management is introduced.

As Abadjiev put it, "small energy, smart energy, electromobility is economically efficient as long as it is allowed to breathe. Because right now he's having trouble breathing." He was adamant that "these are the changes that need to happen."

"Extremely relaxed regimes should be introduced, provided that there are intelligent systems to limit and integrate, so that there is no last-mile limitation and return in the low-voltage branches. Then people will be able to invest and sell this energy," he commented. According to Abadjiev, if this is reflected in the energy strategy and the conditions for smart green energy are eased, "we will have a huge increase in green energy in Bulgaria, without overloading the grid and without having the current problems with zero lunch prices and zero prices overnight".

The former Deputy Minister of Energy Elenko Bozhkov, for his part, commented that the transformation of the energy sector, including the small one, will require a lot of funds. He called for the creation of a strategic council for energy development made up of experts with experience in the sector. In general, it also outlined the need for a clear strategy, as well as the need for a program of activities to attract investment, for example for heat pump installations. In the list of recommendations, Bozhkov included the need to abolish the monopoly of the energy exchange, to form regimes for the provision of land, the introduction of emission-free projects, etc.