The Electricity Generation Facility as axis for regulation.
The power generation has the Electricity Generation Facility as the main axis on which the regulations revolve, both with regard to the authorization procedure and to its commercial exploitation.
However, said characterization becomes more complex given the different terminology used by current legislation to refer to itself and given the diversity of elements that make up this type of facility.
Thus, various standards speak of:
- “Electricity generation facility” or IGE (article 2.6 Regulation (EU) 2016/231).
- “Electricity generation module” or MGE (article 2.5 Regulation (EU) 2016/231).
- “Synchronous electricity generation module” or MGEs (article 2.9 Regulation (EU) 2016/231).
- “Electric park module” or MPE (article 2.17 Regulation (EU) 2016/231).
- “Main generation plant” or PGP (article 2.8 Regulation (EU) 2016/231).
- “Electricity generation unit” or UGE (NTS).
- “Additional components of the MGE” or CAMGE (NTS).
This implies the need to delimit the concepts provided in the regulations to, once this, determine the legal incidence that each concept has during the life of the generation project.
From the IGE to the UGE, going through the MGE.
References included in regulations.-
Within the IGE authorization process, we must take into account each different stage to define which of the concepts we are referring to at each moment:
a) Access and connection.-
In compliance with the provisions of both article 33 of Law 24/2013, as well as Royal Decree 1183/2020 and Circular 1/2021, Access and Connection permits are granted to applicants who intend to build and commercially exploit the IGEs, specifying article 6.2 that the requests for Access and Connection permits for the IGEs will be made “for said installation, that is, for the set of electricity generation modules […] that are part of it, in accordance with the provisions of article 2”, which refers to the definition offered by Regulation (EU) 2016/631.
b) Administrative Authorizations.-
Both article 53 of Law 24/2013 and articles 111 et seq. of Royal Decree 1955/2000, relating to the administrative authorization procedure, always refer to Production Facilities, a term that is another way of referring to IGEs.
c) Commissioning.-
Regulation (EU) 2016/631 and its national implementing regulations, that is, Royal Decree 647/2020 and Order TED/749/2020, focus their attention on the MGE and, within them, on the MPE when we talk about photovoltaic solar installations.
However, the NTS goes into more detail and differentiates, within the MGE / MPE, between UGE and CAMGE.
d) RAIPEE.-
Finally, the references contained to the object of registration in the RAIPEE both in Royal Decree 1955/2000, and in Royal Decree 413/2014, are made, obviously and as it is clear from the name of the registry, to the Production Facilities of Electric Power, that is, to the IGE.
Relationship between the various terms.-
Despite the use of this diverse terminology, we are dealing with closely related terms.
Specifically, the relationship that can be established between all of them is a relationship of genus to species. So:
- The most generic concept that encompasses the rest would be that of IGE, which refers to that installation that converts a primary energy source (in our case the sun) into electricity and that is made up of one or more MGE connected to a grid. It is the concept equivalent to the Photovoltaic Solar Installation or ISF.
- Within an IGE, therefore, one or more MGE can be found, depending on its technical configuration, that is, electricity generation units or, what amounts to the same thing, the units that make possible the conversion of primary energy into electricity and that are divided, according to the different existing electricity generation technologies, into:
- MGEs.
- MPE.
- In the case of the ISF, we must speak of MPE, which is the unit or a set of units that, within the ISF, generate electricity and that are connected to the grid by means of power electronics, having a single connection point.
- However, the MPE can still be decomposed in more detail by existing:
- The UGEs, that is, those parts of the MGE / MPE that have the specific function of generating electricity and that are named by Regulation 2016/631 as PGP.
- The CAMGE, that is, the rest of the additional components of the MGE / MPE.
Conclusions.
From the above, we can draw the following conclusions:
i) It is perfectly correct to speak, always and in any case, of IGE or, in the case of solar energy, of ISF.
This is so because it is the IGE or ISF that both requests and obtain the Access and Connection permits, as well as administrative authorizations and registration in the RAIPEE.
ii) Notwithstanding this, we must take into account the idea or concept of MGE, since an IGE can be integrated either by a single MGE or by more than one MGE connected to the same point in the network.
In this way, the administrative authorization procedure will always refer to the MGE, one or more depending on the configuration of the IGE or ISF.
iii) In the same way, it is necessary to clarify that, in the case of the ISF, the term MPE can also be used since the MGE in photovoltaic plants are called MPE.
iv) Finally, and notwithstanding the foregoing, for the purposes of commissioning and the NTS, the regulations break down the MGE (MPE in ISF) into UGE (also called PGP) and CAMGE and that, for these purposes, the tests of compliance with the network codes are referred to certain elements that are part of the MGE (MPE in ISF).
