Law 4001/2011 as in force, provides for the legal basis for the granting of state aid for the establishment of standalone electricity storage stations (“SESSs”). It stipulates that an investment aid or an annual operating aid can be granted both to SESSs connected to and operating in the Hellenic Electricity Transmission System (“HETS”) and to SESSs installed in countries within the European Economic Area.

The aid takes the form of an additional compensation to the net income arising from the operation of the above stations in the electricity markets, subject to the prior approval of such aid scheme by the European Commission (EC) and can be granted both through competitive bidding processes and on an individual basis.

Within this context, Greece, on 10.06.2022, has notified to the EC its intention to establish a scheme to provide support for the establishment of SESSs in Greece, which was approved by virtue of the EC’s decision C(2022) 6461/05.09.2022 regarding State Aid SA 64736 (2022/N) RRF – Greece – Financial support in favor of electricity storage facilities.

Pursuant to the said Law, it is foreseen that, with regards to cases where an operating aid is granted through competitive bidding processes, a Ministerial Decision shall be issued, which shall provide for the way of conducting such processes for SESSs. To this end, on 25.04.2023, the Greek Ministry of Environment and Energy has issued a draft Ministerial Decision (“draft MD”) entitled “Competitive bidding processes for the granting of investment and operating aid to electricity storage stations”. The draft MD was open for public consultation until 02.05.2023.

The key elements of the draft MD, which might be subject to alterations, are summarized below:

1. Timetable and capacity auctioned

The total capacity to be auctioned through the competitive bidding processes is 1,000 MW. The selection of the ESSs through the competitive bidding processes shall take place until 31.12.2023 whereas the selected ESSs should be put under operation until 31.12.2025.

The number of competitive bidding processes and their respective capacity to be auctioned are depicted as follows:

YEAR –QUARTER        COMPETITIVE BIDDING PROCESSES      TOTAL CAPACITY AUCTIONED (MW)

2023 – Q2                           1st Competitive bidding process                        400

2023 – Q3                           2nd Competitive bidding process                       300

2023 – Q4                           3rd Competitive bidding process                        300

                                                                                          TOTAL                        1,000

The capacity to be auctioned with regards to the 1st and the 2nd competitive bidding processes does not concern specific geographical areas whereas the 3rd competitive bidding process specifically concerns the lignite phase out zones.

The maximum capacity limit of the SESSs to be supported shall not exceed 300 MW per region (such limitation applies to SESSs to be selected during the 1st and 2nd competitive bidding process).

The competitive bidding processes will be declared following a decision of the Regulatory Authority for Waste, Energy and Water (RAWEW) and will be conducted through a single-stage bidding type of auction.

2. Capacity Limitations

– A minimum number of four (4) participants who are not affiliated persons applies for each competitive process.
– A maximum capacity limit of 100 MW per SESS is set in order for the SESS to be allowed to participate in the competitive bidding processes.
– A maximum participation capacity limit per participant in each competitive bidding process is stipulated, which is set to 25% of the capacity to be auctioned.

3. Eligibility Criteria

In order for the SESSs to be eligible to participate in the competitive bidding processes, the following requirements should be cumulatively met:

– The owners of SESSs who wish to participate in the 1st Competitive Bidding Process should hold a valid Electricity Storage License.
– No construction works should have taken place prior to the submission of the bid.
– The SESSs should have a maximum injection power of at least 1 MW.
– The storage technology of the SESS should have been used internationally in electricity storage facilities which participate in electricity markets and have been put into operation during the period 2018-2022, with a total capacity of at least equal to 1,000 MWh.
– SESSs should connect directly to the HETS or the electricity transmission system of other EU countries.
– SESSs should be able to participate as independent entities providing balancing services to the electricity markets.

4. Investment aid and operating aid

The SESSs selected through the 1st and 2nd Competitive bidding processes will be awarded an investment aid of €200,000 per MW.
In order to be awarded the investment aid, the owner of the SESS should submit a Performance letter of guarantee and a letter of guarantee for an amount at least equivalent to the amount of the investment aid to be awarded.

Apart from the investment aid, the selected stations shall also receive an operating aid for a 10-year period, which shall be awarded as of the commencement of the selected station’s operation. The conclusion of an operating aid contract between the owner of the selected SESS and the RES Operator & Guarantees of Origin (DAPEEP) constitutes a prerequisite for the award of the operating aid.

The editorial team