The Council of Ministers has approved, on 29 December 2020, the Royal Decree regulating access and connection permits for the installation of renewable plants.

New request

Firstly, the CNMC must approve (by Circular) the methodology and conditions of access and connection.

The Royal Decree establishes that the system operator will accept new requests for access and connection permits once published the values of available access capacity at each node (calculated according to the new criteria that will be established in the above-mentioned Circular).

General criteria: time priority

Applications for access and connection permits will be considered and granted in the order that they are received. For this purpose, the relevant date will be the date the application was submitted to the system operator.

If the application submitted requires any correction, the submission date will be the date when all required documentation and information has been duly submitted to the system operator.

If two applications have the same date, priority shall be established based on the submission of a receipt certifying that the required economic guarantees have been correctly deposited.

The time priority criteria do not apply to (i) the hybridisation of existing facilities and (ii) public tenders for access capacity in certain nodes of the transportation grid for the integration of renewables.

Installed power

The rule introduces a new definition of installed power for photovoltaic plants, which will be the lowest among the sum of the maximum unitary powers of the photovoltaic modules that make up the installation and the maximum power of the inverter, or inverters, that configure the installation.

Public tenders for access capacity

The Royal Decree introduces new tenders for access capacity in specified nodes of the transportation grid (new nodes introduced by means of a new planning process for the electricity transportation grid or by means of the modification of specific aspects of the current plan, or nodes where new capacity emerges).

The participants must be new facilities which (i) generate electrical energy from renewable sources and (i) can store electricity.

Hybridisation of the facilities

Operators of existing installations may request the modification of permits from the system operator without the need to apply for a new permit when the installed capacity for each of the technologies making up the hybridisation may not be less than 40% of the access capacity granted in the access permit or requested. The time periods applied to obtain permits for hybridisation of existing installations shall be those of the simplified procedure and the guarantees shall be reduced by 50%.

However, applications must be submitted to the general application procedure (rather than the simplified procedure) with the following modifications:

  1. The amount to be covered by the guarantees required for granting access shall be reduced by 50%; and
  2. If there is an application in progress, an update may be made, starting from the original application date for the purposes of time priority, provided that the generation.

Storage regulation

The Royal Decree expressly includes the projects of storage, the figure of which has been expressly defined by the Royal Decree-Law 23/2020. In particular, storage facilities that can discharge energy into the grid will be treated as a power generation facility regarding access and connection permits.

Exemption of self-consumption

The Royal Decree exempts form obtaining access and connection permits:

  1. Self-consumption generation facilities without surplus and those of 15 kW or less that are located on developed land that has the provisions and services required by urban planning regulations.
  2. Self- consumption facilities up to 100 kW of low voltage and 250 kW of high voltage that are located on developed land that has the provisions and services required by urban planning regulations.

Additionally, the rule sets out a simplified procedure for owners of facilities with an installed capacity of less than 15 kW and for low-voltage consumers requesting a connection point of less than 15 kW. Under the simplified procedure, all deadlines are reduced by half.

Revocation of the sole spokesman of the node and the coordinated applications

Under the new regulation the following obligations are revoked:

  1. The obligation to appoint a sole spokesman if the node (IUN), in those position where there is no previous IUN; and
  2. The obligation to submit joint and coordinated request if several generators share a connection point to the transportation grid.

Rocío Gros
Lawyer