HYBRID ELECTRICITY GENERATION IN TURKISH ELECTRICITY MARKET
Introduction
With the amendment to the Electricity Market License Regulation (“Regulation”) by the Energy Market Regulatory Authority (EMRA), published in the Official Gazette dated 08.03.2020 and numbered 31062 and envisaged to enter into force on 01.07.2020, “multiple sources electricity generation” has been paved the way.
Prior to this amendment, while licensing for electricity production was possible for only one type of source in the same field, it is possible to generate electricity from more than one energy source connected to the network through the same connection point.
In the amendment of the regulation, within the scope of multiple sources electricity generation facilities; it is set forth hybrid renewable electricity generation facilities, hybrid electricity generation facilities, supportive source electricity generation facilities, and co-firing electricity generation facilities. In this study, “hybrid electricity production” and “hybrid renewable electricity production” are discussed.
Hybrid/ Hybrid Renewable Electricity Generation
In the new regulation, the “hybrid electricity generation facility” is defined as a single electricity generation facility, which is established to generate electricity from multiple energy sources connected to the grid at the same connection point.
“Hybrid renewable electricity generation facility”, on the other hand, is defined as a single electricity generation facility that is established to generate electricity from more than one renewable energy source connected to the grid at the same connection point.
After this amendment, multiple and different production sources can generate electricity and related facilities can be established within the same field and depending on the same network infrastructure.
The choice of source for pre-license or license applications in multiple-source electricity generation facilities is called “the main source”. Other sources or sources other than the main source are called “auxiliary sources”, not being the main source type used in pre-license or license applications in multiple source electricity generation facilities.
Pre-license Application and Evaluation Process
Hybrid/ hybrid renewable electricity generation facilities’ pre-license and license applications and evaluation processes will not be different from the one for electricity generation from one source as a rule. However, in the amendment of the Regulation, for hybrid/ hybrid renewable electricity generation facilities, some different provisions were introduced.
Pursuant to article 5 of the Regulation, the legal entities wishing to operate in the Electricity Market, before starting the activity, as a rule, it must obtain a separate license for each activity and for each facility if such activities will be conducted at multiple facilities. However, with the amendment of the Regulation, an exception was brought in this regard for the multiple source electricity generation. Accordingly, the auxiliary welding unit used in multiple source electricity generation facilities is considered to be the unit of the facility based on the main source and the facility is evaluated under a single pre-license or license and the application is made accordingly. On the other hand, under no circumstances can the auxiliary source be converted into a main source in the hybrid/ hybrid renewable electricity generation facilities.
According to the article 15/3 of the Regulation, which regulates the evaluation process of pre-license applications; in pre-license applications made to establish a wind or solar power generation facility, if there are more applications than the declared capacity to connect to the same connection point and/or the same connection area, and/or if there are more than one application to the same site, the applications that gain connection capacity are determined by making competition by TEİAS in order to determine the ones to be linked. However, with the amendment of the Regulation, it is envisaged that the competition provisions will not be applied for the auxiliary sources of the pre-license applications made for the hybrid/hybrid renewable electricity generation facilities. Other provisions of article 15 of the Regulation regarding the evaluation process of pre-license applications are applicable to the said generation facilities.
Pre-license holder legal entities applying for the purpose of establishing multiple sources electricity generation facilities are obliged to fulfill their obligations in the first and second paragraphs of the 17th article of the Regulation, which regulates the works and procedures that must be completed within the term of the pre-license. These obligations can be fulfilled individually or together on the basis of sources.
Conversion of the Facilities in Pre-license/License Stage to Hybrid/Hybrid Renewable Electricity Generation Facility
It is possible to convert the generation facility in the pre-license/license to multiple source electricity generation facility, in accordance with the provisions added to the article 18 and 24 of the Regulation, which regulates the conversion of the facilities having pre-license/license. Accordingly, the conversion application made in this direction can be found suitable if it meets the following conditions:
- a) Not to go out of the field that is associated with pre-license/license,
- b) Not change the total electrical installed power of the facility, which is assigned to pre-license/license,
- c) Not change the current connection type, the connection point and voltage level that is included to the pre-license/license,
ç) Being appropriate of the technical evaluation made by the General Directorate of Energy Affairs for auxiliary sources, whose auxiliary source is based on wind or solar energy,
- d) Providing the appropriate opinion by DSI (Directorate General for State Hydraulic Works) for pre-license/licenses based on hydroelectric sources, the lease agreement has been signed with DSI for solar power units to be installed on the canal surfaces of the hydroelectric sources or in the reservoir area between the maximum water level and the operating level.
Providing that the relevant document is submitted to the Authority for the completion of the obligations set out in the fifth paragraph of the 18th article of the Regulation and the fourth paragraph of the 24th article of the Regulation within the period determined by the Board decision and after the notification date of the Board decision, pre-license/license conversion shall be made.
Utilization from YEK Support Mechanism (YEKDEM)
In the Official Gazette dated 08.03.2020 and numbered 31062, the amendment to the Regulation on Certification and Support of Renewable Energy Sources was also published. The amendment is set forth to come into force on 01.07.2020.
Accordingly, the amount of net energy produced and given to the system in the hybrid renewable electricity generation facility is evaluated at the lowest of the prices determined for the renewable energy sources used in the generation facility and within the scope of YEKDEM for the remaining period of the facility.
In the event that the generation facilities within the scope of YEKDEM are converted into a hybrid renewable electricity generation facility, providing that all of which are renewable, the YEKDEM utilization period shall not be changed.
Guarantee Refund
In the article 45 of the Regulation, it is regulated in which cases the guarantees submitted to EMRA during the pre-license and license applications will be refunded or will be recorded as revenue.
According to the provisions brought by the amendment of the regulation, in case the unit established based on the auxiliary source in the hybrid/hybrid renewable electricity generation facility becomes operational before the unit based on the main source becomes operational, the guarantee provided to the Authority for the unit based on the auxiliary source shall not be refunded until the unit based on the main source is operational.
