GREECE Law and Practice Contributed by: Evangelos (Evans) Courakis, Evangelos Mylonas Tsoumas, Sofia Andreanoudi, Vassiliki Xynou and Ioanna Marouso Argyriou, Koutalidis Law Firm
are regulated by the Management Code for the Greek Electricity Transmission System, which is scrutinised and approved by RAWEW. Users, such as independent producers and eligible customers, connect to the system through spe- cific installations extending from their premises to the existing grid. These projects, termed “sys- tem expansion projects” under the management code, require an implementation agreement between IPTO and the user to allocate respon- sibilities. Costs for these projects, including land expropriation, are solely the responsibility of the applicant. Once completed, ownership of equipment and associated civil works transfers to IPTO. The extension projects for the connec- tion of producers and consumers may be imple- mented either by the respective producer or consumer, or by IPTO. In any case, IPTO shall be responsible for the control and the supervision of the construction and location of the extension works. As far as projects connecting to the grid, the framework and, in particular, Law 4951/2022, as amended and in force, provide that such projects would have to obtain a GCO from either IPTO or HEDNO (depending on whether the voltage is high, medium or low). Grid connection lines always belong to the operator and not the owner of the connected station. Substations, however, may be owned by the RES station owner, who is nevertheless obliged to facilitate the connection of other RES station owners to the substation. 4.2 Obtaining Approvals to Construct and Operate Transmission Lines and Associated Facilities The regulatory process for obtaining all neces- sary approvals to construct and operate a trans- mission line and associated facilities involves several critical steps and considerations. The Energy Law foresees that IPTO must annually
submit the TYNDP to RAWEW. This plan ensures system adequacy and supply security, detailing major infrastructure projects, ongoing and new investments, with feasibility studies and time - lines. It considers demand response, energy storage and other alternatives to system expan- sion. According to the Electricity Transmission Man- agement Code, extension projects of the Dis- tribution Network, as well as the substation development projects are implemented by IPTO, which undertakes the licensing of such pro- jects, such as obtaining environmental permits and any building permits, pursuant to the Greek legislation (Laws 4014/2011 and 4495/2017, respectively). The environmental licensing process for trans- mission lines or other transmission network works depends on the environmental categori- sation of such activities. Works expected to have a significant environmental impact are required to submit an environmental impact assessment. The assessment of the environmental impact depends on the scope and the characteristics of the requested project, the size of the works required and its impact on the environment. In the case of transmission lines, this would mostly depend on the length of the lines, the nature of the area where the lines are to be installed and whether a substation would be required. It is noted that new substations for specific projects, as well as the transmission lines to be installed for the connection of such projects to the grid, are included in the environmental assessment required for the issuance of the projects’ envi- ronmental permit. Lastly, IPTO’s TYNDP is also accompanied by a strategic environmental impact assessment, which needs to be approved by the Ministry of Environment and Energy.
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