Implementation of virtual net metering system by self-producers

With virtual net metering, it is permitted to net the energy injected into the Network by a production station against the energy consumed by one or more consumption installations of the self-producer, without the requirement that the production installation be located in the same or an adjacent area as the consumption installation, or be physically connected to it through the same supply line—conditions that apply in standard net metering.

The terms and conditions for the development of production stations with virtual net metering were established by Ministerial Decision ΑΠΕΗΛ/Α/Φ1/οικ.175067 (GG Β’ 1547/5.5.2017) which was repealed and replaced by Ministerial Decision ΥΠΕΝ/ΔΑΠΕΕΚ/15084/382 (GG Β’ 759/5.3.2019) and was finally amended by Ministerial Decisions ΥΠΕΝ/ΔΑΠΕΕΚ/74999/3024 (GG Β’ 3971/30.8.2021) and ΥΠΕΝ/ΔΑΠΕΕΚ/121503/5016 (GG Β’ 6287/29.12.2021).

Virtual net metering can be implemented in the following ways:

• Netting the energy injected into the Network from a production station against the energy absorbed by a consumption installation of the self-producer at a remote location (compared to the production installation). In this case, the production station is connected to the Network via a new supply, in standard independent producer scheme. The same applies in the case where the station is located close to or adjacent to the consumption installation without being electrically connected to it.

•  Netting the energy supplied to the Network by a production station against the energy absorbed by more than one consumption installations of the self-producer at remote locations (compared to the production installation). In this case, the production station is connected to the Network via a new supply, in standard independent producer scheme. The same applies in the case where the station is located close to or adjacent to one or more of the consumption installations, without being electrically connected to any them.

• Netting of the energy supplied to the Network by a production station with the energy absorbed by more than one consumption installations of the self-producer, one of which is located in the same or adjacent area as the production installation and is electrically connected to it. In this case, the production station shall be connected to the Network either through the existing supply of that consumption installation (as known from net metering) or after its increase, if required by the size of the station.

Eligible parties include: a) Legal entities under public or private law pursuing public benefit or other public interest objectives of general or local scope. b) Those registered in the Register of Farmers and Agricultural Holdings in accordance with Law 3874/2010. c) Motorway concessionaires holding a Concession Contract ratified by law, who either own the site where the production station is to be installed or have legal use of the site (e.g., through lease, free concession, etc.), provided they have obtained the written consent of the site owner.

Specifically for those registered in the Register of Farmers and Agricultural Holdings of Law 3874/2010 the presentation of a certificate of affiliation from the competent body (O.P.E.K.E.P.E.) is required.

On the mainland and the interconnected islands (including the small Interconnected System of Crete) the capacity of each production station must not exceed the sum of the agreed capacity of all consumptions to be netted (in kVA) and the maximum capacity of 3 MW.
Specifically for small wind turbine production stations or stations with two technologies, one of which is small wind turbines, the total installed capacity small wind turbines may not exceed the maximum of 60 kW.

Stations with virtual net metering are exempted from the obligation to obtain a Producer’s Certificate.

In the Non-Interconnected Islands (NIS) the capacity of the production station cannot exceed the sum of the agreed capacity of all the consumptions to be netted (in kVA) and the limit of the following Table:

Specifically for small wind turbine production stations or stations with two technologies, one of which is small wind turbines, the total installed capacity small wind turbines may not exceed the maximum of 60 kW.

Stations with virtual net metering are exempted from the obligation to obtain a Producer’s Certificate.

It should be noted that the capacity of production stations with virtual net metering is counted in the respective power margin of each NII power system. The power margin per technology and per power system is determined by RAE Decision 616/2016. The same Decision provides that the margin for photovoltaic production stations is allocated exclusively to Special Roofs Program stations and to stations with net metering or virtual net metering (self-producer or Energy Community).

For the stations in Rhodes with an installed capacity exceeding 100 kW and in the rest of the NIIs with a capacity exceeding 50 kW, the rules for integration and operation provided for in the NII Code (Article 206) apply, and therefore the Operator can impose the limitation of the active power output of these stations or even their shutdown. To this end, these production stations shall be equipped with remote monitoring and control equipment in accordance with the requirements of HEDNO.

Production stations can feature one of the following technologies: photovoltaic stations (with fixed photovoltaic on buildings or on the ground or with ground-based solar tracking systems), biomass/biofuel plants, biogas plants, small hydroelectric plants, CHP plants and small wind turbine plants. In particular, production stations connected to the MV alone may consist of two of the above technologies.

The basic terms and conditions for the installation of production stations with the application of virtual net metering are as follows:

a. The existence of an active permanent consumption supply in the name of the self-producer1 (at least one supply).

b. All consumption supplies to be netted as well as the supply of the production station must:

•  be in the name of the self-producer (under the same VAT number)2,
• be represented by the same Supplier,
•  belong to the network of the same Operator
• if the station is connected to the LV, then it is mandatory that all the services to be netted are connected at the LV level. There is no corresponding restriction if the station is connected to the MV. Consumption supplies to be netted can be connected either to MV or to the LV.
•  be located in the same Regional Unit and, in addition, for the NII they must belong to the same electrical system,
•  not to be involved in the execution of another netting (“Special Roofs Program”/
  “Special Program for Developing low power Photovoltaic Systems in residences connected to a corresponding residential account”), net metering or virtual net metering)
• specifically for those in the Register of Farmers and Agricultural Holdings of Law 3874/2010, all consumption to be netted must relate to agricultural holdings, i.e. facilities of exclusive agricultural use in accordance the legislation in force.

c. The interested party must either own the site where the production station is installed or have the legal use of the site (e.g. through lease, free concession, etc.) and have obtained the written consent of the owner of the site.

d. The installation of one production station with virtual net metering per independent property is permitted. Independent property is considered to be the land for which a separate title is presented or referred to as such in the same title and which has not been obtained by partition through lease or sale of individual parts of the land, created after 23.1.2018, the date on which Law 4513/2018 came into force.3

1 Construction site supplies are not treated as permanent.
2 Article 68 of Law 4602/2019 makes provision for the possibility for first and second grade Local Authorities to install RES and CHP stations with virtual net metering to cover energy needs belonging to other legal entities (with different VAT number), namely. 13 of Article 107 of Law No. 3852/2010 (A’ 87), school units of pre-school, primary and secondary education, school special education and training school units (SMEE) of Article 8 of Law 3699/2008, health centers and hospitals of public interest, without profit-making capacity. However, the application of virtual net metering in these cases has not been foreseen and is not covered by the provisions of Ministerial Decision ΥΠΕΝ/ΔΑΠΕΕΚ/15084/382/19.2.2019(GG Β’ 759/5.3.2019), as in force
3 The condition does not apply to stations installed by legal persons under public or private law, and which pursue public benefit or other purposes of public interest, of general or local range, General Land Reclamation Organizations and Local Land Reclamation Organizations.

In the connection application to HEDNO, the self-producer declares the element of consumption supplies they wish to include in the netting, provided that these supplies comply with the terms and conditions mentioned above. The element of consumption to be netted is also indicated in the Appendix to the Virtual Net Metering Contract that the self-producer signs with the Supplier of their choice. The self-producer reserves the right at any time to amend the Appendix to the Virtual Net Metering Contract by submitting a new declaration of supplies to the Supplier. The declaration shall be notified to HEDNO.

The netting of the produced energy is carried out on a mandatory and priority basis with consumption connected to electricity in the same supply as the production station, if any. If, after netting, there is a surplus quantity of energy injected into the Network, it shall be offset against the consumption of the next time settlement account.

For the sizing of the production station it is appropriate to take into account the annual consumption of the consumption installations to be netted. It is recommended that the annual energy produced by the station should not exceed the total annual consumptions to be netted.

In the Interconnected System and on the island of Crete for PV stations connected to LV4 consumption installations, the connection request is submitted to the competent local unit of HEDNO (Region), while for PV stations connected to MT consumption installations, the connection request is submitted to the headquarters of the competent Region Department of HEDNO. Applications for stations with other technologies, regardless of the level of connection, as well as for stations with a combination of two technologies shall be submitted to the Network Users Department. In the Non-interconnected Islands applications for PV stations, regardless of the level of connection, they will be submitted to the competent Region of HEDNO. For other technologies, applications will be submitted to the Islands Management Department.

The application must be accompanied by the document and the information indicated in the application form for this stage (template available on the website of HEDNO). It is a prerequisite that the relevant technical study has been carried out by an engineer with appropriate expertise and that the type of equipment to be installed has been selected.

The connection requests will be submitted to the protocol of the competent receiving unit (NUD, Region Department), will receive an incoming protocol and then the completeness and correctness of the file will be checked. If the file is incomplete, it will be returned to the applicant.

The competent department of HEDNO (Area/Region/NUD) shall within the next two
(2) months following the submission of the application, proceed to the written formulation of a Final Connection Offer to the applicant, provided that the conditions in the application form for issuing a Final Connection Offer are met. The offer shall include a description of the works to be carried out by HEDNO for the connection and the total related costs, as well as the works and actions to be undertaken by the applicant for the implementation of the connection. The offer shall be valid for a total period of two (2) months from the date of its issue. Within the above

4 In 3φ LV supplies, PV stations with a capacity equal to the Agreed Power of the supply can be installed. Applications for connections to existing supplies No. 6 and No. 7, where PV stations with a capacity of up to 135 and 250 kW respectively are now allowed, will be handled by the relevant HEDNO Regions.
period, a written acceptance must be submitted by the interested parties. Any failure to comply with the two-month period will result in the automatic termination of the offer of connection.

In particular, for the Non-Interconnected Islands, the Connection Offer will be granted if there is available power margin in the specific electricity system.

The activation of the station must completed within the validity period of the Connection Offer. The validity period of the Connection Offer is defined as:
a) twelve (12) months from the granting, provided that no work is required on the LV/MV Substations.
b) twenty-four (24) months from the date of its issuance, if the construction of a new LV/MV Substation or extension of an LV/MV Substation is required.

Specifically for cases where there is an obligation to conduct competitive procedures, in accordance with the provisions public procurement, in order to implement the project, the validity of the Connection Offer is extended by eighteen (18) months respectively, provided that the operator informs HEDNO before the expiry of the Offer.

At the same time as the acceptance of the Final Connection Offer, the interested party submits an application for the signing of the Connection Contract to the competent unit of HEDNO (Area/Region/NUD), presenting the additional documentation required at this stage. The competent unit notifies the interested party of the procedure for payment of the connection fee and signing of the Connection Contract.

a. In the case of a PV station connected to an existing supply and its connection does not require a new Network project or an increase in the power of the supply, the costs for the connection are presented in Table 1. Included in the costs are also the costs of controlling a production meter and the metering transformers, where required. The indicated prices shall be increased by the applicable VAT.

Table 1: Costs of connecting a PV production station with virtual net metering to the Network of HEDNO in an existing supply (without new Network project and without increase of supply capacity)

b. In the case of connection of a PV station to an existing supply, for which an augmentation project is required, the self-producer is additionally charged with the augmentation project.

c. In the case of connection of a PV station through a new supply, the connection project is charged after a budget of the actual costs of its connection, in proportion to the connection charges of operational support stations.

After the signing of the Connection Contract, the self-producer submits a request to the Supplier representing the production installation and the consumptions to be netted, for the signing of the Virtual Net Metering Contract. The procedure shall be completed within 15 days from the date of receipt of the request. The effective date of the Virtual Net Metering Contract shall be the date of activation of the connection of the production station.

The Virtual Net Metering Contract signed between the Supplier and the self-producer has a term of 25 years, starting from the date of activation of connection of the production station.
In the event of a change of Supplier of the production installation and all consumption installations, after the activation of the production station, the Virtual Net Metering Contract is automatically terminated and a new Netting Contract is concluded between the self-producer and the new Supplier for the remaining 25-year period.

The connection of the production station with virtual net metering is carried out either by using an existing supply to which a consumption installation is connected or by using a new supply.

• In case a new supply is required, follow the procedure provided in the procedure for connecting a new independent producer, proportional to level of power they are connecting to. The meter of the new supply shall constitute a fixed asset of the Network and shall be installed by HEDNO. In particular in the case where two generation technologies are combined to produce energy, two additional meters shall be installed.
• In the case where an existing consumption supply is used for the connection of the production station, as in the case of energy netting, if the existing meter of the consumption installation is not of double direction – reading, it is replaced and a second meter is installed for the measurement of the electricity produced by the production station, which constitutes a fixed part of the self-producer, from which it is installed, as in the case of “standard” net metering. In particular, where two generation technologies are combined to produce energy, two meters are installed instead of one production meter. The other consumption installations involved in the netting remain connected via the existing supply and meters.
• In case the installed capacity of the production station exceeds the capacity of the existing supply, in addition to the above works, an increase in supply will be required.
• In any case where the production station is connected to the indoor installation of an existing supply, the connection will be made as in the case of “standard” net metering, as follows:

In the case of low-voltage (LV) users, the production station is not connected to the main distribution panel of the installation, but rather to a point upstream of the panel (see Figure 1). For medium-voltage (MV) users, it is connected to the LV busbar. In both cases, the connection is made in such a way that the main consumption panel is simultaneously supplied with power from both the grid and the production station.

To activate the connection of the production station the following is required:

• The submission of a request from the interested party stating the readiness of their installation with the relevant supporting documents attached to the request for this stage.
• The completion of the works required by HEDNO, such as replacement of an existing meter, construction of any connection project and carrying out the required checks of the production installation for safe connection to the Network.

The metering of all consumption services involved in the virtual net metering and the production installation shall be carried out during the consumption cycle of each of them, except in cases where simultaneous extraordinary metering of all supplies is required, which are (a) the case of a change of supplier for all consumption and production supplies, (b) the expiry of twenty-five (25) years from the activation of the connection of the station and (c) the termination or cancellation of the netting contract for any reason.

After the activation of the production station, the energy injected into the Network is subtracted from the energy absorbed by the Network and the difference, if positive, yields the net energy to be charged by the Supplier as chargeable energy in the competitive part of the bill. If the difference is negative, there is no energy charged and such difference shall be credited to the next time clearing account of another clearing consumption as injected energy. The procedure, if there remains a surplus of injected energy, shall be repeated in subsequent clearance bills of other cleared consumptions of the utility, until is zeroed out, or else the remaining part is credited as additional injected energy in a new cycle of clearance bills.
The self-producer shall be obliged to pay in due time each issued debit clearance bill for all its consumption included in the netting, irrespective of any energy expected to be credited in subsequent periods.

The transfer of any surplus energy from past metering periods shall continue until the next metering of the energy produced, after the expiry of three years from entry into force of the Virtual Net Metering Contract and the procedure shall be repeated every three years until the termination or expiry of the Contract. At the end of each three-year period, any surplus energy (negative balance) resulting from the netting shall not be credited to a subsequent clearing account and there shall be no obligation to pay any compensation to the self-producer for this action.

In the case where the production station is connected to the MV and one or more consumption supplies are connected to the LV, the absorbed energy of each LV supply is netted against the injected energy of the station, which has been previously reduced to the LV level by an appropriate factor.

This reduction factor is calculated annually by HEDNO on the basis of HEDNO’s estimation study approved by RAE on the loss factors of the network. Only the technical losses of the LV network are taken into account for the calculation. Indicatively, for the calculation of the reduction factor to be applied in the year 2019, the value of the factor ΣΠΑ_ΧΤ = 4.34% was used, which was calculated based on the data of the 2018 study, after considering zero non-technical losses. The reduction factor was found to be equal to 95.84%, i.e. 1000 kWh injected from a production station to the MV is equivalent to 958 kWh to the LV.

Therefore, for example, if in an LV supply to be netted, the metered energy was greater than 958 kWh and the injected energy was 1000 kWh, the total injected energy is used for the netting and the remainder is charged as chargeable energy. Conversely, if the metered energy was less than 958 kWh, the netting shall be made with part of the injected energy, no chargeable demand the supply shall arise and the surplus of injected energy shall be credited to the next clearance bill of another netted supply.

It is noted that the reduction factor applies the Interconnected Network. The same coefficient will be applied to the NII systems until the RAE Decision on the determination of the loss factor in each system is issued.

a) For consumptions not connected to the production station installation the regulated charges are calculated as normal as for all consumers.

b) For the consumption that enters into the virtual net metering and is electrically connected to the installation of the production station:

• The Public Utility Services charge is calculated in each clearance bill on total consumption of the self-producer installation on the basis of the energy consumed, i.e. “Absorbed + Produced – Injected ” energy, multiplied by the corresponding unit charge. In the case of a tariff with different billing time zones, the sum of the produced and injected energy will be used for the calculation of the Public Utility Services charges corresponding only to the consumption of the normal billing zone (daily consumption).
• The charges for ETMEAR, System Usage, Network Usage and other regulated charges are calculated in each clearance bill on the energy absorbed by the Network, multiplied by the corresponding unit charge.

• Requests for capacity augmentation for stations for which a request has been submitted in principle without a connection offer having been issued in the meantime shall be considered as new requests and shall be dealt with in chronological order in which the request for increase was submitted.
• Requests to increase the capacity of stations for which a connection offer has been issued and is in force are considered as new requests, i.e. they are examined in the chronological order of submission of the increase request and a new connection offer is issued for the new total capacity if there is available electrical space, with cancellation of the original offer, otherwise it remains in force.
• Requests for augmentation of the capacity of production stations after the activation of the connection will be possible, at the same level, after a new request, the granting of a new Connection Offer and the payment of the related costs. In such cases, the Connection and Netting Contracts will be amended with regard to the capacity of the production station.

The transition of operating systems installed under the “Special Roofs Program” as well as net metering to virtual net metering is allowed for the remaining period of time against the 25 years of the originally concluded Netting Contract.
The transition requires the submission of a request, the summary of a new Connection Contract (if required) and the summary of a new Virtual Net Metering Contract with the Supplier. The costs of the transition shall be borne by the party concerned.

If the provision is in the name of the usufructuary, the usufructuary without the consent of the bare owner. If it is in the name of the bare owner, the bare owner with the consent of the usufructuary. In cases of joint ownership, the master in whose name the provision is made with the written agreement of their joint owners.

The aforementioned Solemn Declaration concerns the entire installation, i.e. both the existing consumption installation, after it has been modified, and the production installation that is integrated into the consumer’s internal electrical installation. This Solemn Declaration and the relevant documentation accompanying it (design, technical report, description of how to avoid islanding, protection arrangements, etc.) shall be signed by an Electrical Engineer or an Engineer of similar specialization with the corresponding professional title (e.g.

Self-producers with virtual net metering must ensure compliance with the provisions of the applicable planning and environmental legislation during the installation of the production station and ensure the issuance of all the required permits, approvals or other relevant administrative acts, which they must submit to the Network Operator, whenever required.
Before the activation of the production station, HEDNO will receive a solemn declaration of Law 1599/1986 from the self-producer as well as from their responsible engineer, with
which they will attest to and assume responsibility compliance with all relevant provisions.

Consistent with par. 13 of Article 8 of Law No. 3468/2006 as in force, PV stations installed in a building or other structures or within organized receptors of industrial activities, are exempt from the obligation to issue an Environmental Terms Approval (ETA) decision and the inclusion in standard environmental commitments (SEC) and for the exemption from ETA and SEC no certificate is required
For the placement of PV stations in a building with a power output of up to 100 kW, no building permit or approval of small-scale building works is required. For PV stations with a capacity exceeding 100 kW, approval of small-scale building works and a structural adequacy study of the building on which the installation will be made, signed by a qualified civil engineer, is required.

PV stations with a capacity of less 1 MWp installed on land are exempt from environmental licensing if they are not located in a Natura 2000 network area or in a coastal location less than 100m from the coastline of the shore, except for rocky islets. Otherwise, the stations are classified in Category B in accordance with Ministerial Decision ΥΠΕΝ/ΔΙΠΑ/74463/4562 (GG 3291 Β’ 2020) and are subject to a SEC. In any case, the installation of PV stations on land requires the approval of small-scale building works.

It is permitted provided that the specific supplies will be opted out of the virtual net metering, otherwise a change of supplier will have to be made for all the simultaneous production and consumption supplies.

The Supplier shall carry out a special reading and issue clearance bills. Any surplus energy shall not be compensated and a new Virtual Net Metering Contract shall be concluded with the new Supplier.

The process from application to connection and operation of the station is summarized in the following steps:
Step 1: Submit a connection request to the Network Operator.
Step 2: If the application file is complete and the information is correct, the Operator will review the request and make a connection offer to the interested party or will reject the application. The offer shall include description and cost of the connection work and shall be valid for period of two (2) months from the date of issuance. Within the aforementioned period, the interested party must submit its acceptance in writing. Any failure to comply with the two-month period will result in the automatic termination of the offer of connection.
In compliance with Ministerial Decision ΥΠΕΝ/ΔΑΠΕΕΚ/28857/1083 (GG 940 Β’ 2020), as amended by Ministerial Decision ΥΠΕΝ/ΔΙΠΑ/74463/4562 (GG 3291 Β’ 2020), applications for production stations with net metering are classified in Group B2 and are considered in absolute priority over applications classified in Groups C, D and E (while their consideration follows chronologically in relation to the Solid Waste Management Entities applications that

5 Provided that the contribution of the production station to the short circuit at its output is not greater than S times its rated power (in the case of connection of plants of other technologies than photovoltaic).
are classified in Group A). The offer shall be issued within the next two (2) months following the submission of the request. In case of inability to connect, the Operator shall keep the application pending if they receive a request from the applicant within one (1) month of its granting.
Step 3: Acceptance of the connection offer and submission of a request for the preparation of the Connection Contract. Stations with virtual net metering are not subject to a guarantee for the commitment of the electrical space.
Step 4: Signing of the Connection Contract with simultaneous payment of the relevant expenses. The Operator then proceeds with the construction of the connection works. If no connection work to the Network is required, the works shall be completed within one (1) month from the signing of the Contract. In the case where Network works are required, the construction of the works shall be completed within four (4) months for stations on the LV, within eight (8) months for stations on the MV if no works are required on HV/MV Substations and within eighteen
(18) months if HV/MV Substation extension works are required.
Step 5: Submission of an application to draft a Net Metering Contract to the Supplier representing the supply to be netted.
Step 6: Signing the Net Metering Contract with the Supplier. The Contract is signed within fifteen (15) days from the receipt of the request.
Step 7: Submission of a request to activate the connection. Upon completion of the construction of the production station, the interested party applies to the Operator for the activation of the connection of the production station.
Step 8: Activation of the connection within the validity period of the connection offer. Upon activation of the connection, the Net Metering Contract comes into force, which has a term of twenty-five (25) years.