Everyone liked the new EWRC Ordinance on the connection of renewable energy sources, but there will be refinements to the texts

All participants in the public discussion at the EWRC of the new Ordinance No. 6 on the connection of objects to the electrical networks. However, there were no shortage of comments and the texts are still to be refined. As the participants expressed, the problems that arise are not from the Ordinance, but from the law.

"We welcome the inclusion of a text regarding control of the power of producers and consumers, but we also think that the texts regarding the possibility of ex officio and connected power increases should be further developed, said the representative of ERM West Zornitsa Genova. At the same time, she opposes the planned possibility of increasing generation capacities by referring to the network's capabilities. "We are categorically opposed, and this is extremely important for us, to the increase of the permissible generation power, which is necessarily connected to the distribution network, from 5 to 10 MW ", she said. In her words, such a decision "would technically and practically mean that one connection would exhaust the transmission capacity of the distribution network in an area where a particular producer connects."

"In the report of the working group, we did not see any reasons for this proposal, nor what are the circumstances that require such a fundamental change from doubling the power, nor the consequences of adopting such a measure, namely, as I said, a rapid exhaustion of the capacity of the existing networks and facilities from producers at the expense of consumers. Because, in addition to producers, we also connect consumers, for whom there must also be network capacity and facilities," explained Genova.

The representative of ERM West noted, not without criticism, the recorded possibility of unilateral change by producers and operators of energy storage facilities and, in particular, to unilaterally change the conditions of a relevant operator. And without his consent. "This will not guarantee stability of relations. The issuance of an opinion by the operator, in which the detailed content is definitely described, what should be contained, will further render meaningless," explained Zornitsa Genova.

She did not overlook the increase in the obligations of the operators at the expense of shortening the terms in which they have to provide their services, and she also considered that some of them were not well tailored. "The deadline for providing a contract for joining users has been shortened from 21 to 15 days. Yes, the other deadlines have been complied with, but this one is not," she pointed out, emphasizing the apparent "disproportion of the detail of providing the opinion with the shortened deadline. This term is being shortened, but more and more activities have to be carried out, which will make the process quite difficult and create some tension," commented Genova.

There were also remarks regarding the so-called "join receiver". According to the director of ERM West, the new texts in the Ordinance create an opportunity for circumventing the procedure by some manufacturers and called not for the expansion of the regulation, but for its detailing in order to limit abuses.

The representatives of Elektroraspradelenie South Shteryu Radev and Elektroraspradelenie North Desislava Ruseva shared the same concerns. Shteryu Radev also asked a question about the objects in a welded position.

Desislava Ruseva raised a question about the lack of good regulations for plants arranged in ZEVI with a capacity of up to 10.8 kW. There is also uncertainty regarding the 3-month period between the entry into force of Ordinance No. 6 and the methodology for joining, the representative of Elektrorazpradelenie Sever also pointed out.

The immediate entry into force of the Ordinance will cause difficulties for the company to adapt to the terms of entry into force, she also pointed out. The other two power distribution companies had previously expressed similar concerns.

Yana Kirilova, a representative of producers of green and wind energy in particular, saw a correlation between problematic financing for the construction of green energy systems. As she put it, the responsibility is transferred to the participants to be "embracing the common interest in the development of the network". Remarks were also expressed by the Bulgarian Solar Association and APSTE.

Iliya Grozdanov from the "Dimova-Rusev" law firm saw opportunities for improvement, one of which concerns the indication of the property boundary already in the accession opinion, and not in the final contract, as this is important for the measurement by the producers. He also called for the preliminary opinion to include all costs, including those for distribution or transmission companies, so that a producer can make a decision before paying a deposit whether to proceed with a given project. "Because it can dramatically change the cost of a project," he reasoned, adding that as an opportunity to influence and conditions are joining. As another possibility to refine the texts, Grozdanov also indicated the specification of terms for the return of a security deposit.

Of no less importance, according to Iliya Grozdanov, is the need for the design to be outsourced to a preliminary contract, so that there is no delay in the start-up of a given power plant.

The chairman of the working group, Plamen Mladenovski, for his part, stated that there is nothing worrisome regarding the raising of the limit from 5 to 10 MW for connection to the electricity distribution network. "I believe that this border will change absolutely nothing," he was categorical. In addition to seeing additional administrative procedures, he also referred to the European practice, which "indicates that plants up to 20 MW join distribution companies. So the networks of the distribution companies are unlikely to be blocked."

Regarding the terms, Mladenovski pointed out that they originate from ZE and ZEVI. In his comment on the so-called receivers, the chairman of the working group supported the companies' position, but asked for proposals to limit the abuses.

Regarding the connection of the batteries, he referred to the opinion of the CDU on the need to balance the system. "Maybe through aggregators, but this activity is poorly developed in Bulgaria," he said. At the same time, he expressed the opinion that a potential operator of storage facilities would comply with the offer of the better network operator.

Mladenovski also clarified that there is no way for plants up to 10.8 kW to write something more detailed, "after it is said that they must join within 30 days". The chairman of the EWRC working group expressed a positive attitude towards Iliya Grozdanov's proposals and stated that he would consider mentioning the property boundary in the opinion, as well as regarding the design. There will also be clarification regarding the possibility of a unilateral change of opinion by the operators of the storage facilities, it became clear already during the public discussion at EWRC.

Within 14 days, the Commission for Energy and Water Regulation will expect the written opinions of the interested parties.

At the same time, it became clear from the words of EWRC chairman Ivan Ivanov that there can be no deadline for the companies to prepare and immediately after the adoption Ordinance No. 6 will enter into force. The reason is the request of the finance minister for faster adoption of this document, because of the expected money from Europe.