ABSTRACT
It is intended to use potential areas with renewable energy resources to reduce dependence on foreign resources of energy production in Turkey. In this respect, a number of incentives have been envisaged for investors to increase their investments in the energy sector. Renewable Energy Resources Certification and Support Mechanism (“RERCSM”) has been established as a mechanism that includes incentives based on “purchase guarantees” in order to increase investments related with renewable energy resources. In the context of the mentioned mechanism, the state guarantees certain prices for the electricity produced in the power plants using renewable resources. In addition to RERCSM, which will be explained in detail in this article, legal entities who have production licenses and those who produce renewable energy resources within the scope of unlicensed energy production will be able to benefit from this incentive which can be called as a certain period of purchase guarantee.
I. INTRODUCTION
The Republic of Turkey is a social state under, the article 2 of the Constitution which indicates basic qualifications of the Republic. The duties of the Administration determined by the nature of being a social state include activities of encouragement and support of these activities by private persons operating in some areas which are perceived as important for development arising from the planned development principle. As a matter of fact, the Constitution foresees the incentives and support for some private sector activities and areas which are accepted to have public interest1.
The incentives envisaged in energy investments play a major role in the Administration’s effort to encourage and support useful public activities. Indeed, the Republic of Turkey with a developing economy, the energy demand in the country also increases in parallel with these developments in economy. In order to contribute to the development of the economy, energy supply should meet energy demand. “Turkey has become dependent on imported energy resources at a level of approximately 70%”2 since Turkey’s natural resources are insufficient to meet the energy demand. Increase in current deficit resulting from energy imports “has made it inevitable that the new policies to be developed”3 in order to reduce imports and dependence. Within the context of the said policies, the Administration has offered a number of incentives to the investors in order to improve Turkish economy by using local and renewable energy resources, thus to ensure realization of this situation which is for the good of public interest.
Turkey has started to follow the policy of diversification of energy resources and using alternative energy resources in order to ensure security of supply while reducing especially dependence on oil and other countries countries4. The application of energy buying guarantee tariff (within the context of supporting renewable energy resources policy) is carried out with RERCSM, which is one of the most important incentive activities5. It is aimed to eliminate the dependence on foreign resources of energy by supporting the use of renewable energy resources in Turkey with RERCSM. Thus, the amount of electrical energy based on internal resources will be increased as much as possible by revisal of outsources in electrical energy production, specifically natural gas weighted production type. One of the government aims determined in this direction is to increase the amount of electricity production from renewable energy resources to an amount corresponding at least 30% of total electricity production6.
II. DEVELOPMENT OF THE RERCSM REGULATION
Renewable Energy Resources Certification and Support Mechanism Regulation (“RERCSM Regulation”) is enacted with the purpose of creating a legal basis for incentives used by investors and regulation as a mechanism to increase the usage of potential renewable energy resources in Turkey and to decrease dependency on external resources. Said subject is stated in the article 1 of RERCSM Regulation with the expression “with the purpose of encouraging the production of electricity based on renewable energy resources”7.
III. RERCSM
A. Definition of Renewable Energy Supporting Mechanism
RERCSM is defined under subclause 3 of article 3 of the RERCSM Regulation. According to this definition, RERCSM is a support mechanism which includes the principles and procedures regarding prices, periods, and payments that can be benefited by the legal entities who have production licenses while producing electricity based on renewable energy resources within the scope of RERCSM and the individuals who produce electricity from renewable energy resources within the scope of unlicensed electricity production via authorized supply companies in the area where such legal entities and individuals are located8.
RERCSM is a market-based purchasing mechanism operated by Energy Exchange Istanbul (“EXIST”) that has the duty and authority to implement day-ahead planning/ day-ahead market and market settlement operations and transactions, whose tasks and responsibilities are regulated under Electricity Market Law numbered 6446 published in the Official Gazette dated 30.03.2013 and numbered 28603 (“EML”) and in the related legislation. Under this mechanism, the State guarantees the operation of the system at certain prices with regard to the electricity produced in the power plants operating with renewable resources. This practice, which can be described as a guarantee to purchase, continues for ten (10) years according to article 10 of the RERCSM Regulation and unlicensed production facilities based on renewable resources are able to sell surplus productions with incentive added price during the mentioned period9.
B. The Beneficiaries of RERCSM and the Conditions of Benefit
It is firstly required to determine which renewable energy resources RERCSM includes before determining who is benefiting from this mechanism. In this context, subclause 1.b of article 3 of the RERCSM Regulation has narrowed the renewable energy resources to be determined within the scope of RERCSM as wind, solar power, geothermal, biomass, biomass obtained from gas (including waste gas), wave, discharge energy and electric energy production suitable for the establishment of a hydroelectric power generation plant with the pumped storage and channel with a tide or river type or reservoir area less than fifteen thousand square kilometers10. According to the RERCSM Regulation, licensed production facilities or unlicensed production facilities can benefit from RERCSM. Licensed production facilitates are involved in the mechanism directly by themselves. However, unlicensed production facilities could get involved in the mechanism through supplier companies that are in charge11.
1. Licensed Production Facilities
Legal entities that make production by usage of above mentioned limited energy resources in accordance with the article 8 of the RERCSM Regulation, and legal entities having production licenses for production facilities that are engaged, or to be engaged in the production, partly or wholly, until the date determined by the relevant Council of Ministers Decision. The abovementioned licensed legal entities can benefit from RERCSM for ten years beginning from the date mentioned below;
- The date of the first established power that included in the license enters into the operation, or
- The first date of first established power that included in the license participates in RERCSM in case where it participates to RERCSM without wholly entering into the operation.
The point that should be paid attention to is that the amendment made on 29 April 2016 has canceled the condition pointing that the date of entry of the production facilities into operation should be “from 18.05.2005 to 31.12.2015”, and the authority to determine this date is given to the Council of Ministers. In order to benefit from the RERCSM Regulation with the decision of the Council Ministers numbered 2013/5625 published in the Official Gazette dated 05.12.2013 and numbered 28842, the production license holders shall enter into operation from 01.01.2016 to 31.12.2020. In this case, legal entities which hold production licenses related with production facilities that came into partial or total operation until the date specified by the Council of Ministers, will be able to benefit from RERCSM12.
2. Unlicensed Production Facilities
According to the article 14 of the EML, production facilities based on renewable energy resources, which use the entire energy produced without transmitting it to the distribution or transmission system and whose production and consumption are at the same point of measurement, can operate without a license13. The facilities operating in this context, can benefit from RERCSM according to the RERCSM Regulation. According to the RERCSM subclause s of article 3 and subclause 2 of article 5 unlicensed electricity production facilities operating under the Regulation on Unlicensed Electricity Production in the Electricity Market published in the Official Gazette dated 02.10.2013 and numbered 28783 shall be included in RERCSM without any application14.
Subclause 2 of article 5 of the RERCSM Regulation, the authorized supply companies are natural participants of RERCSM during their license period. Real persons and legal entities operating in the field of unlicensed electricity are included in RERCSM for 10 years from the date they started to operate through these authorized supply companies in their region. Moreover, it is not necessary for these persons making unlicensed production to make any applications to be included in RERCSM for the next calendar year. It is not possible for such persons to go beyond the scope of RERCSM in accordance with subclause 2 of article 4 of the RERCSM Regulation.
C. PERIOD OF ENJOYMENT OF RERCSM
Certain periods are foreseen for power plants which can benefit from promised purchase guarantee incentive at a certain price within the scope of support mechanism in RERCSM Regulation. This issue is regulated under article 8 of the RERCSM Regulation:
“ARTICLE 8 – (1) Legal entities holding production licenses for production plants based on renewable energy resources hereunder, which have partially or fully started, or that will start, operation by the date determined through a Cabinet Decree may benefit from RERCSM for a period of ten years following;
a) The date on which the whole of the first established power indicated in the license starts operation,
b) The date on which it first participates in RERCSM in the case that it participates in RERCSM before its first established power indicated in the license starts operation.
(2) The production plants of legal entities applying under the first paragraph must have partially or fully started operation by the application date, and the application they file with the Republic of Turkey Energy Market for registry with RERCSM must have been accepted pursuant to the provisions of this Regulation.
(3) Real persons or legal entities, which their production amount of the electricity energy they produce from renewable energy resources covered by the exempt under LUY (Regulation on Unlicensed Electricity Production in Electricity Market – Elektrik Piyasasında Lisanssız Elektrik Üretimine İlişkin Yönetmelik), shall benefit from RERCSM through supply companies in charge in whose region they are established, for a period of ten years following the date on which the production plants fully or partially start operation.”
The date to be determined by the Decree of the Council of Ministers mentioned in subclause 1 of article 8 of the RERCSM Regulation was decided as 31 December 2020. In other words, power plants that are willing to take advantage of said incentive by being included to support mechanism, can make an application until 31 December 2020 and they will be able to benefit from RERCSM for 10 years from the date they are accepted. However, if the Council of Ministers does not postpone this period, it will not be possible for a new power plant to enter under this coverage and benefit from RERCSM after 2020.
Furthermore, as stated in subclause 3 of article 8 of the RERCSM Regulation, unlicensed production facilities will be able to benefit from RERCSM, as well, for 10 years through the authorized procurement companies.
Furthermore, in accordance with the article 6 of the Regulation on the Support of Domestic Parts Used in Electricity Generating Plants from Renewable Energy Resources published in the Official Gazette dated 24.06.2016 and numbered 29752, the additional incentive provided for users of domestic parts in production facilities will be granted for the first five years of ten-year RERCSM period15.
D. PROCEDURE FOR PARTICIPATION TO RERCSM
Some procedures and essential dates have been stipulated under RERCSM Regulation in order for real persons and legal entities to be under the scope of RERCSM. In accordance with article 5 of the RERCSM Regulation regarding the procedure for participation to the RERCSM, the legal entities with production licenses based on renewable energy resources have to make an application by 31st of October if they want to register with RERCSM on a license basis in the next calendar year. Authorized supply companies, that are obliged to purchase the surplus electricity transmitted to the system from real persons or legal entities establishing the production facility based on renewable energy resources in their own territory within the scope of unlicensed production, shall be registered to RERCSM throughout the license periods without the need for an application. According to the RERCSM Regulation, legal entities that own production license applying for benefits of RERCSM, have to notify the Energy Market Regulatory Authority in writing until 31st of October, if they are willing to renounce said application16.
According to article 7 of RERCSM Regulation, power plants that are included under RERCSM by approval of application made until October 31st under article 5, will be announced no later than November 30th. Period of RERCSM starts first day and ends at the last day of each calendar year17.
IV. RIGHTS AND OBLIGATIONS OF PARTIES UNDER THE RERCSM
A. Duties and Obligations of the Market Operator
According to subclause 12 of article 11 of the EML“EXIST starts to carry out market operation activities by obtaining the required market operation license from the Authority within six months of its establishment.” As stated in that Subclause, EXIST has assumed the role of the market operator. The rights and obligations of EXIST as market operator are stated in the Subclause 7 of the same article.
“(7) Rights and responsibilities of EXIST shall be as follows:
a) To conduct programs to establish new markets within organized wholesale electricity markets under the jurisdiction of EXIST in line with the market development and to present such programs to the Authority.
b) If deemed appropriate by the Ministry, to participate as a party in international electricity markets established or to be established in the future for the purpose to operate organized wholesale electricity markets under the jurisdiction of EXIST, to become a partner or member of international electricity market operators established for this purpose.
c) To determine market operation tariffs within the framework of the procedures and principles stipulated by the Authority and to present such tariffs to the Authority.”
As the market operator, the rights and obligations of EXIST have been regulated under the EML as mentioned above, and the said issue has been mentioned under article 22 of the RERCSM Regulation:
“Duties and Responsibilities of the Market Operator
ARTICLE 22 – (1) The Market Operator shall be obliged to carry out the work and procedures specified in this Regulation based on the principles of the impartiality and diligence.
(2) The Market Operator shall keep and monitor the suppliers’ and RERCSM participants’ rights and obligations under this Regulation under separate accounts.”
According to these articles EXIST, as the market operator, has rights and obligations such as sustaining activities impartially, trying to establish new markets in wholesale electricity markets while following the rights and obligations of the market participants under separate accounts and becoming a member of organizations of international electricity market operators if needed, by following international developments.
B. Duties and Obligations of Participants
The duties and obligations of participants of RERCSM are regulated under article 23 of the RERCSM Regulation. In accordance with the related article, licensed RERCSM participants, like other market operators, instead of being obliged to sell electricity to EXIST directly, will sell electricity in outside market and are obliged to pay the value (without taking into consideration of the real value of revenue) which is calculated by multiplying, the value calculated by multiplying the total amount of the electricity produced and the market clearance price (“MCP”) that is shaped in day-ahead market, and the tolerance coefficient, to EXIST.
In addition, the participants making licensed and unlicensed production, are obliged to comply with provisions of the legislation and act in accordance with the goodwill principle. They are also obliged to act according to the instructions of Turkey Electricity Transmission Corporation (“TETC”) and NLDC (National Load Dispatch Center) which is responsible center under TETC for real-time balancing of electricity supply – demand and system operation, if deemed necessary.
V. THE PAYMENT MECHANISM AND THE SITUATION THROUGH 2016 CHANGE WITHIN RERCSM REGULATION
Prior to the amendments on RERCSM Regulation, which was published in the Official Gazette on 29 April 2016 and entered into force on 1 May 2016, the support policy for renewable energy had a much different view. Before the said amendments, an isolated portfolio view consisting of the plants within the scope of RERCSM was mentioned, but after the amendments, the isolated portfolio system was removed from the market and they started to operate in the market like power plants not within RERCSM18.
Prior to the said amendment, the power plants covered by the support mechanism had the purchase guarantee by the price in US Dollar undertaken in the table of annex to the Law on the Utilization of Renewable Energy Resources for the Purpose of Generating Electricity, numbered 5346, published in the Official Gazette numbered 25819 and dated 18.05.2005 and they were selling electricity they produced to the electricity market operatör without restriction on the amount of produced electricity. In this system, it is seen that the power plants within the support mechanism can sell all the electricity to the market operator without having any market activity and regardless of the production quantities. The ability to sell the entire amount produced was one of the consequences of the fact that the plants in this context were in the form of an isolated portfolio19.
Furthermore, prior to the mentioned amendment, the power plants within the support mechanism did not have any balance responsibility. In other words, after predicting the amount of electricity they will produce and making a notification to the market operator or another institution in this matter, they did not have to assume the cost of imbalance due to the electricity production which its amount is more or less than their estimates within the scope of Electricity Market Balancing and Settlement Regulation published in the Official Gazette numbered 27200 and dated 14.04.2009. If they could not produce as much as they could, then this was a “cost” advantage for power plants within the framework of the support mechanism, compared to power plants that had to undertake this in the name of imbalance costs20.
The system described above with the purchase guarantee announced in 2010 has begun to become more attractive as the US Dollar has become increasingly appreciated against the Turkish Lira, although it has not been very popular in the first years of its announcement. In this aspect, while the capacity of power plants benefiting from the incentive prices was 5.000 MW in 2015, that amount reached to three times which was 15.000 MW in 2016. It is foreseen to make some amendments in the RERCSM Regulation due to the increase in the number of power plants included in the incentive since the cost of the incentive is reflected to the market and to the consumer indirectly from the supplier channel.
The amendments in the RERCSM Regulation which entered into force on 1 May 2016, have brought radical changes in the above-mentioned isolated portfolio appearance. First of all, power plants within the support mechanism sell electricity to outside market by dayahead market, intra-day market or bilateral agreements instead of selling the electricity directly to the market operator. However, after this sale, they will have to pay a price to the market operator under the name “RERCSM Revenue” in response to the income obtained from the sale. The point to be noted here is that the RERCSM price to be paid to the market operator is not the revenue obtained from the sale but the price that is generated by the multiplication of the amount of electricity sold and the MCP arising in the day ahead market. In other words, MCP will be the decisive component of the RERCSM revenue that will be paid whatever the outside market price of electricity that is sold by the power plant21.
After the power plants pay to the market operator which is being calculated under the name of RERCSM revenue mentioned above, this time they will be paid the renewable energy resources price (“RERP”) resulting from the multiplication of the amount of electric power they produced and the incentive price in US Dollar which was promised. However, it should be noted that if the MCP arising from the day-ahead market is higher than the price promised under the incentive, the power plants will have to pay the market operator.
As mentioned briefly above, one of the largest changes brought by the mentioned regulation amendment is that the plants within the scope of the support mechanism now have balance responsibility. In other words, the power plants in this scope will have to make production estimations and have to assume the cost of imbalance in these estimations according to the Electricity Market Balancing and Settlement Regulation. Especially it is difficult for power plants that make production from unpredictable resources, such as wind and sun, it is obvious that this situation can be a serious expenditure item.
One of the changes introduced with the regulation amendment in order to counter the risk is the tolerance coefficient. The RERP to be paid to the power plants within the support mechanism will be calculated by multiplying the MCP with this tolerance coefficient. Since the tolerance coefficient is determined as a number less than 1, an additional income for the power plants in this scope arises. If the said tolerance coefficient is produced from any renewable resource, it is currently determined as “0.98”. This means that a 2% margin of error is recognized for the power plants in this scope. However, the difference in the strength that can be estimated according to the type of resource used in production has led to criticism of recognizing a margin of error of 2% for all resource types. Taking this criticism into account, the Energy Market Regulatory Authority has prepared and publicized a draft on adopting different tolerance coefficients according to the types of resources used in electricity generation, but this draft has not yet come into force.
At this point, different possibilities will arise when calculating the imbalance costs of power plants. If the power plant produces less than the quantities estimated and the System Marginal Price (“SMP”) in the balancing market is less than or equal to the MCP in the day ahead market, the imbalance cost will not occur but if the SMP is larger than the MCP, an imbalance cost will emerge. If the plants in this scope produce more than the estimated amount and SMP is greater than or equal to the MCP, the imbalance cost will not occur but if the SMP is smaller than the MCP, an imbalance cost will arise.
VI. ADVANTAGES AND DISADVANTAGES OF RENEWABLE ENERGY RESOURCES SUPPORTING MECHANISM
The system has several disadvantages while providing many advantages to the power plants that have the right to be included in the scope of RERCSM and to benefit from this support mechanism.
The most significant advantage is that the electricity generated by the plants in this context is provided with a 10-year purchase guarantee at a previously fixed price set in US Dollar. Given this fixed price purchase guarantee, it can be seen that power plants in this scope can have relatively more foreseeable financial conditions with these computable income items than the power plants that are not in this scope. However, at this point, it should be kept in mind that the power plants covered by the support mechanism will bear the imbalance costs with the amendment made on 29 April 2016.
Another advantage is that there are some incentives provided to the renewable energy power plants in accordance with the Regulation on the Support of Domestic Parts Used in Electricity Generating Plants from Renewable Energy Resources. According to this regulation, supplementary financial incentives are provided in addition to purchase guarantee incentive determined at a fixed price for the producers who use indigenous equipment in the facility, and a purchase guarantee can be provided at a higher price. The duration of this additional incentive has been determined as 5 years from the date of incentive22.
It should also be noted that licensed production facilities are included in the RERCSM together with unlicensed production facilities, and the production surplus electricity produced in these facilities is also guaranteed. These unlicensed production facilities, which are relatively small in size, will be able to sell their surplus production electricity to the authorized supply companies. This point is expressed in subclause 2 of article 5 of the RERCSM Regulation as follows:
“In their own regions, supply companies in charge are obliged to purchase the surplus electric energy supplied to the system by real persons or legal entities establishing production plants based on renewable energy resources under the scope of unlicensed production. During their license terms, the supply companies in charge shall be registered with RERCSM without the need for an application.”23
Lastly, since the purchase guarantee is provided in the US Dollar, it is another advantage for power plants in this scope not to have the risk of exchange rate.
Among the disadvantages the system has, the most remarkable one is that, in case the MCP, which emerged in the day ahead market, is higher than the purchase guarantee provided under the incentive, the power plants may have to pay the market operator instead of being paid by market operators.
Another issue that arises in this context is that the deadline to apply for 10 years of the purchase guarantee incentive provided at a certain price is 202024. It is important to note that the power plants applied before 2020 to be included in the scope of RERCSM will be able to benefit from this incentive for 10 years from the date of coverage, but after 2020 a new plant will not be included within the scope of this incentive. Therefore, there is an uncertainty about the situation after 2020.
Finally, it should be noted that, for the licensed producers, the power plant which is chosen to be included for the year within RERCSM according to annual applications, has to stay within the RERCSM mechanism for that year. It will not be possible to go beyond the scope of this coverage at any date until the end of that year.
VII. CONCLUSION
As a result, Turkey aims to minimize external dependence about energy in line with National Energy and Mines policy. According to this policy, Turkey is trying to ensure that security of energy supply, domestic energy production and foreseeable market conditions are provided. RERCSM has been put into operation in order to reach the mentioned aims in terms of electricity energy. Within the scope of this mechanism, power plants using renewable energy resources are provided with incentives for purchase for 10 years on a fixed price to increase interest of potential investors on this issue. Accordingly, it is aimed to increase amount of electricity production from renewable energy resources to an amount corresponding at least 30 percent of total electricity production.
When the data in recent years are examined “During the last 13 years, the installed power of our country has reached to 73 GW by increasing 2.3 times. The renewable energy projects constitute approximately half of the relevant investments. The amount of investment by private sector in the electricity production sector reached to $ 70 billion (Renewable Share: $ 36 billion). Financial amount provided by banks to the sector reached to the $ 50 billion (Renewable Share: $ 29 billion). The share of natural gas in electricity production has decreased from 50% to 38% with the contribution of renewable energy projects that stepped in especially in the last 5 years along with the solution of supply security problem through investments. Through RERCSM, it is aimed to prevent imports approximately in the amount of $ 25 billion by 2030. Owing to the power plants built within the scope of RERCSM, it is aimed to reduce natural gas bill to 50 billion dollar by 2030. Without renewable energy plants, it is estimated that lowefficiency natural gas-based productions would be pricedetermining factors in more hours. It is estimated that contribution in the amount of $ 5 billion will be made by investors by 2030 within the scope of government tenders.”25
It should be noted that while the total installed capacity under the support mechanism in 2015 was 5,000 MW, it increased by 3 times and reached to 15,000 MW in 2016. It should not be forgotten that by appreciation of US Dollar against the Turkish Lira, the said number will rise further. In line with these developments, with the amendment of RERCSM Regulation made in April 2016, the power plants under the support mechanism must also bear the imbalance costs. It should be kept in mind that the planning of changing the tolerance coefficient in order to counterbalance these imbalance costs in a very limited time, may have a serious effect in shaping the future of the industry when considering this change’s serious effects on the cost items of the power plants under support mechanism.
BIBLIOGRAPHY
Metin Günday, “İdare Hukuku” (“Administrative Law”), İmaj Yayıncılık, Ankara 2013.
Erdal Tanas Karagöl/İsmail Kavaz/Salihe Kaya/Büşra Zeynep Özdemir, “Türkiye’nin Milli Enerji ve Maden Politikası” (“National Energy and Mining Policy of Turkey”), SETA Analiz, June 2017, Issue: 203.
Barlas Balcıoğlu/Şahin Ardıyok, “Yenilenebilir Enerji Kaynaklarının Belgelendirilmesi ve Desteklenmesine İlişkin (YEKDEM) Yönetmelikte Değişiklik Yapılmasına İlişkin Yönetmelik” (“Regulation on the Amendment of the Renewable Energy Resources Certification and Support Mechanism Regulation”) (Last Access: 13.02.2018), https://www.baseak.com/tr/insights/alerts/2016/may/2/enerjiregulasyonu?Archive=Fase&ParentItemID=440ymEOm1qNzuDAToZ1rUlHcgNNN0csAQG2FaHooIOVWFCm9GbPdkA
YEKDEM Çalıştay Raporu (Workshop Report of RERCSM), (Last Access: 13.02.2018), http://www.tureb.com.tr/files/tureb_sayfa/duyurular/yekdem_calistay_raporu_17.08.2016.pdf
FOOTNOTE
1 Metin Günday. "Administrative Law", İmaj Yayıncılık, Ankara 2013, p.20-21.
2 Erdal Tanas Karagöl/İsmail Kavaz/Salihe Kaya/Büşra Zeynep Özdemir, "Turkey's National Energy and Mining Policy", SETA Analiz, Haziran 2017, numbered 203, p.8-9.
3 Karagöl/Kavaz/Kaya/Özdemir, p.8-9.
4 Karagöl/Kavaz/Kaya/Özdemir, p.26-28: p.11-13.
5 The Outlook of Turkish Energy Market | Achievements, General Outlook and Opportunities (Last Access: 13.02.2018) http://dektmk.org.tr/upresimler/turkiye-enerji-plyasasinin-gorunumu.pdf
6 Karagöl/Kavaz/Kaya/Özdemir, s. 10.
7 Renewable Energy Resources Certification and Support Mechanism Regulation, article 1 ("RERCSM Regulation") published in the Official Gazette dated 01.10.2013, numbered 28782.
8 RERCSM Regulation, article 3.
9 RERCSM Regulation, article 10.
10 RERCSM Regulation, article 3.
11 RERCSM Regulation, article 8.
12 Annex of the Decree dated 18.11.2013, numbered 2013/5625.
13 EML, article 14.
14 RERCSM Regulation, article 3 and 5.
15 Article 6 of the Regulation on the Support of Domestic Parts Used in Electricity Generating Plants from Renewable Energy Resources.
16 RERCSM Regulation, article 5.
17 RERCSM Regulation, article 7.
18 Barlas Balcıoğlu Şahin Ardıyok, "Regulation on the Amendment of the Renewable Energy Resources Certification and Support Mechanism Regulation" (Last Access: 13.02.2018), https://www.baseak.com/tr/insights/alerts/2016/may/2/enerji-regulasyonu?Archive-False&Parentiteml D-440ymEOm1qNzuDAToZ1rUIHcgNNNOcsAQG2FaHoo IOVWFCm9GbPdkA
19 Balcıoğlu/Ardıyok.
20 Balcıoğlu/Ardıyok.
21 Balcıoğlu/Ardıyok.
22 Regulation on the Support of Domestic Parts Used in Electricity Generating Plants from Renewable Energy Resources, article 6.
23 RERCSM Regulation, article 5.
24 Addendum to the Decree numbered 2013/5625 and dated 18.11.2013, article 5.
25 RERCSM Workshop Report, (Last Access: 13.02.2018), http://www.tureb.com tr/files/tureb_sayfa/duyurular/yekdem_calistay raporu_17.08.2016.pdf
