Peer Ritter
Rahandusministeerium
Our Ref: 02.01.2023 No 17-9/2022/2-1
Suur-Ameerika 1
10122, Tallinn
SA.102228 - Amendments to the budget of the
RES and CHP support scheme – SA.102228
Dear Mr. Ritter,
Thank you very much for the detailed and thorough letter.
We are hereby sending our reply to the questions and observations concerning amendments to the
budget of the RES and CHP support scheme:
1. We formally confirm that the aid amount increases under the notification here at issue
exclusively relates to aid to ‘existing producers’, therefore falling under the ‘existing’ scheme.
We also confirm that the producers with electrical capacity of 1 MW or more can receive
support as ‘existing producers‘ based on the ‘existing’ scheme only on condition, and therefore
the budget increase will only concerne them if the producer has started works on the investment
project concerning that generating installation by 31 December 2016 at the latest (Electricity
Market Act § 59 subsection 22). The producers with generating installations whose electrical
capacity is higher than 50 kW but falls below 1 MW can receive support based on the ‘existing’
scheme only on condition the relevant installation was able to generate electricity by 31
December 2018 (ELTS § 59 subsection 24).
Elering AS as the transmission network operator assessed the producer’s compliance with the
conditions specified in § 59 subsection 22 of the Electricity Market Act (including that the
producer has, at the latest on 31 December 2016, commenced work on the investment project
concerning that generating installation), in accordance with § 59 paragraph 23 of the Electricity
Market Act. In that analysis Elering AS also evaluated Aidu and Purtse – they were positively
assessed which means they met the conditions to receive support as ‘existing producers‘. The
assesment states that Purtse and Aidu had started work as of 2016, but they have not started
production yet due to various reasons. Among the evaluation there were several producers for
whom Elering decided they did not have started work as of 2016. Negative decisions were
challenged in court, and they were not taken into account as aid recipients in the budget
increase calculation. Only those who were positively evaluated were included in the budget
increase calculation. Estonia continues to be of the opinion that it is possible to start paying
Suur-Ameerika 1 / 10122 Tallinn / ESTONIA
Phone: +372 625 6342 / Fax: +372 631 3660 / E-mail:
[email protected] / http://www.mkm.ee
support when production starts and pay support up to 12 years after the end of the scheme, i.e.
until 2032 at the most.
2. We acknowledge that an error has occurred during the summation and the correct total amount
aid is EUR 1.37 billion (EUR 0,72 billion + EUR 0,650 billion). Please note that these are
estimated numbers and projected budget that may vary slightly in the future.
3. We understand that the notified increase in the budget should be assessed under the EEAG and
we are ready for close cooperation with the Commission.
With best regards,
(signed digitally)
Timo Tatar
Deputy Secretary General for
Energy and Mineral Resources
Kristo Kaasik
+372 6256465
[email protected]
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härra Kajak
Rahandusministeerium
[email protected] Meie 02.01.2023 nr 17-9/2022/2-1
Suur-Ameerika 1
10122, Tallinn
SA.102228 - Amendments to the budget of the
RES and CHP support scheme
Austatud härra Kajak
Edastame Majandus- ja Kommunikatsiooniministeeriumi vastused Euroopa Komisjoni
konkurentsi peadirektoraadi küsimustele (vt lisas) seoses riigiabi teatisega SA.102228, Support
scheme for electricity produced from renewable sources (renewable energy auctions; amendment
2022). Palume, et Rahandusministeerium edastaks Majandus-ja Kommunikatsiooniministeeriumi
vastused Euroopa Komisjonile Eesti esinduse EL juures kaudu.
Lugupidamisega
(allkirjastatud digitaalselt)
Timo Tatar
energeetika ja maavarade asekantsler
Suur-Ameerika 1 / 10122 Tallinn / 625 6342 /
[email protected] / www.mkm.ee
Registrikood 70003158
Kristo Kaasik
6256465
[email protected]
2 (2)