The main risk we see in the latest version of the text – OBLIGATORY exit from the balancing group of the Guaranteed Buyer and transition to a new FIP system of wind and solar power plants with a capacity of 10+ MW until 01.01.2024 (50+ MW of wind and solar power plants will be forced to the new system even earlier – until 01.01.2023) .
EUEA’s position is to return to the original version of the Draft Law in terms of voluntary exit of RES producers from the balancing group of the Guaranteed Buyer and the transition to a new Feed-in Premium support system.
We propose to specify in the Draft Law that the current system of compensation at the “feed-in” tariff for electricity not released as a result of the execution of TSO commands at the level of the established “feed-in” tariff should be maintained for RES producers.
An alternative may also be considered, according to which market rules should provide for the pricing of services of RES producers in the balancing market in a way that will provide compensation for electricity not released as a result of the execution of TSO commands at the level of the established “feed-in” tariff.
We propose to define in the Draft Law that for RES producers a current mechanism should be maintained regarding permissible deviations of actual production volumes from the forecast ones, within which RES producers are not responsible for such deviations (tolerance margin).
The principle of obligatory exit for certain categories of RES producers from the balancing group of the Guaranteed Buyer proposed by the Ministry of Energy in the final version of the Draft Law, and other above-mentioned items actually worsen the conditions of RES producers compared to the current regulation, in our opinion,and this is a violation of the obligations undertaken by the state in accordance with the Memorandum of Understanding and Law № 810-IX.
It should also be noted that the electricity market in Ukraine today is opaque, inefficient and extremely affected by the Regulator and the Government. Thus, instead of forcing RES producers to participate in this market, which under current conditions will lead to additional losses for them (compared to the current system of electricity sales), we consider a more effective approach to focus on improving the market environment. A transparent and predictable market will best encourage RES producers to participate in it and switch to the Feed-in premium system (provided that all other essential elements of the «green» tariff system currently applied to RES producers are not changed – compensation for electricity production restrictions, tolerance margin, etc.).
Today, October 21, EUEA sent a letter of position to the Ministry of Energy of Ukraine, and we are waiting for constructive decisions.
✔️ EUEA letter: ENG_EUEA Comments on FIP Draft Law 2021 10 21
The photo is taken from the Facebook page of the Ministry of Energy of Ukraine.