EUEA addressed the NEURC with proposals on the following issues, the solution of which is urgent for RES producers, in particular:

1. Creation in SE “Guaranteed Buyer” of a deficit of funds in the amount of 20% of the value of marketable electricity products of RES producers

Proposal: to delete from the text the following addition to the draft Changes in paragraph 12.1 of the Procedure for Purchase by the Guaranteed Buyer of Electricity Produced from Alternative Energy Sources (Procedure), approved by the NEURC Resolution of April 26, 2019 №641 namely: “Pn – expenditures for financial support of the guaranteed buyer to pay for electricity produced from alternative sources, in accordance with the budget requests of the central executive body that ensures the formation and implementation of state policy in the electricity sector, based on calculations provided by the NEURC, in the amount of not less than 20 percent of the forecast production of marketable electricity products from alternative sources for the relevant year, thousand UAH.”.

2. Defining the term “reimbursement” as compensation without directly relating it to the goods or services will make it impossible to pay VAT

Proposal: Compensation should be clearly defined as a “service” provided by the Guaranteed Buyer to RES producers to address their imbalances (a VAT-taxable transaction) that will allow both parties to pay VAT.

3. Late payment for settlement of imbalances may be grounds for exclusion of RES producer from the balancing group of the Guaranteed Buyer

Proposal: to exclude from item 10.7 of the Procedure of the provision on loss of membership in the balancing group of the Guaranteed buyer, and also to exclude item 7.11 from the draft of changes to the Standard contract.

Full original text of the letter at the link:Лист ЄУЕА_22_12_2020 до проекту Змін до постанови НКРЕКП від 26 квітня 2019 року № 641