
ICLG - Renewable Energy Laws and Regulations - Greece Chapter covers common issues in renewable energy laws and regulations – including the renewable energy market, sale of renewable energy and financial incentives, consents and permits, and storage.
The Hellenic Republic has adopted a National Energy and Climate Plan (NECP or ESEK, as per its Greek acronym), which constitutes a Strategic Plan for the Greek Government on climate and energy issues and presents a detailed roadmap for the achievement of specific energy and climate goals by 2030.
The NECP was adopted in the context of the Hellenic Republic’s compliance with the Regulation of the European Parliament and of the Council 2018/1999, aiming to ensure the achievement of the objectives and targets of the European Union for 2030 and the long-term (net-zero greenhouse gas emissions within the European Union by 2050) in accordance with the 2015 Paris Agreement.
In relation to the increase of the use of renewable energy sources (RES) in energy consumption, the NECP has set ambitious targets concerning the use of RES in gross final energy consumption (30%), in gross final electricity consumption (55%), in heating and cooling needs (30%) and in the transport sector (14%).
Following the REPowerEU Plan and the ongoing Energy Market disruption, the NECP is under revision and consultation between the Hellenic State and the European Commission, aiming to achieve and further accelerate the complete dependence on fossil fuels.
In relation to the above, the Hellenic Republic has recently adopted the first “National Climate Law” (Law 4936/2022), which establishes measures and policies to adapt the country to climate change and ensure the path of decarbonisation by the year 2050 and, among others, prohibits the production of electricity from solid fossil fuels from 31 December 2028.
On a de lege lata basis, Law 3468/2006 contains a definition of “renewable energy”, which refers to energy from renewable non-fossil sources, namely wind, solar, geothermal, and environmental energy, tide, wave and other miscellaneous ocean energy forms, biomass, hydropower, landfill gas, sewage treatment plant gas and biogases.
Greece has integrated all energy market liberalisation packages, in accordance with EU rules.
Particularly, RAE is an independent administrative authority and member of the Agency for the Cooperation of Energy Regulators (ACER), empowered, among others, to monitor the licensing procedure of RES projects, operate all sectors of the Energy Market, provide advice to the competent state bodies, and adopt regulatory measures towards the full liberalisation of the electricity and Natural Gas Markets.
The following entities also play an important role in the licensing process for RES projects, although they are not formally market regulators:
There is no renewables company in which the Greek State participates directly or that is owned directly by the Greek State.
The electricity production from renewable sources in Greece is a fully liberalised market and there are no legal and real entrance barriers to the relevant market. Due to the extensive intensity of RES projects either under development or construction, the RES market is highly fragmented.
Long-established market players, such as Terna Energy, EDF Renewables, Enel Green Power, PPC Renewables S.A., Ellaktor, Total Eren, Iberdrola, Mytilineos Holdings, Intrakat, as well as a great number of market newcomers such as Lightsource BP, Macquarie Group Limited, 547 Energy, Akuo Energy, Abo Wind, Copenhagen Infrastructure Partners, BayWa r.e., OX2, and many others, including Hellenic Petroleum and Motor Oil Hellas, the two major national oil refining and petroleum products trading groups, can be in included among the key players.
Greece’s strategic position and climate characteristics offer important potential for all types of RES technologies. Wind and solar power plants represent the majority of installed capacity in Greece; however, small hydroelectric plants, biogas and biomass occupy a considerable market share. As Greece runs an ongoing plant focusing on decarbonisation, a significant pipeline of RES projects (mainly large-scale PV plants) is being constructed and developed (with PPC’s leading position, through its affiliate PPCR) throughout the territory and especially within depleted lignite fields.
Beyond the above, due to the potential of the RES market in Greece, there is a constantly increasing interest for both domestic and foreign investments for the development and construction of all RES technologies.
It is also important to note that, in recent times, the institution of Energy Communities (as enacted by Law 4513/2018 and radically reformed by Law 5037/2023, through the replacement of Energy Communities by Renewable Energy Communities and Citizens’ Energy Communities, in accordance with EU Directive under no. 2019/944) is flourishing.
The legislation provides multiple incentives for the establishment of and participation in Energy Communities (e.g., increased tariff and facilitation of the licensing procedure) and encourages the cooperation between private investors and local communities (i.e. citizens and local authorities).
In terms of achieving the national long-term (by 2050) and intermediate (by 2030 and 2040) goals regarding climate neutrality, mitigation of anthropogenic emissions and dependence of fossil fuels, as set out by the NECP and the National Climate Law, more and more established groups, which have traditionally not been active in the electricity sector, are actively entering the RES sector.
For example, Motor Oil Group, traditionally active in the oil sector, has proceeded, through its affiliate Motor Oil Renewable Energy (MORE), to the acquisition and development of a significant pipeline of both operating (800 MW) and under construction and development (2.3 GW) RES projects.
Recent data confirms the steady commitment of Greece for a gradual zero-emission economy. In particular and according to “The Green Tank”, during January 2024, RES production set a record. Specifically, Renewables had the second highest historical monthly production in January 2024, compared to the absolute record of August 2023. According to such analysis, production reached 2,207 gigawatt hours (GWh), when in August 2023 it stood at 2,254 GWh.
In the same tenor, RES production approached approximately 50% (47.7% to be accurate) of demand coverage within the first two months of 2024, while together with hydroelectric plants it exceeded 55%.
The above achievements, regarding the penetration of RES in the energy mix, are accompanied by a parallel decrease in dependence on fossil fuels.
Within the first two months of 2024, RES production exceeded fossil gas and lignite by 762 GWh. This trend is increasing; in the first two months of 2023, renewables outnumbered fossil fuels by 425 GWh.
Greece is ranked seventh, on a global scale, in the use of renewable energy in its gross final energy consumption with considerable prospects of further penetration of RES in the energy mixture.
The environmental national framework of Greece complies with the European and international rules for public participation in the decision-making process during the assessment of the effects of public and private projects on the environment (Directive 2011/92/EU, Aarhus Convention, etc.).
Further, the national legislative framework allows natural persons to directly participate in energy communities (please see question 2.1 above).
To further promote RES penetration in the final energy consumption, the Hellenic Republic constantly adopts several incentive programmes that provide partial financing for housing energy upgrading works that aim to reduce the energy footprint of homes and residences and increase energy saving (e.g., the installation of rooftop photovoltaic (PV) systems, replacement of heating systems, etc.). Through all the above policies, the Greek State promotes self-production, net-metering and net-billing so that citizens gradually become “prosumers”.
The model of “prosumers” is also encouraged by energy companies who offer a comprehensive package (financing, supply of solar panels etc.) to electricity consumers for the installation of PV facilities.
The legislative framework governing (in general) the operation of the electricity market and the energy sector in Greece is set by Law 4001/2011.
The development, construction, grid connection, commissioning and commercial operation of RES projects in Greece is regulated by several laws, most of them primarily adopted in order to transpose relevant EU legislation into national legal order, among which Laws 4685/2020, 4951/2022 (recently replaced Law 3468/2006 and adopted with an aim to further simplify and accelerate the permit-granting process, in line with the relevant provisions set out under RED II) and 4414/2016 have a prominent role.
Law 4685/2020 regulates the first phase of the licensing procedure required for typical scale projects (up to the issuance of a Producer’s Certificate) providing for simplified, digital and automated procedures, enabling the acceleration of the process.
Law 4951/2022 consists of the second licensing phase following the issuance of a Producer’s Certificate and until the granting of an Operation Licence.
Law 4414/2016, which has been adopted in compliance with the EU Guidelines on State Aid for climate, environmental protection and energy, sets the support scheme under which RES projects operate through long-term operating contracts or through direct participation in the energy market.
Briefly, the key licences provided in the regulatory framework are (a) a Producer’s Certificate, (b) an Environmental Terms Approval Decision, (c) an Installation Licence, and (d) an Operation Licence.
IPTO and HEDNO are responsible for the interconnection of RES plants to the Grid System and/or Interconnected Distribution Network, as well as for the operation of the System and the Network, as the case may be.
The above legislative framework is supplemented by a number of secondary legislative acts, mainly in the form of ministerial decisions and decisions of RAE to regulate in a more detailed way various issues relating to the development, construction and commercial operation of renewable energy projects, such as environmental, spatial planning, building and operational issues.
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