The authorization for electricity power plants (IGE, as referred in Spanish), given the general economic interest of the electricity supply, is subject to a complex mixed authorization procedure (legal and technical), in which both the necessary legal and economic control of the public administration over the generation facilities that make up the energy mix must be coordinated, as well as the precise technical control of the electricity grid managers to ensure that these facilities comply with the parameters required for the energy produced to be transmitted safely into the grids and, of course, for the later usage.
Within this mixed authorization procedure, the degree of significance of the generation facility is essential.
What is the degree of significance of the generation facilities?
We can define the degree of significance as the result of the evaluation performed by the electricity grid manager to which a specific IGE is to be connected, in order to determine the set of technical requirements that it must meet and, therefore, must prove to said electricity grid manager during commissioning and as a prerequisite for the commercial exploitation of the generated electricity.
What are the degrees of significance of the generation facilities?
The degrees of significance of an IGE are fixed, on the one hand, in Article 5 of Commission Regulation (EU) 2016/631 of April 14th 2016, and on the other hand, in domestic law, in Article 8 of Royal Decree 647/2020, being these degrees of significance divided into four types or groups:
|Type of MGE||Connection Point voltage||Maximum access capacity|
|Type A||< 110 kV||&||=/> 0,8 kW & =/< a 100 kW|
|Type B||< 110 kV||&||> 100 kW & =/< a 5 MW|
|Type C||< 110 kV||&||> 5 MW & =/< a 50 MW|
|Type D||=/> 110 kV||Or||> 50 MW|
Who carries out the evaluation of the significance of the generation facilities?
The evaluation of significance does not derive from a unilateral interpretation by the promoter based on the interpretation of the regulations according to the characteristics of their project.
The evaluation and determination of significance is an exclusive function of the electricity grid manager to whom Access and Connection permission has been requested and obtained.
This is because, as we saw in the previous table, the determination of significance derives from the content of Access and Connection permits, so who better than the electricity grid manager to officially and unequivocally determine the degree of significance of the IGE.
This has been expressly stated in Article 8.8 of Royal Decree 647/2020, which states:
“The relevant grid manager shall be responsible for notifying the holders of electricity generation modules of their significance […]”
What are the steps to determine the degree of significance?
Based on the table, the steps to determine the degree of significance are as follows:
The first step, of course, is to obtain the Access and Connection permit since, as we said, these permits contain the necessary elements for its determination, as the granted access will determine the maximum capacity allowed for the IGE and the granted connection point, the voltage of the same.
In other words, the determination of significance derives from elements that we can qualify as extrinsic to the IGE, insofar as they are granted by a third party (TSO or DSO), and that, of course, must be specified by the promoter in their project.
The second step focuses on the voltage data of the connection point since:
- If the voltage is =/> 110 kV, we do not need any further information since the IGE will be type D.
- If the voltage is < 110 kV, we know that we are not dealing with a type D, and we move on to the third step.
The last step will, therefore, be to consult the maximum access capacity to determine if we are dealing with type A, B, or C.
What is the relevance of the degree of significance of the generation facilities?
Therefore, the significance of generating power plants marks the technical roadmap that the promoter must follow throughout the entire authorization process for the promoted IGE.
Initially, since promoters only have a preliminary project at the time of requesting access and connection permits, the degree of significance indicated in said permits will serve them in specifying the project that must obtain Prior Administrative and Construction Authorization.
Likewise, after the IGE’s construction is completed, the degree of significance will determine the stages of its commissioning and the technical requirements that the promoter must demonstrate to the grid operator prior to connection and prior to the definitive operating authorization and registration in RAIPEE.
In accordance with this, the regulatory rules of network codes applicable to generators (specified in Regulation 2016/631, Royal Decree 647/2020, and Order TED/749/2020) and the NTS (Technical Standard for Supervising the Compliance of Electricity Generation Modules under EU Regulation 2016/631) adopt a progressive criterion, such that the higher the degree of significance, the greater the technical requirements.