By virtue of art. 11D of Law 4685/2020 concerning the promotion of the installation of Electricity Storage stations, the delegated Ministerial Decision (MD) no. ΥΠΕΝ/ΓΔΕ/28255/1143 (OJ Β’ 1248/13.03.2025) has been issued in order to define the procedure for the submission of applications for the granting of a final Connection Terms Offer (CTO) for the installation of Standalone Electricity Storage Stations (“SESSs”).
The key elements of the new MD are summarized below:
1. Eligibility criteria
For the submission of an application for the granting of a CTO, the eligible participants should, inter alia, hold a valid Storage License of battery technology, have submitted a complete application for a CTO to the competent Operator following the entry into force of L. 4951/2022 i.e. 04.07.2022, and have secured, upon the submission of the CTO application, pre-approval or loan approval, or have own funds available for the project’s implementation. In addition, the SESS should have neither being granted a final CTO nor being selected for the granting of operating aid through participation in competitive bidding processes.
2. Technical requirements and operational limitations
The SESSs eligible for the granting of a final CTO should amongst others:
(a) have a maximum injection capacity more than or equal to 0.5 MW and a useful capacity of at least two (2) hours (MWh/MW) upon the commencement of their operation,
(b) have a degree of full-cycle efficiency of at least 80% upon the commencement of their operation, including their self-consumption and internal losses.
3. SESSs’ classification into Priority Groups
Following the expiry of the deadlines set for the submission of the CTO application, a Committee appointed following the issuance of a new Ministerial Decision, shall evaluate the applications submitted in terms of the fulfilment of the aforementioned requirements and further classify the projects under Priority Groups.
The order of priority is based on several factors including amongst others whether the SESSs’ owners have concluded PPAs with businesses or energy-intensive industrial consumers, the geographical location of the SESS i.e. the SESS is installed in a lignite phase-out zone, whether the SESS’s owner also holds a RES Aggregator License etc.
4. Maximum capacity limitations
The MD defines certain maximum capacity limitations depending on whether the SESSs are connected to the Transmission Network (ESMIE) or the Distribution Network (EDDIE) as follows:
a) 3800 MW of maximum injection capacity for CTOs granted by the Operator of ESMIE i.e. the Independent Power Transmission Operator (IPTO) shall be allocated among IPTO’s Priority Groups.
b) 900 MW of maximum injection capacity for CTOs granted by the Operator of EDDIE i.e. the Hellenic Electricity Distribution Network Operator (HEDNO) shall be allocated among HEDNO’s Priority Groups.
5. Anti-concentration criteria
For the purposes of avoiding market concentration and in order for the SESSs to be granted a CTO, the MD provides for a maximum total limit of maximum injection capacity of the stations per natural or legal person which is defined as follows:
– 250 MW per natural or legal person including companies directly or indirectly connected to it for the SESSs connected to ESMIE and EDDIE
– 500 MW until 2029 per natural or legal person including companies directly or indirectly connected to it for either SESSs of battery technology or SESSs combined with RES stations (excluding self-generation storage units).
It is also noted that the transfer of a SESS at any stage of development and operation is prohibited in case it violates the anti-concentration criteria.
6. Project Implementation
The SESSs which shall be granted a final CTO should declare readiness within an 18th month period from the acceptance of the CTO.
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