Letter Spef to Samaras

Letter to the Prime minister, Antonis samaras, regarding the possibility of imposing an emergency levy on turnover to the generators of electricity from photovoltaics sent by spef.

SPEF is asking for prime intervention to prevent the scenario from being implemented, which it describes as disastrous for Investors. It also cites examples proving that the levy will work in such a way that photovoltaics “work” in favour of banks and eforiwns by bringing “crumbs” to Investors.

The letter was notified to Mr.  Ioannis stournara, Minister of finance, Mr. Kostis hatzidakis, Minister of Development and competitiveness, Mr. Notis Mitarakis Deputy Minister for Development and competitiveness, Mr Evangelos Livieratos Minister for the Environment of energy and climate change, To Mr. Stavros kalafatis, ANNE. Minister of Environment for Energy and climate change, Mr. A. papageorgiou, Deputy Minister of the Environment for energy and climate Change and N. vasilakos, chairman of the Energy regulatory Authority.

More specifically, the letter States:

Mr Prime minister, ministers

With this letter we receive the honour of appealing to you, convinced of your ability, sincerity and fortitude, with which and daily mochtheite in the interests of the country.  The stabilisation of the economy and the consequent society, are the epitome of a fundamentally productive regeneration that is required and must be syntelesete with respect for existing investments and the rule of LAW.

1. The cost from the operation of photovoltaic systems in 2012

In follow-up articles of our Association on the Apofeygomeno cost of the penetration of photovoltaic systems that perform most of their operation mostly at the peak of the load of the electrical system, the SPEF commissioned a study on the subject in Aristotle University of Thessaloniki (auth) and in particular the electrical Energy Systems Laboratory of the Department of Electrical and computer engineering.

The held study for the year 2012 simulates the development of the penetration of PV for the second semester and concerns the interconnected system in which the daily energy programming (iep) is carried out under the model Mandatory Pool that Our country works.

The main assumptions of the study concern installed power PV 1.200 MWp by the end of this year in the interconnected system and are examined the additional costs that would bring to the system the substitution of this power by conventional.  It is worth noting here that due to the Mandatory Pool model carried out by the IEP the additional cost of the conventional units that would fill the gap is not only equal to their own compensation but also to the over-compensation that would have brought to the already Due to the rise in the system limit value (ots).

so, Solving the study of the new IEP with the absence of PV for 2012 results in a cost of 244.6 Million. The euro means that the conventional power generation and imports will absorb to cover the gap of PV in the year 2012 Overall.  The amount of EUR 244.6 million is therefore The euro must be deducted from their total remuneration with FIT in 2012 in order to determine their etmear and not the amount of 78.8 Million. Euro which concerns the prorated in the “counterfeit” OTS value i.e. 62.9 euro/MWh X 1.25 TWh which is planned to be the annual PV power generation in 2012.  There is therefore an unreasonable charge of the Lagie’s special res account with 165.8 Million. (244.6 – 78.8 million Euro) for 2012 Only.  If we include here the corresponding amounts of years 2011, 2010 and so on, antilambanomaste that today we will not even omiloysame for a deficit due to the current PV modules.

In addition, the study identifies the effect on OTS from the abolition of the variable cost recovery mechanism (mme), which constitutes the important distortion of the electric Chondremporikis market, which will raise the average annual for 2012 OTS by the 62.9 Eur/mwhsta 76.5 Eur/MWh.  In this difference of 13.6 euro/MWh we add the prorated value added from the Power availability (sth) receipts received by the conventional units and amounting Mesostathmika to an additional EUR 9/MWh.  of the study, however, but of the combined further reasoning arises total artificial degradation in OTS for 2012 equal to 22.6 euro/MWh.

If this amount multiplied by the total production of res for 2012 (5.17 TWh) It gives an artificial deficit production to the special res account of the Lagie equal to 22.6 euro/MWh x 5.17 TWh i.e. 116.8 Million. Euros only for this year, while corresponding amounts obviously exist for previous Years.  We therefore conclude from this perspective that the lagie deficit due to res is artificial and is due to the miscalculation of the etmear on the basis of OTS which does not include the full cost of conventional power generation.

We explicitly restating our net position for no intervention whatsoever in the economics of in-service PV modules (direct or indirect, now or hereafter), which is not legitimized by anywhere, we note that:

2. What absolutely must be avoided

* The rule of law must protect and not penalise those who invested their money in the country instead of exporting it abroad.

* The actual numbers analysed above prove that for the minimum growth sizes of pv, the deficit shown in the special res account of the Lagie is Artificial.

* The money invested (3 billion EUROS) the producers to date borrowed expensively from the banks, through the Post-mortem intervention of the Ministry in their finances, will make them hostages without profit.

* The unilateral interest in “haircut” the yields of producers ‘ investments without “sheareding” their loans equally, thus ensuring in full only the interests of banks, constitutes a social challenge for thousands of power from PV .

* The request of the importers-traders of PV equipment, which in order to be revised incremental anarchically the national target of 2014 of 1, 500MW are illegally directed against our companies asking us to pay the power any new ones of their own sales, destroys any concept of legality and sustainability of the Market.  It is inconceivable to think that those who implemented investment will be harmed for more!


3. What we recommend

* Credit of the special res account with the money of the deficits that were virtually created up to the present day (as indicative for 2012), where the cumulative current deficit of 300, 000 million is to be reset. Euro.  This can practically be achieved by raising capital of the Lagie.

* Immediate removal of distortions in the calculation of the necessary etmear (former res charge) on the basis of the apofeygomenoy cost of the penetration of PV so as not to generate a new notional deficit in the special res Account.

* Immediate replacement of the fictitious current OTS by the actual complete Chondremporiko electricity cost that would incorporate the cost of the variable cost recovery mechanism (mme) and the power availability evidence (sth) in a Size. Transients can directly use the deviation limit value (ota) which is also daily accounted for by the administrator and for the first half of 2012 its average price was 81.8 euro/MWh when the fictitious OTS amounted to 63.5 euros/MWh.  This difference creates a virtual new shortfall in the RES Special account of EUR 95 Million. Euro for 2012.

• Reduction of Feed-in-Tariffs to from now on projects by category of power Separately.
• Abolition of the month of honour in the new Lagie Contracts.
• Limiting month to existing Lagie Contracts.
• Adherence to the national penetration targets of PV and not unregulated augmentation without proper financial planning because some ask for it.
• intervention, If it cannot be avoided, in economics (E.G. through emergency levy) only the projects to be linked from now On.
• Conversion of the program of domestic roofs from now on to a self-production program that will consume the energy produced and all that is left to sell in the Network.  It is completely unfair that the current regime that turns citizens into traders without tax and insurance obligations.
• Reduction of FIT in household and imposing ceiling of new installed power annually.

4. Economic Analysis

In order to illustrated understand the magnitude of the destruction that will bring to the power the measure of the levy on turnover, follows indicative economic analysis of PV Unit 100 KWp on Agros (with Full security system worth 20.000 euro and We emphasize this because the theft of PV parks has begun and no one can ignore this as cost, connection terms PPC 20.000 euros, means of earthworks and other qualitative-specifications 20etias-building works according to what is foreseen and exhausts the Poleodomki licensing i.e. fencing 2.5 m height with spikey coil of camp in the upper part and Senazi of concrete 0.4 m in the lower part, shelter, external and internal lightning protection) that was interconnected e.g. in mid 2011.  So we have:

Capital structure
Full cost of quality construction = 330.000 Euro
Loan 75% x 330.000 = 250.000 Euro treasury duration with interest rate 10% and fixed tokochreolytiki repayment.
Same participation 25% x 330.000 = 80.000 Euro Now the purchase of installation land e.g. 30.000 euro which did not counted however in the cost of construction of the Plant.

Annual Economic Analysis
Turnover of PV plant = 63.000 euro
repayments = 40.000 Euro
Operating expenses = 8.000 euro
Pre-tax Profit = 15.000 euro
Income tax = 4.000 Euro
Finally after tax profits 11.000 euro

Of these the professional producer or worse still each bonehead partner for producer companies, must cover individually and its insurance contributions which, according to the fund, range for example at 4.000 euros annually.

Therefore there remains net after tax profit for Living 11.000 – 4.000 = 7.000 Euro annually

This investor was called by the Greek state over time to invest in green growth, put the savings of 110.000 euros (80.000 same participation + 30.000 euros for the purchase of the installation field), borrowed another 250.000 euros from the banks Mortgaging and his personal property, in order to end up earning 7.000 euros annually, taking into account his insurance contributions.

If the producer is charged a levy on turnover e.g. 10% = 6.300 euros Then he will earn 7.000 – 6.300 = 700 euros annually! So his investment will only work for the banks and the irs, and he won’t even get the money he put back!

In conclusion, we would like to point out that the produced, for at least 25chronia, electricity from PV has only a positive effect on the current account of the country, since the imports of any fuel or other functional Raw material and thus no money is extracted abroad for the electricity produced by them and even at the peak of the system Load.

Following on from the above and the meeting we had in Ypeka on the subject last Thursday 26/7/12 and in no way have we been exposed to these destructive prostheses, please intervene to immediately abandon any thought of imposing a levy Turnover in operating PV modules.

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