Unfortunately, the NEURC didn’t give us the floor during the open hearing of the draft Resolution the NEURC “On setting a tariff for electricity transmission services of «NPC «UKRENERGO» for 2022”, referring to the fact that the positions of the participants are already known. But the goal of the discussion is not only to express a position but also to be able to ask questions and get an answer.

However, when 80% of opinions and news are produced on social networks, we can also use Facebook as a platform to express the position of the European-Ukrainian Energy Agency members, an association that unites the largest foreign investors in the renewable energy sector. An official letter with the position has been sent to NEURC, and we are preparing clarifications based on the published today new calculations of NEURC.

Oleksandra Gumeniuk, Director of the EUEA: “Let’s first look at the implementation of the Memorandum of Understanding, dated June 10, 2020 (by the way, let me remind you that due to the retrospective reduction of «feed-in» tariffs, more than EUR 2 billion were saved):

THROUGH underfunding of the tariff:

 the old debt for 2020 for the produced RES electricity (which currently amounts to UAH 15 billion) has not been repaid in full;

 payments to RES producers for 2021 on average remain at 64.8% per month, which has led to an increase in new debt this year in the amount of about UAH 11 billion;

 The NEURC usually uses in its arguments a reference to the rule of law which provides for the POSSIBILITY (note, not an obligation) of 20% of green energy financing from the State Budget. In the State Budget for 2021, there were no RES expenses, and for 2022, the corresponding RES expenses are also not provided.

Question: Does the NEURC intentionally keep the transmission tariff, the main source of payment of the «feed-in» tariff, at a low level to accumulate TSO debts?

It will be recalled that the presence of debts in the TSO becomes a barrier to the completion of its certification, for synchronization with the EU energy system – ENTSO-E. Why does NEURC create this risk of non-synchronization with ENTSO-E?

– and again in 2022, the NEURC offers a lower tariff than UKRENERGO. Especially, underfunding of the article in the tariff structure of «NPC «UKRENERGO» on special obligations fulfillment to increase the share of electricity from alternative energy sources by reducing 20% of the forecast marketable products of SE “Guaranteed Buyer” in 2022. – UAH 10.8 billion. We emphasize that the current and next year’s budget, 20% are not included in expenditures!

– the tariff proposed by the NEURC contradicts the signed Guarantee Agreement* (on the issue of Ukrenergo bonds) between the TSO, the NEURC and the Ministry of Finance, in particular, paragraph 4.2. Take all necessary measures to establish and maintain the Tariff in an amount that will ensure full coverage of costs to the Borrower, including the service of ensuring the share of electricity production from alternative sources in accordance with applicable law.

 

*Agreement on measures to ensure the fulfillment of obligations under the Agreement on repayment of debts of the PJSC “NPC” Ukrenergo” to the state for the fulfillment of guarantee obligations concluded between the Ministry of Finance of Ukraine and NPC” Ukrenergo “.