Authorization procedures

A crucial part for implementing a project like ROBINSON is the authorization procedures, that are governed by the aforementioned legislative context, which as mentioned may vary from country to country. Moreover, the authoritative level that is expected to provide the essential licenses may also differ from region to region, since it could be either a municipal, a regional or a central ministry authority. Taking Greece as an example of the licensing procedures for the installation and operation of energy systems is indicative of how crucial this step may be. In Greece, while implementing an energy system, every discrete component that the system is comprised of shall follow a separate licensing process. The overarching rule for issuing such licenses includes the following successive major steps:

  • A ‘power production certificate’ that refers to both energy and spatial space for a specific technology, according to a recent 2020 domestic law.
  • The ‘environmental permit’ that the owner of the power production certificate is obliged to apply for within six to eighteen months, after the issuance of the power production certificate. Variations and additional demands may arise, depending on the siting of the project (e.g. within a NATURA 2000 or similar protected area).
  • The ‘installation license’ that allows the project’s owner to initialize the construction of the project. Nevertheless, issuing the installation license may also include various other permits and licenses depending on the very nature of each project. For example, a certain project may include the construction of buildings, marinas, docks, electricity networks, electromechanical facilities or other accompanying infrastructures and/or procedures like connection to the local grid, which shall be licensed according to the proper legislation.

However, there are exceptions from the obligation of issuing the ‘power production certificate’ to the ‘Greek Regulatory Authority for Energy’ for natural or legal entities that apply to:

  • geothermal plants with power equal or lesser to 0.5 MW,
  • biomass, biogas and biofuel plants with power equal or lesser to 1 MW
  • photovoltaic or heliothermic plants with power equal or lesser to 1 MW,
  • CHP plants with power equal or lesser to 1 MW,
  • wind parks with power equal or lesser to 60 kW,
  • small hydropower plants with power equal or lesser to 0.5 MW,
  • educational/research plants with power equal or lesser to 5 MW.

Moreover, for the aforementioned cases with ‘power production certificate’-exceptions, also an installation and operational license is not required. However, depending on the case, environmental permits may apply.  

Concerning the environmental permits, the ‘Environmental Impact Assessments’ must be issued to certain authorities depending on the unique characteristics per case, but in general, some agencies involved may be:

  • municipal and regional councils/authorities,
  • agencies of spatial and environmental planning of the respective ministry
  • forestry and rural development agencies/ministry
  • protected areas’ management agencies
  • ministry of maritime affairs (for offshore and coastal plants)
  • regional water management agencies (for hydropower plants),
  • regional/ministry agencies for antiquities, etc.

Furthermore, for an operator to deploy backup power generators a ‘solemn declaration’ must be issued to the license-providing authority. In this ‘solemn declaration’ must be included the ‘Additional Connection Agreement’ between the operator of the backup power generator and the respective Power Transmission/Distribution Operator per case. Once the submission of the aforementioned ‘solemn declaration’ to the license-providing authority takes place, the operation of the backup power generator may initiate.

It becomes apparent that implementing such a project demands accurate planning and estimation of the prerequisite procedures both from a legislative and bureaucratic aspect. Issuing the licenses shall take in mind all possible details in order for a licensing procedure to be approved and not arise delays. Bureaucracy and implications, like in any project may cause financial, operational and constructional impacts. The latter is going to be moderated by the use of the ROBINSON Replication Tool, which shall take account of as many as possible crucial characteristics that may assist or burden any further procedure, and consequently provide the decision support tool in terms of fit-to-purpose ROBINSON’s replication.