Turkey amends its unlicensed market regulation

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At long last, and something that has been widely expected by energy market players in Turkey, the amendment of the regulation on the unlicensed electricity generation in the electricity market has been issued. The amendment, prepared by Turkey’s Energy Market Regulatory Authority (EMRA), was published in the official gazette on March 23rd.

Three major changes

A spokesman for Turkey’s Solar Energy Society (Solarbaba) told pv magazine that the amendment brings three basic changes.

Firstly, a given company can install only one project up to 1 MW. In more detail: "Apart from the exceptions in relation to rooftop installations, the amendment on the regulation brought a restriction on the total installed capacity of plants held directly or indirectly by the same real or legal person," said Solarbaba. Thus, the total grid allocation to be made to unlicensed energy plants owned by one entity cannot exceed 1 MW per substation.

The updated regulation also requires the applicants to present information as per their direct and/or indirect shareholding in the course of their system connection application, which hints that the government aims to apply the rule strictly.

Secondly, whatever entity receives the call letter must also finish the project and connect it to the grid. In other words, project developers cannot sell a license before they develop and electrify the project. After a solar power plant is connected to the grid, the owner can freely sell the company to another investor.

Finally, the amendment on the unlicensed market regulation applies restrictions on the self-consumption front. Therefore, the meter of the investor applying for a new license must be rated at least 30 kW in order to install a 1MW project (the ratio is 1:30).

In more detail, power meters are rated according to the max Wattage. For example, households use power meters rated max 5 kW. So, if an investor aims to connect to the grid a PV installation using his power meter, he can only install up to 150 kW (this is 30 times kW). Investors who aim to install 1 MW of PV capacity need to arrange with the utility companies for power meters rated 35 kW.

The self-consumption requirement

Of perhaps lesser significance, but under the same scope of applying stricter rules on the self-consumption front, the amended regulation brought specific norms and procedures in relation to the distance to the grid connection. Thus, the distance from the unlicensed energy plant to the connection point cannot exceed five kilometers for plants with an installed energy capacity below 0.499 MW, and ten kilometers for plants with an installed energy capacity between 0.5 MW and 1 MW.

In fact, the self-consumption requirement already existed for the unlicensed installations. However, in practice, investors often built two to four different projects together and nearby, totaling 1 MW capacity and by far exceeding their power demand. It is possible that Turkish institutions deliberately turned a blind eye on this situation for the PV market to kick start. The amended regulations rather make it clear compliance will be much stricter.

Looking forward

Solarbaba’s spokesman said that the unlicensed market regulation amendment "will affect the PV market negatively," but he added, "we want first to observe the real situation on the field before making any comments, because those changes are on paper and the reality may differ from the theory."

So far, the unlicensed market has driven Turkey’s solar PV installations, adding about 150 MW of new PV capacity in 2015 alone. "The potential unlicensed pipeline is circa 1 GW," Andi Aranitasi, an Instabul-based senior member of the Power and Energy team at the European Reconstruction and Development Bank (EBRD) said recently.

The April issue of pv magazine will run an analysis of Turkey’s solar PV market including inputs from the EBRD and other major energy stakeholders.