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Last update: 02.04.2017
National Contact Point: eclareon - Ivana Naydenova
(in(at)eclareon.com)
Bulgaria: Small Scale Residential PV
The construction of small rooftop PV systems on residential buildings in Bulgaria is hampered by numerous complicated procedures. It is not possible only by notification, but involves obtaining permission (Building Permit). This procedure entails the need for a supervision company to monitor the construction of the PV system architectural, electrical, static and other designs subject to special approval by the municipal administration. According to an amendment to the RES Act, more formal simplified regime for building of small PV on ... (Unhide text)rooftops and surrounding areas were implemented by reducing the number of procedures, relevant to large and middle scale ground mounted PV plants. The procedure should not last more than 60 days, but in practice it takes over 4 months because of several controversial provisions. A transitional provision of the RES Act implements rescheduling of the grid connection of larger scale PV plants after 2016, which the Electricity Distribution Companies are trying to apply also for the small residential PV segment.
Additional information on RES-E plants’ location is available at: http://vei-bg.org/en/projects?srch=true&text=&type=1%7C8%7C9&oblast= (Hide text) PV installations on residential rooftops and surrounding areas
Additional information on RES-E plants’ location is available at: http://vei-bg.org/en/projects?srch=true&text=&type=1%7C8%7C9&oblast= (Hide text)
Legal entity
Description
Electricity producers shall be legal entities to have the rights to issue invoices to the electricity supply company.
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | Registry Agency/Commercial Register |
| Specialists: | Solicitor |
| Legal Level: | |
| Legal Reference: | Trade Act |
| Year: | 1991 |
Barriers
It is not allowed to sign contracts, incl. purchasing contracts personally. The producer has to establish a legal entity, which slows, complicates and raises the cost of building a small PV installation and maintenance of the legal entity for the whole lifespan of the installation.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | Energy Act (Zakon za energetikata) |
| Year: | 2003 |
| Severity Level [1-10]: | 2 |
"Energy System Security" Fund
Description
All energy producers should pay installments to the Fund amounting to 5% of the monthly revenues from sold electricity, VAT not included.
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | Ministry of Energy |
| Specialists: | |
| Legal Level: | |
| Legal Reference: | Art. 36e (3) of the Energy Act (EA) |
| Year: | 2003 |
Barriers
The retroactive tax of 5% on the monthly revenues for all electricity producers has the greatest impact on RES because of the fixed price of the produced renewable energy. Therefore, this tax is a capital expense of the renewable energy producers which will make the investment in PV even more unattractive.
| Legal Level: | |
|---|---|
| Legal Reference: | Art. 36e (3) of the Energy Act (EA) |
| Year: | 2003 |
| Severity Level [1-10]: | 7 |
Preliminary PV system study
Description
A preliminary inspection of the roof needs to be done - roof slope, shadows, accessibility of the roof, using by birds for nesting. A consultation with the neighbours is also advised since their approval is needed in the follow-up steps. Conducting market research and a meeting with a qualified rooftop PV installation company. Inspection of the suitability of the roof structure; of grid connection feasibility; selecting an appropriate system size and type; drafting a preliminary proposal for locating and fixing the modules.
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | |
| Specialists: | Installer/Builder or Individual |
| Legal Level: | National & Regional |
| Legal Reference: | |
| Year: |
Barriers
Lack of knowledge among potential clients about the benefits of rooftop PV systems. Few people are aware that they have real opportunities to generate electricity using their roof space.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 5 |
Few roofs are in a suitable condition to have PV systems installed on them. The main problems are: old roof structures, lack of adequate maintenance, unsuitable roof materials.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 2 |
Contract with the owner of the building
Description
A contract for the roof provisions is needed – either for renting it or establishing the right to build on behalf of the building’s owners. The user is a legal entity operating the rooftop PV system.
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | Notary Public |
| Specialists: | Solicitor, Manager |
| Legal Level: | |
| Legal Reference: | Land Use Planning Act - LUPA (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
Barriers
Lack of knowledge among potential clients about the benefits of rooftop PV systems. Few people are aware that they have real opportunities to generate electricity using their roof space.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 5 |
Few roofs are in a suitable condition to have PV systems installed on them. The main problems are: old roof structures, lack of adequate maintenance, unsuitable roof materials.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 2 |
Technical and working plans
Description
Drafting technical and working plans for all elements of the PV installation by a team of technicians and engineers; Coordination of technical and working plans with the Building Supervision Company. The plans shall be submitted to the Municipality to apply for design permit.
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | Municipality/District |
| Specialists: | Specialists - engineer-constructor or engineer planners |
| Legal Level: | |
| Legal Reference: | Land Use Planning Act - LUPA (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
Barriers
A different set of administrative procedures in different municipalities. In some municipalities procedures are more complicated due to the opinions of the environmental/health administration on the assumed damaging impact of the system on people/birds. To some extent this problem is due to ignorance and a lack of adequate knowledge about PV.
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA, Natura 2000, health ordinances, building and construction requirements |
| Year: | |
| Severity Level [1-10]: | 4 |
Unclear procedure for planning. Some municipalities require the plans to contain exact specifications of the provided equipment (like brand and electricity parameters of the provided modules).
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA, Chapter V |
| Year: | 2001 |
| Severity Level [1-10]: | 3 |
The procedure of putting into operation a small PV system is identical to that of medium to large PV plants and it is hard to be done without the help of a specialist company. This leads to loss of time and money.
| Legal Level: | |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 5 |
Design permit
Description
A deed of ownership is needed along with an up-to-date property plan (the latter should not be older than 6 months). In case of lack of ownership, a contract with the building’s owner establishing the right to build on the roof and a declaration of consent from the owner are needed. Then, a design permit based on motivated request submitted to the Chief Architect is issued along with the respective documentation in accordance with the LUPA (Land Use Planning Act).
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | Municipal/District administration |
| Specialists: | Chief Architect of the respective Municipality/District; Specialists from various administrative departments |
| Legal Level: | |
| Legal Reference: | Land Use Planning Act - LUPA (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
Barriers
A different set of administrative procedures in different municipalities. In some municipalities procedures are more complicated due to the opinions of the environmental/health administration on the assumed damaging impact of the system on people/birds. To some extent this problem is due to ignorance and a lack of adequate knowledge about PV.
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA, Natura 2000, health ordinances, building and construction requirements |
| Year: | |
| Severity Level [1-10]: | 4 |
Unclear procedure for planning. Some municipalities require the plans to contain exact specifications of the provided equipment (like brand and electricity parameters of the provided modules).
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA, Chapter V |
| Year: | 2001 |
| Severity Level [1-10]: | 3 |
The procedure of putting into operation a small PV system is identical to that of medium to large PV plants and it is hard to be done without the help of a specialist company. This leads to loss of time and money.
| Legal Level: | |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 5 |
Application for grid connection
Description
The owner of the installation needs to submit a written application for grid connection to the DSO in order to understand the technical availability and the conditions for grid access. The network operator shall consider the application within 14 days. In case of incomplete documents, the applicant may act on the instructions of the DSO in the 30-day period, otherwise the procedure will be terminated.
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | Distribution System Operator (DSO) |
| Specialists: | Individually or Specialist/Installer |
| Legal Level: | |
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
Barriers
A Decision of the National Electricity Company for rescheduling the grid connection of large and middle scale PV is interpreted and applied as relevant to this segment as well. On this the Distribution System Operator bases its arguments for postponing the moment of grid connection for small installations after 2016 or to nullify the grid connection procedure.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 9 |
The Ordinance 6 provides an opportunity for the Electricity Distribution Companies (EDC) to reject connection of the installation to the grid. This is contrary to the preferential status for connection of residential installations provided by the RES Act.
| Legal Level: | |
|---|---|
| Legal Reference: | Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
| Severity Level [1-10]: | 7 |
Standpoints and contracts differ between the various distribution system operators (EVN, EnergoPro, CEZ). Some of them do not indicate the connection point in their preliminary standpoint, on the basis of which all licensing procedures for the construction of the system are carried out.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 4 |
Legal remedies
The DSO has no right to illegally refuse access to the grid, grid connection and signing of purchasing contract. If it happens, the producer can appeal the actions of the DSO at the Regional Court.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
Preliminary grid connection contract
Description
Signing of a preliminary grid connection contract with the DSO (This step is not needed for PV installations on rooftops and surrounding areas with capacity up to 30 kWp). For preliminary grid connection contract with the DSO for installation with a capacity upto 5 MW the investors schould make an advanced payment in the amount of 25 000 BGN (approx 12 830 €) pro installed MW.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Distribution System Operator (DSO) |
| Specialists: | Specialist/Installer |
| Legal Level: | |
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
Barriers
A Decision of the National Electricity Company for rescheduling the grid connection of large and middle scale PV is interpreted and applied as relevant to this segment as well. On this the Distribution System Operator bases its arguments for postponing the moment of grid connection for small installations after 2016 or to nullify the grid connection procedure.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 9 |
The final grid connection contract is not possible to be issued by the Distribution System Operator without a building permission for the PV installation.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA (2011), LUPA (2001) |
| Year: | 2011 |
| Severity Level [1-10]: | 5 |
Request for a final contract
Description
Written request for the signing of a final contract after obtaining a permission for the investment project. The applicant may also propose to change the terms of the preliminary agreement.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Distribution System Operator (DSO) |
| Specialists: | Specialist/Installer |
| Legal Level: | |
| Legal Reference: | Art. 96 (1) of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
The final grid connection contract is not possible to be issued by the Distribution System Operator without a building permission for the PV installation.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA (2011), LUPA (2001) |
| Year: | 2011 |
| Severity Level [1-10]: | 5 |
Standpoints and contracts differ between the various distribution system operators (EVN, EnergoPro, CEZ). Some of them do not indicate the connection point in their preliminary standpoint, on the basis of which all licensing procedures for the construction of the system are carried out.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 4 |
Approval of plans by the DSO
Description
Coordination of testing plans with the Distribution System Operator before applying to DSO for a final grid connection contract and a purchasing contract
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | Distribution System Operator (DSO) |
| Specialists: | Specialist/Installer |
| Legal Level: | |
| Legal Reference: | Art. 96 §2 of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
A Decision of the National Electricity Company for rescheduling the grid connection of large and middle scale PV is interpreted and applied as relevant to this segment as well. On this the Distribution System Operator bases its arguments for postponing the moment of grid connection for small installations after 2016 or to nullify the grid connection procedure.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 9 |
Final contract
Description
Applying and signing a final electricity purchase contract with the DSO.
| Step Difficulty: | |
|---|---|
| Authority Level: | |
| Authority Name: | DSO: Distribution System Operator |
| Specialists: | Specialist/Installer |
| Legal Level: | |
| Legal Reference: | Art. 85 (2) of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
A Decision of the National Electricity Company for rescheduling the grid connection of large and middle scale PV is interpreted and applied as relevant to this segment as well. On this the Distribution System Operator bases its arguments for postponing the moment of grid connection for small installations after 2016 or to nullify the grid connection procedure.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 9 |
The final grid connection contract is not possible to be issued by the Distribution System Operator without a building permission for the PV installation.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA (2011), LUPA (2001) |
| Year: | 2011 |
| Severity Level [1-10]: | 5 |
Standpoints and contracts differ between the various distribution system operators (EVN, EnergoPro, CEZ). Some of them do not indicate the connection point in their preliminary standpoint, on the basis of which all licensing procedures for the construction of the system are carried out.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 4 |
Grid access
Description
Signing a grid access contract with the DSO.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Distribution System Operator (DSO) |
| Specialists: | Specialist/Installer |
| Legal Level: | |
| Legal Reference: | Art. 85 (1) of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
A Decision of the National Electricity Company for rescheduling the grid connection of large and middle scale PV is interpreted and applied as relevant to this segment as well. On this the Distribution System Operator bases its arguments for postponing the moment of grid connection for small installations after 2016 or to nullify the grid connection procedure.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 9 |
The final grid connection contract is not possible to be issued by the Distribution System Operator without a building permission for the PV installation.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA (2011), LUPA (2001) |
| Year: | 2011 |
| Severity Level [1-10]: | 5 |
Standpoints and contracts differ between the various distribution system operators (EVN, EnergoPro, CEZ). Some of them do not indicate the connection point in their preliminary standpoint, on the basis of which all licensing procedures for the construction of the system are carried out.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 4 |
PV system finance
Description
The Bulgarian financial institutions are conservative in their behaviour. The approach applied by banks varies from one case to another. The producer should apply for credit to bank, leasing company, etc.
| Step Difficulty: | High |
|---|---|
| Authority Level: | National |
| Authority Name: | |
| Specialists: | Banks, Financial institutions, Leasing companies, etc. |
| Legal Level: | National & Regional |
| Legal Reference: | |
| Year: |
Barriers
Limited local capital for funding PV installations. There are no incentives for support the installing of small residential plants, even in the model of FIT support scheme - insufficient capital to invest in PV plants. Difficuties to receive a credit from local banks, leasing companies, etc.
| Legal Level: | |
|---|---|
| Legal Reference: | none |
| Year: | |
| Severity Level [1-10]: | 7 |
Incoherent energy policies and insecure legal framework pull back foreign investments. In the past years there had been many changes in the energy laws, policies, incentives, retroactive decisions, generation limitations, etc., which have made the investment field in Bulgaria quite unstable and unpredictable, thus leading to a reflux of investments.
| Legal Level: | National & Regional |
|---|---|
| Legal Reference: | |
| Year: | |
| Severity Level [1-10]: | 7 |
Contract with the company for the assembly of PV systems.
Description
A contract is signed for the supply, assembly and maintenance of the PV system with PV system integrator company after the building permit for the PV system is issued by the Municipality
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | |
| Specialists: | Installer, Solicitor |
| Legal Level: | National & Regional |
| Legal Reference: | |
| Year: |
Barriers
Due to a lack of knowledge by the supervision companies and the Distribution System Operators, errors could occur during the further legalisation of the site by the local building authorities during the different building phases, according to the Land Use Planning Act (LUPA)
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA - Land Use Planning Act (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
| Severity Level [1-10]: | 4 |
Assembly of the PV system
Description
The system is built by the supply company. Construction is monitored by the supervision company
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | |
| Specialists: | Installation company |
| Legal Level: | |
| Legal Reference: | LUPA - Land Use Planning Act (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
Barriers
Due to a lack of knowledge by the supervision companies and the Distribution System Operators, errors could occur during the further legalisation of the site by the local building authorities during the different building phases, according to the Land Use Planning Act (LUPA)
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA - Land Use Planning Act (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
| Severity Level [1-10]: | 4 |
PV system construction supervision
Description
The built system shall be supervised by the engineer who has made the construction plans, by the building supervision companies and by experts of the DSO.
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | DSO |
| Specialists: | Specialists, Engineers |
| Legal Level: | |
| Legal Reference: | LUPA - Land Use Planning Act (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
Barriers
Due to a lack of knowledge by the supervision companies and the Distribution System Operators, errors could occur during the further legalisation of the site by the local building authorities during the different building phases, according to the Land Use Planning Act (LUPA)
| Legal Level: | |
|---|---|
| Legal Reference: | LUPA - Land Use Planning Act (Zakon za ustroistvo na teritoriata) |
| Year: | 2001 |
| Severity Level [1-10]: | 4 |
Technical testing of PV systems
Description
72-hour tests are carried out in the electrical PV connection systems. During this test, the installation is put under tension. After the test has been carried out, the installation is granted a receipt for entry into service. In the next stage, tests are made for the individual facilities and subfacilities of the power plant.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | DSO |
| Specialists: | Installer, Supervision, DSO |
| Legal Level: | |
| Legal Reference: | Art. 63 of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
The grid operators do not explicitly guarantee grid access despite a positive preliminary standpoint. Access is conditional on "technical feasibility at the moment of connection". This does not provide the investor with any certainty that the system will be connected to the grid after its construction.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 7 |
Distribution grid connection requirements vary between Distribution System Operators. Complex and inaccurate technical prescriptions in grid connection contracts. DSOs require different documents, which delays the signing of the contracts.
| Legal Level: | |
|---|---|
| Legal Reference: | Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
| Severity Level [1-10]: | 6 |
Legal remedies
The DSO has no rights to illegally refuse access to the grid, grid connection and signing of purchasing contract. If it happens, the producer can appeal the actions of the DSO to the Regional Court.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
Grid connection
Description
Connecting PV electricity system to the grid.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | DSO |
| Specialists: | Installer, DSO specialists |
| Legal Level: | |
| Legal Reference: | Art. 63 of the Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
Barriers
The grid operators do not explicitly guarantee grid access despite a positive preliminary standpoint. Access is conditional on "technical feasibility at the moment of connection". This does not provide the investor with any certainty that the system will be connected to the grid after its construction.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act, Art.61 (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 7 |
Distribution grid connection requirements vary between Distribution System Operators. Complex and inaccurate technical prescriptions in grid connection contracts. DSOs require different documents, which delays the signing of the contracts.
| Legal Level: | |
|---|---|
| Legal Reference: | Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
| Severity Level [1-10]: | 6 |
Signing a Feed-in tariff contract
Description
The Feed-in tariff (FIT) is fixed for 20 years. To have the right of FIT, the producer has to comply with the grid connection requirements of the Renewable Energy Sources Act (RESA). The formal securing of the FIT happens, when a purchasing contract with the DSO is signed, as the most important appendix is the protocol for commissioning issued by the Regional Directorate of National Building Control (RDNBC). The exact amount of FIT is fixed depending on the date of commissioning of the plant. The FIT is secured as of the day of commissioning of the PV system - the produced electricity will be purchased on the relevant FIT, determined by the Energy and Water Regulatory Commission (EWRC).
| Step Difficulty: | Low |
|---|---|
| Authority Level: | |
| Authority Name: | DSO, Energy and Water Regulatory Commission (EWRC) |
| Specialists: | |
| Legal Level: | |
| Legal Reference: | RESA - Renewable Energy Sources Act; LUPA - Land Use Planning Act |
| Year: | 2011 |
Barriers
The electricity feed-in tariff is fixed but is determined annually or more often for new RES projects by unclear mechanism which makes the investment initiative almost impossible. The FIT can be changed every time, when there is a 10% change in the price-forming components, but there is no clarity about the range of the FIT change. No clarity about the information sources, on which the 10% change is based and proved by the Commission of Energy and Water Regulation.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 7 |
DSOs refuse sometimes to purchase the full amount of electricity from rooftop PV plants, motivating that first the PV plant “own electricity needs” should be considered and then, the rest of the electricity will be purchased. “Own needs” are mistakenly interpreted as the electricity need of the entire building on which roof the PV plant is. This problem is usually resolved by registering a legal entity, as then, "own needs" are interpreted as the needs of the PV plant.
| Legal Level: | |
|---|---|
| Legal Reference: | Ordinance 6 on Connecting Electricity Producers and Consumers to the Electricity Transmission and Distribution Grids (Naredba 6) |
| Year: | 2014 |
| Severity Level [1-10]: | 5 |
Guarantees of origin
Description
The producers have to submit monthly an application for issuance and transfer of guarantees of origin of the produced energy for the previous month.
| Step Difficulty: | Moderate |
|---|---|
| Authority Level: | |
| Authority Name: | Sustainable Energy Development Agency (SEDA) |
| Specialists: | Technical specialist |
| Legal Level: | |
| Legal Reference: | Art. 4 (3) of the Ordinance for issuance and transfer of guarantees of origin (Naredba za izdavane I prehvarliane na garancii za proizhod) |
| Year: | 2011 |
Barriers
Unnecessary administrative procedure for issuance and transfer of the guarantees of origin with obligatory administrative taxes. The approval of the produced electricity could be done directly between Distribution System Operator and Sustainable Energy Development Agency. The administrative fee for application for guarantees is not among the priceforming components of FiT, but should be paid monthly by the producer.
| Legal Level: | |
|---|---|
| Legal Reference: | Ordinance for issuance and transfer of guarantees of origin |
| Year: | 2011 |
| Severity Level [1-10]: | 5 |
Grid access fee
Description
According to Decision № C-7 of 7.4.2017 of EWRC, the grid access fee for non-household customers is currently 0.01651 BGN/ kW/ day, and for household customers - 0.00503 BGN/ kWh. The price for electricity transmission in the distribution grid with medium voltage is 0,00808 BGN/KWh and with low voltage - 0.02933 BGN/ kWh.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Commission on Energy and Water Regulation (EWRC) |
| Specialists: | Owner |
| Legal Level: | |
| Legal Reference: | Decision № C-7 of 7.4.2017 of EWRC |
| Year: | 2017 |
Barriers
A retroactive decision of Commission of Energy and Water Regulation (CEWR), which implements grid access fee in very high amounts (1-39%) gathered from PV producers from 18.09.2012 to its revocation in mid/late 2013. Although the fee was revoked by the Court, the EWRC does not reimburse the gathered money. New complaints have been filed to the court for returning the money.
| Legal Level: | |
|---|---|
| Legal Reference: | Decision C-33/14.09.2012; Decision KM-1/13.03.2014 |
| Year: | 2014 |
| Severity Level [1-10]: | 9 |
Since April 2017 the fee, which replaces the already revoked by the national court "temporary grid access fee" for PV and wind installations amounts to 0.01651 BGN/ kW/ day for non-household customers, and for household customers - 0.00503 BGN/ kWh. The fee is in force as of 18.09.2012 and is due in future. The amount of the fee is set by EWRC and cannot be predicted.
| Legal Level: | |
|---|---|
| Legal Reference: | Decision C-7/07.04.2017 |
| Year: | 2017 |
| Severity Level [1-10]: | 7 |
FiT is applied for part of the generation
Description
Only installations with overall installed capacity up to 30 kW which are envisaged to be mounted on roof and facade structures of buildings connected to the electricity distribution grid will be eligible for feed-in tariff support and benefit from a mandatory power purchase. Existing operational projects will continue to benefit from their respective feed-in tariffs and power purchase agreements (PPAs).
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | DSO |
| Specialists: | Owner |
| Legal Level: | |
| Legal Reference: | Art. 30 (5) of the RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
Barriers
This amendment reduces the expected overall income of the already installed PV installations, as this kind of limitations are not included in their initial business plans.
| Legal Level: | |
|---|---|
| Legal Reference: | RESA - Renewable Energy Sources Act (Zakon za energiata ot vazobnoviaemi iztochnici) |
| Year: | 2011 |
| Severity Level [1-10]: | 8 |
Limitation of Generation
Description
The Electricity System Operator (ESO) requests the generation from RES installations to be limited to 40–60% of their capacity, mostly between 10:00 and 17:00. According to the Energy Act (EA), the ESO may limit certain renewable energy plants, in case there is an "inability to maintain the balance between generation and consumption on the electricity grid. "
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Electricity System Operator |
| Specialists: | Owner |
| Legal Level: | |
| Legal Reference: | EA - Energy Act (Zakon za energetikata) |
| Year: | 2003 |
Barriers
As the limitations are during the day hours, they affect PV plants at most. The installations work with 40–60% of their capacity, which added to all the retroactive measures takes away 100% of their income.
| Legal Level: | |
|---|---|
| Legal Reference: | EA - Energy Act (Zakon za energetikata) |
| Year: | 2003 |
| Severity Level [1-10]: | 10 |
Costs for balancing
Description
The balancing market, in which PV systems are included, starts since 1 June 2014. The participation in this market is estimated to cost between 6 and 8% of the PV system income.
| Step Difficulty: | High |
|---|---|
| Authority Level: | |
| Authority Name: | Coordinator of a Balancing Group |
| Specialists: | Technical specialist, Owner |
| Legal Level: | |
| Legal Reference: | Rules for Electricity Trading (RET) |
| Year: | 2013 |
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