GREECE Law and Practice Contributed by: Evangelos (Evans) Courakis, Evangelos Mylonas Tsoumas, Sofia Andreanoudi, Vassiliki Xynou and Ioanna Marouso Argyriou, Koutalidis Law Firm
3.3 Approvals to Construct and Operate Generation Facilities In Greece, the installation, construction and operation of a generation facility require com- pliance with the environmental terms set out in the project’s environmental permit, adherence to technical and safety standards, as well as maintaining the validity of all necessary permits and licences from the relevant authorities. The generation facility owner must also have lawful use of the land plots where the project is located. Maintaining the permits might entail certain amendments or renewals during the project’s lifecycle. The renewal and the amendment pro- cess for each permit could be summarised as follows. • The producer’s certificate and the special pro- jects certificate are valid for an initial period of 25 years. Law 4685/2020 and the RES Licensing Regulation allow for the renewal of the certificates every five years and for a maximum of 25 additional years under certain conditions. Amendments are generally allowed, albeit major amendments may only be requested at specific timeframes. • Environmental permits, either ETA or SEC, are valid for 15 years and require the submission of a renewal file at least two months before expiry, with the environmental authority reviewing the file within 15 working days. The complexity of the renewal process for the ETA depends on whether modifications to the pro- ject characteristics or compliance with new regulations necessitate changes in the ETA. A modification of the project might require an amendment to the ETA and the imposi- tion of stricter environmental terms and the complexity of the process for such amend- ment depends on the scale and the expected impact of the modification.
potentially significant environmental impact requiring environmental impact assessment studies) and Category B projects (ie, projects with potentially lesser environmental impact). Category A projects require the issuance of an environmental terms approval (ETA), which follows a stricter administrative process, including the drafting of an environmental impact assessment study and the issuance of opinions from various administrative authori- ties and stakeholders. In contrast, Category B projects are subject to standard environmen- tal commitments (SEC), which is a simpler and standardised process. • Following the environmental permit, the pro- ducer may apply for a grid connection offer (GCO) from the competent operator. At this point, it is important to note that grid connec- tion applications are examined in accordance with a detailed prioritisation framework. • Upon acceptance of the GCO, the pro- ducer proceeds with obtaining an installation licence. The installation licence requires that the producer has secured the land related to the installation polygon, allowing it to apply for the respective building permits neces- sary to begin the project’s construction. At the same time, the producer proceeds with executing a final grid connection agreement (GCA) with the competent operator. • The final licensing step before the generation facility’s operation is obtaining an operation licence. One should note that the process above is the usual licensing process for generation facilities in Greece. There are deviations for special pro- ject categories or smaller scale projects.
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