The EUEA sent its suggestions and comments to the draft resolution of the NEURC “On Amendments to the Resolution of the NEURC dated December 1, 2021 №2454” (regarding the revision of the tariff for electricity transmission services of NPC “Ukrenergo” from December 1, 2022).
In the letter, EUEA noted the following comments and requests to the Regulator:
- as a result of the change in the official exchange rate of the hryvnia to the euro, please let us know when the Regulator will carry out actions aimed at recalculating “green” tariffs from April 1 to September 30, 2022, and take into account the corresponding increase in the weighted average “green” tariff when revising the service tariff for electricity transmission services;
- to explain the reason for not taking into account changes in the amount of transmission (consumption) of electricity that took place in 2022 when calculating the tariff rate, that took place in 2022 as a result of the full-scale invasion of the russian army into Ukraine. According to the information provided by the Minister of Energy in May 2022, electricity consumption in Ukraine has decreased by 32–35% since the beginning of the war. Respectively, the tariff proposed by the Regulator in the amount of UAH 397.85/MWh (without VAT) will not ensure the balanced operation of NPC “Ukrenergo”, in particular, the possibility of financing costs in the amounts determined by the proposed structure of tariff costs. At the same time, there is already a certain deficit of funds of NPC “Ukrenergo”;
- we propose, taking into account the parts of the third article 8 of the Law of Ukraine “On Alternative Energy Sources”, to also ensure the completion of full calculations by NЗC “Ukrenergo” for payment to SE “Guaranteed Buyer” for services provided in 2021 to increase the share of electricity production from alternative sources. This will make it possible to ensure compliance with the state’s legally defined guarantees of full payment in cash for electricity produced from RES, based on the results of 2021.
Original letter: EUEA Letter NEURC Transmission Tariff for Dec 2022 2022 10 28