The most noteworthy point, introduced in this regard, is that the submission of an application for the issuance of the installation licence constitutes an additional milestone investors need to comply with on risk of losing the project. The procedure for the issuance of the installation licence is not radically amended. This is especially so given that investors may also face curtailment clauses in their FGCOs or face an overall suspension of the grid connection process which is also allowed under the provisions of the new Law. While the amendments introduced are expected to reduce timing, they are also bound to create uncertainty as investors will be henceforth required to submit the requested grid connection bonds without having visibility on the technical and financial parameters of the offers to be issued by the respective Operator. Nevertheless, in the event that the competent Operator issues a FGCO prior to the expiry of the aforementioned 4-month deadline, whilst the project owner has not submitted the GCB by that time, the project owner shall be obliged to submit the GCB upon acceptance of the FGCO. In case such GCB is not submitted within the above deadline: (i) the application for the Grid Connection Offer will be considered incomplete, meaning that current priority may not be maintained, and other Grid Connection applications will take precedence in their examination by the competent Operator and (ii) the producer’s certificate of the project concerned will be revoked unless a Producer’s Certificate Letter of Guarantee is submitted to RAE within the above deadline. Meanwhile, for those applications submitted to the Operators prior to the publication of the new Law which are currently pending, interim provisions stipulate that the applicants are required to submit such GCB within 4 months from its publication. This means that contrary to the previous regime, the producers will directly apply for the issuance of a Final Grid Connection Offer (“FGCO”) by also submitting the required grid connection bond (“GCB”), whilst the Operators must respond to the above application by granting a FGCO or by rejecting the application within 2 months as of the date of completion of the application. The new law provides for the abolition of the provisional grid connection offer. The most important changes introduced in this regard may be summarised as follows:Ībolition of the provisional grid connection offer The law introduces some key amendments affecting the 2nd Phase of the licensing process, in an effort to make it swifter and more efficient reducing its duration from 5 years to 14 months. The first area touched upon the Law is the reform of the RES licensing process. Reform and acceleration of the RES licensing process.The key areas covered by the Law are the following: The Law comes at a time of rich legislative activity in the energy climate and environmental front and aims to ensure Greece’s compliance with its National Plan for Energy and Climate, as well as with its National Recovery and Resilience Plan “Greece 2.0”, which would ultimately help release funding for energy-related investments. On 4 July 2022 and following a waiting period of almost two years, the Greek Government has enacted 4951/2022 (the “Law”) on the reform of the second-phase RES licensing process and the energy storage framework.
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