The local communities in areas of project development (mainly wind farms and biomass/biogas plants) usually have a negative attitude towards the construction of such projects. Such negative attitude is often translated to fierce opposition.The problem is apparent in two levels. The first one is the local one. Local communities and interests as well as specific environmental NGOs are opposing the realisation of those investments. The arguments are the “classic” arguments against wind energy (landscape, bird population). The second level is the national, as the existing government is relating to some degree to those “anti wind” environmental groups, which try to exercise their influence on those matters. The similar problem is applied to biomass technologies and it is more serious as biomass in Greece is expected to be further supported in the near future.

Information campaigns concerning the benefits certain RES technologies have are advisable. Such campaigns are important on a local level so as certain “myths” surrounding certain RES technologies can be unveiled. Additionally, there should be a focus on the spillover benefits such RES may bring, as there is a very dominant narrative that “only the plant operator benefits from the installation of the RES plant”

Since Law 3468/2006 on the promotion of RES in Greece came into force (including its subsequent amendments), a significant number of prosecutions for annulment of RES licenses in the State Council (High Court) have taken effect. Such actions have been the result of the opposition by the local communities and public authorities (municipalities) towards the construction of new RES projects. Such barrier impacts the legal, technical or operational level of the RES sector. The renewable energy technologies affected by this barrier are mainly wind farms, small hydro power plants and biomass plants. Such barrier affects the licensing procedure of the RES projects since it has to be paused until the application of annulment is examined by the Court. In other instances, the barrier affects RES projects in operation. In most cases it takes more than 2 years for the annulment applications to be examined and for a decision to be delivered causing severe consequences to the energy companies developing such projects.

Information campaigns concerning the benefits certain RES technologies have are advisable. Such campaigns are important on a local level so as certain “myths” surrounding certain RES technologies can be unveiled. Additionally, there should be a focus on the spillover benefits such RES may bring, as there is a very dominant narrative that “only the plant operator benefits from the installation of the RES plant”

There are numerous administrative barriers which affect the permitting process of RES projects. As a result, it becomes very difficult for the energy companies to complete the permitting process of their projects in accordance with the timelines pointed out in the relevant legislative framework. The barrier impacts the legal, technical or operational level of the RES sector. All types of renewable energy technologies are directly affected by this barrier.This problem re-emerged and gained importance in 2019.

New investments in networks are required to connect the island complexes in Greece with the mainland. The current interconnection network is not adequate enough to cover the new RES capacity corresponding to national targets. The barrier impacts the legal, technical or operational level of the RES sector. Almost all renewable energy technologies are affected by this barrier and mostly the wind farms and photovoltaics.

This is a problem basically encountered in the biomass/ biogas sector and it is attributed to the inefficient training of professionals and public servants that could not fully understand the character of such an investment that is basically an investment of environmental value. As this barrier is mentioned in other barrier, this is delete so as to avoid duplication.

Administrative authorities should be educated and informed, so as to consider biomass as an RES and be aware of the benefits this RES technology may bring.

A problem that might appear in the future but would have severe consequences is the possible insolvency of the Special RES Account. The short-term capability of the Special Account to pay off its obligations to RES producers has been one of the key drivers behind the radical reform of the RES sector in 2014. It seems that this problem has been solved. However, the insolvency, i.e. the long-term capability of the Special RES Account, can constitute a great problem. This is due to the fact that the overdue obligations to PPC S.A. the main electricity producer in Greece, amount to €6.5 billion.

Cost of RES-E grid access can be seen as a barrier because of the fact that sometimes consists a considerable portion of the investment cost. This is also related to the predictability / transparency of connection procedure as there are sometimes problems with the connection point. This is an already known problem and it has to do with the TSO/ DSO.

Taxing regime applies not only to RES specifically, but to all enterprises located in Greece. Characteristically, corporate tax is set at 29% (26% in 2019) and creates an "unfriendly" business environment.

There are more than 100 Secretariats in different Ministries in charge of collecting data on available feedstock. Those different Secretariats do not cooperate and they are reluctant to exchange this data. Consequently, information remains fragmented, even on similar organic residues. This obstructs a comprehensive and holistic evaluation of the feedstock potential in the country, let alone their identification

For the estimation of the Reference Prices of all RES and CHP under Law No. 4414/2016 a methodology was applied where basic benchmark was IRR based on capital investment (CAPEX) operating costs (OPEX) and utilization rate. However, the methodology does not take into account the parameters of stable and foreseeable production, short-term storage, the possibility of CHP. In addition, the CAPEX and OPEX coefficients are fixed; regardless of size and this have an increasing effect for plants under 500 kWe. For example biogas with less than 100 kWe, CAPEX increases at least 50%. There is urgent need to revise Reference Prices, especially for units below 500 kWe. For such stations scaling is recommended, which will (indicatively) increase the Reference Prices for stations of 100 kWe to 275 € / MWh.

Primarily, PV and RES projects in general could be installed in so-called “high yield” fields. As this provision was abolished and only “low- yield” fields are now applicable for such projects. Such development reduces the number of available lands, where PV projects can be installed. The previous provision offered a steady and secure supply of lands, where PV projects could be prospectively located.

A bottleneck has emerged as far as the issue of the electricity generation license is concerned. During the monthly rounds for new production licenses, a great number of RES have submitted an application to the Greek Regulatory Authority on Energy (RAE). Among others, for the issue of the production license, RAE checks the investor's capability for realising the RES investment. However, such an argument is under the current auction scheme outdated, as this parameter can be assessed when this investment is taking part to one of the future tenders (by submitting a guarantee letter for 1% and afterwards of 4% of the investment, thus proving that the investment an be realised by the plant operator). Further issues that are examined for the issue of the production license will be examined in other process steps such as the Strategic Environmental Impact Assessment and the Connection offer. It is estimated that the issue of the production may take up to 1.5 years. In other words, a mature project may need almost 2.5 years so as to be eligible to take part to a tender. Consequently, this can create an unnecessary delay and many investors cannot take part in tenders, although their project is ready to be in operation.

The issue of generation license could be simplified. Instead of submitting a complete file with all necessarry documents, the process can be automatised and the generation license can be seen more of a checklist of certain key points.

Ministry of Environment and Energy has announced the amendment of the spatial planning framework, based on which the installation of RES is regulated. More specifically, the “Special Spatial Planning Plan” is the main regulating instrument for the deployment for RES. However, at the same time there are also “Regional Special Planning Plans”. Currently, the “Special Spatial Planning Plan” is prioritized over the respective regional plans. Nevertheless, it is feared that the amendment of those plans may be used by certain environmental groups so to halt further RES deployment. In addition, stricter guidelines are expected to be introduced. A further detail that can be put into consideration is that 37% of the Greek territory above 500m is Natura 2000+ sites. Therefore the Management Plans can contain details and restricting provisions concerning the future deployment of wind energy. Currently, this is apparent in some regions such as the island of Crete, where there exists a complete ban on wind. There are two fears concerning the composition of the new RES Spatial Planning Framework. The first one is to end up as a policy document without concrete planning guidelines. The second one is the fact that it can refer to the existing “Regional Special Planning Plans”. However, this will block instantly the deployment especially of onshore wind plants in certain regions of Greece (e.g. Creta).

Though the deficit of the Special Account for RES was starting to decrease since the introduction of the “New Deal” on RES in 2014, a four-month delay of LAGIE’s payment to the RES producers was observed. In addition, the RES and Guarantees of Origin Administrator (DAPEEP-former LAGIE) commitment to eliminate its deficit by the end of 2014 was gradually achieved. Despite the fact that the Special Account for RES, from which RES technologies are financed, has recently showed a surplus, there are concerns surrounding the sustainability of the account. This is due to the fact that the “Electricity Supplier’s charge”, a fee imposed on all electricity retailers was abolished in 2018. This is one of the prerogatives of the latest Memorandum of Understanding (MoU) between Greece and its creditors in 2015. The “electricity supplier’s charge” is a considerable input for the “Special Account for RES” and an alternative measure/ fee should be found so as the “Special Levy for the Reduction of GHGs”, imposed on all electricity consumers, will not be increased. In addition, there are further issues and risks concerning the sustainability of the Account. There are lawsuits against the Greek Electricity Market Operator (LAGIE) and the decision may influence negatively the account’s viability in short term, as those risks have not been yet sufficiently estimated. However, such fluctuations may prove to be worse than predicted and create a climate of unrest among investors. As of 2019, there is an increasing inquietude among plant operators. For example, one of the sources of revenues for the Special Account of RES are the revenues from selling excess CO2 emissions certificates. However, this relies on the CO2 emissions price, which is not a stable revenue source for the Special Account of RES. Apart from that, the balance sheet of the Special Account of RES shows an accounting surplus but this is not a real surplus, because debts to the Special Account to RES have not been really paid off. This is why payments to the RES producers are delayed by 3-4 months.

Supplier’s charge should not be returned to the energy supplers while new stable revenue sources for the Special Account should be found

The technical details and the necessary arrangements for the operation of a fully competitive market is a priority for the RES sector. Target model electricity market is a sine qua non requirement so as RES can enter the wholly new landscape.This is mainly due to the fact that RES plant operators are obliged to participate in the new competitive electricity market. Delays concerning technical arrangements may have a negative effect on RES. Apart from that, investors enter into a new era for RES and they need to be educated and learn about the new support for RES as well as their participation to the electricity market. As of 2019, it seems that the authorities proceed with scattered and incremental steps. Characteristically, just before the regulations on the distinct markets of market model are into place, the RES and Guarantees of Origin Administrator (DAPEEP-former LAGIE) is appointed as the Aggregator of last resort, i.e. the administrative body that will be responsible for representing RES plants operators in the electricity market (if they are not able to do that on their own or with the help of other private companies that are establisehd as Aggregators). This signals that RES plant operators are pressed to be included in the aggregator, although there is a lack of full functioning competitive electricity market. Furthermore, it also adds an additional burden as there are also gradually increasing participation fees.

There are so called grid congested areas where connection offers are not given. Therefore the challenge is to realise the long awaited interconnection that may ease the access and penetration of new wind energy capacity, while the further challenge has to do with the realisation of international interconnections. It seems to be a lack of a vision with regard to national and international interconnections. Although 10,000MW should be put into the grid by 2030, there is not an ambitious grid development plan. This could put in danger the connection of new RES in the future. As the technology advances and without a comprehensive and ambitious grid development strategy, all Greek regions will be rendered “congested”.

This ambitious but realistic development plan will include not only the timely realisation of interconnections in Greece but also a vision of realising grid development works in neighbouring countries so as to create a reliable transmission system in the Balcan region that can be connected in the mainland European Grid.

Greece has announced a tender scheme in 2016, with a pilot tender only for PV taking place in 2016. New tenders took place in July/December 2018 and included mature projects (PV and wind). The common tender for PV and wind was expected to take place in 2018 but it finally took place in April 2019. Apart from that, the participation regulations of the tenders (75% competition clause) left ample capacity undistributed, which will be offered in the next rounds. But as tenders proceed, the final strike price is gradually lowered and this obliges plant developers to review their initial planning. Finally, this project review makes developers repeat their licensing procedure and due to fact that there are considerable delays for the re-issue of the licenses and permits, this further delays the realisation of basically mature projects. Apart from that, many projects that are located in non-interconnected islands could not participate in tenders as the special provisions concerning their participation (additional premium of 25%) have not been defined. Additionally, with that deployment pace, the 2020 targets will probably not be met.

This applies basically to biomass, biogas and wind projects. It has been argued that such technologies are not equally treated on a national basis. Therefore there are cases that certain regions and the related administration may be against those technologies and does not allow their further realisation by not issuing the necessary permits.

Projects that necessitate substation may have problems with how this substation is installed and integrated into the grid. This is the case mainly in grid congested areas such as Peloponnese.

This is a special case as it concerns a special interconnection of the island of Eyvoia with the transmission grid. The cable has a capacity of 600MW and concerns the interconnection of the wind parks of the island with the grid. It is expected that the cable will also be financed by the wind operators themselves, thus increasing their cost of deployment. It should be noted that all projects that will be connected to the grid have already been in operation.

Greece has pioneered in relation to the transposition of the Energy Communities Directive. It was the first MS to transpose this Directive. However, this is a great challenge for Greece, as there is no tradition on such kind of partnerships. Therefore enabling consumers to prosumers and creating parnetships on energy communities is a step towards to that direction and it remains to be seen if this can succeed.

Due to the fact that the details of new electricity market have not been yet in place, banks and lending institutions consider the participation of those projects as “black box”. They are thus not reluctant to finance to new projects. Consequently, the projects cannot be easily realised.

Delays in the interconnection grid development works impede the introduction of new RES plants into the grid. Characteristically, the Region of Peloponnese, which is characterised as congested has an available capacity of 1,700MW (as it was estimated in 2012). However, this is expected to be revised further down to 1,200MW. Therefore, grid development should be urgent but it goes with a very slow pace. For example, the island of Crete will be connected to the mainland grid through two ways (from Peloponnese and through Cyclades Islands to the Attica Region). The first project is delayed, while for the second interconnection project, there have been disputes over the ownership of the project, as it was initially declared as a Project of Common Interest within the East Med Project, but the Government and IPTO declared it a national project. Apart from that, interconnections of other island complexes (Dodecanese and Islands of Eastern Aegean) are estimated to be constructed by the end of the 2020 decade, according to the Greek NECP.

The Greek NECP has adopted faulty assumptions that are expected to hinder the development of RES. One characteristic example is that estimated energy consumption of 2030 is even lower than that 2020. This ignores parameters as the rebound effect, where a country like Greece that is currently exiting a long period of economic crisis, is logical to pursuit a capital investment path that will boost the country’s economy and its energy consumption. Surely, the parameter of energy efficiency measures should not be undermined but there is need to extensive investments on that field, that are not plausible to be implemented. Other studies by other authorities (IPTO) assume that energy consumption will be greater. Nevertheless, the modest assumptions of NECP that is the strategic energy action plan of Greece will hinder the boost of Greek economy

As many mature projects are urged to repeat their licensing procedure due to the fact that prices in the tenders are falling, they are burdened with further delays. Redesigning a wind power project under new parameters obliges plant operators to resubmit for an approval of their Integrated Environmental Impact Assessment. However, the approval is currently delayed more than usual from 5-6 years to 7-10 years.

IPTO is currently overcharged with providing a connection offer for new wind power plants as well as to review the connection offer for re-designed ones. These further delays the deployment of wind power projects. The same is applied to PV plants. Due to the fact that considerable delays are witnessed in previous licensing steps, HEDNO and IPTO will be flooded with new submissions and this consequently can create a further bottleneck.

The latest amendments of RES support scheme in Greece (March 2019) have offered generous support especially for PV ˂500kW. More specifically, PV plants ˂500kW connected to the grid until the end of 2019 will be remunerated with a tariff of approximately €66/ MWh. For PV plants ˂500kW connected to the grid after 2020, the tariff will be based on the weighted average reference price of the last 3 tenders. It is estimated that the offered price may be as high as €73/ MWh or even €76.5/ MWh. Such generous support might lead to an overheating of the market, where many investors will be urged to invest in small PV, thus overgrowing the share of small PV in the RES and even surpassing the PV indicative target, as it is stipulated in the Greek NECP. Consequently, this can lead to a “market freeze” after several years. This is why the government should be alert to avoid any overheating of the market.

This is the greatest barriers concerning the deployment of small hydro in Greece. The regulatory framework was tightened long before the small hydro could be sufficiently deployed, as it happened with other EU MS. This is mainly a consequence of the EU WFD that prohibits any interventions in water bodies. Sometimes Environmental Impact Assessment of Small Hydro is not approved and consequently, plant operators are obliged to take legal measures against such decision and the realisation of small hydro is further delayed. The situation is further aggravated by the fact that there are in general unexpected delays in the licensing procedure. In any case, 6-7 years are needed so as a small hydro can obtain all the necessary permits. Currently, there are 800-1000MW of small hydro projects waiting in the pipeline.

This is a barrier that is a direct consequence of the long duration of the administrative procedure for small hydro and biomass. Once, the investment decision for the construction of a small hydro plant is taken, grid congestion is taken into consideration. However, after 5-7 years there is no clarity that the plant can be connected to the grid. This is due to the fact that other RES have been installed and reserved the grid capacity. Consequently, there is no room for a new connection for those palnts. One plausible solution could the grid reinforcement but this can be realised solely by the plant operator, who bears the whole cost.

Biogas stations are classified as industrial activities and, according to established practice, are subject to land use in rural areas under land use control. Result of these is that, in accordance with current environmental licensing procedures, it is generally not allowed to instal such stations on high yield agricultural fields. This general approach applies regardless of the scale of production, size of land covered, environmental (positive or negative), and either the energy source is conventional or renewable (RES). It also does not take into account the relevance of energy production to agriculture. Nevertheless, Article 24 of Law 4496/17 (a) provides for the possibility of installing Biogas -Biomass –plants on high yield agricultural fields provided that the raw material comes from an are within a radius of 30 km. It seems that this limitation is based on the intention of the legislator to create compensatory benefits for agricultural holdings in the area in which the plants are located, at the expense of high productivity land. But such a regulation has multiple negative consequences. First of all, only the producers and suppliers that are located within this territory are privileged and secondly, due to the morphology of the mainland territory (mountainous areas) many sources of feedstock are unable to supply new biogas installations.

RES plants above 500 kWe, which from 1 January 2016 are put into operation, the temporary compensation was set at 90% of the Reference Price, subject to future offsetting based on the sliding Premium tariff calculations. This arrangement came with Law No.4546/2018, about two years after Law No.4414/ 2016. The percentage reduction of the 10% compensation is arbitrary and it is based on the assumption that with the operation of the new electricity market, the premium received by the RES plants will be defined at this level. However, as the new electricity market is delayed, none of these assumptions seem plausible.

Law 4414/2016 abolished the distinction between Feed-In Tariff WS (with support from other sources) and NS (no support). RES plant operators that have already received support from other sources such as Direct Capital Grants ,Tax Leniency Grants or specific low-interest loans have received a lower FiT (WS) in contrast with other RES plant operators that received only FíT as support for their investment. The reduced price for units of WS was introduced to discourage integration into other support schemes, because these are considered as double aid. Law 4414/2016 retained the double tax avoidance clause (subsidy + grant) but in a different form. FiT WS was replaced by the Capital Adequacy Ratio (SAC). SAC calculated the "return" of the Investment Aid through the Decrease of the Operating Assistance, i.e. the Feed-In Premium. Principally, this is more rational than the previous regime (linked to the total amount of aid), but much more burdensome. This is due to the fact that the repayment - return of the entire amount of investment aid is required (10% for units <3 MW and 9% for plants> 3 MW). This urges biogas plant operators to redesign their investments under this new regime and in some cases they have applied to pay back their support so as to take advantage only from their FiT- FiP.