The National Electricity Transmission Company Transelectrica SA, as Transmission and System Operator (TSO), participated in a public debate organized by the National Energy Regulatory Authority (ANRE) on the draft amendment to the regulatory framework applicable to the connection of users to the public interest electricity network. Transelectrica supported a set of proposals and observations, submitted to ANRE during the consultation period, based on direct experience in the development and operation of the electricity transmission network.
These aim both to stimulate real investments in new production capacities and to ensure a predictable and rigorous framework, which allows the integration of viable and mature projects into the network, in order to ensure the operation of the National Electricity System (SEN), in conditions of safety, stability and continuity. Thus, Transelectrica formulated and submitted to ANRE a set of 8 concrete proposals to amend the Regulation on the connection of users to the public electricity network:
- Re-evaluation of network reinforcements before the commissioning of power plants
The reinforcement works identified following system analyses should be re-evaluated before the commissioning of production capacities and the capacities should be operated according to the need of the SEN.
- Clarification of the ownership regime over land
The lands related to specific reinforcement works (including the works between the connection point and the delimitation point, the land necessary for the expansion of the existing station) must be owned in property, and not in superficie, from the signing of the connection contract, in order to allow their transfer to the assets of the Network Operator.
- Elimination of the index tariff for reinforcement works
This tariff does not consistently reflect real costs or direct benefits for users or electrical installations, and its elimination is necessary.
- Strict compliance with contractual terms
In the case of extension of the connection contract, if the user does not submit the application and the necessary documents at least 30 days before expiration, the project is classified.
- Limitation of contractual amendments and introduction of progress criteria
The connection contract may be amended or extended no more than twice, provided that the related guarantees are established and that real progress is demonstrated, upon conclusion of the addenda to the connection contracts, by: proof of payment of at least 25% of the value of the purchased equipment or proof of completion of at least 10% of the works on the user installations.
- Clarification of the applicability of the terms for authorizations
The user is obliged to obtain the establishment authorization for the electricity production capacity, including for cogeneration and for storage facilities at the place of production/consumption, within a maximum period of 12 months from the conclusion of the connection contract and 18 months from the issuance of the Technical Connection Approval. The Regulation must clarify whether this provision also applies to the Technical Connection Approvals and connection contracts issued prior to the entry into force of this Order.
- Regulation of the implementation of reinforcement works by users
The Regulation clearly establishes the conditions under which users can carry out, from their own funds and at their request, reinforcement works already included in the Development Plan of the Network Operator.
- Introduction of a guarantee at the time of requesting capacity
The establishment by users of a financial guarantee, expressed per MW, from the first stage, that of submitting the capacity allocation request. This measure is fundamental to discourage speculative projects and to ensure realistic estimates of the network development needs.
Transelectrica considers that updating and correlating the regulatory framework is a priority to ensure a uniform and non-discriminatory application of the connection rules. At the same time, these measures contribute to disciplining investments and stimulating coherent projects, with a high degree of maturity, which can be efficiently integrated into the network.
The experience gained in applying the regulations in force highlights the need to harmonize secondary legislation with the provisions of primary legislation, as well as the introduction of clear mechanisms to encourage compliance with the deadlines for implementing new production capacities.
Over the last five years, in a productive collaboration with ANRE, Transelectrica has constantly submitted proposals and observations in this regard, so that a regulatory framework can be developed that supports sustainable investments and strengthens the security of the National Power System.
