Tag: 2024

Summary

In relation to climate change, as a society, we act at a slow pace. The effects of climate change have become a daily reality. Guidelines, directives, agreements from various global and European organisations have been in place for decades. More and more often the question arises: what we can do ourselves, locally, as a closer community, as a neighbourhood, to contribute to actions that could slow down the devastating effects of climate change.

This text explores the possibility of associating citizens, the local public sector and entrepreneurship into citizen energy communities (ECG) in order to contribute to the achievement of environmental, social and governance (ESG) objectives as soon as possible. The question arises as to how the ECG could contribute to achieving the ESG objectives? It seems that it is precisely legal entities, current or future ESG reporting entities, that could achieve the goals in the energy community with their workers.

1. INTRODUCTION

There are numerous examples of inadequate human behaviour in history, behaviour often referred to as “behaviour to the benefit of one’s own harm”. There are various psychological, sociological and economic reasons for this, but often the incentives to change behavior come too late, so the consequences are more tangible and ubiquitous. A recent example is “climate change”, where decades have elapsed in debates as to whether there are or are the fruit of fiction, erroneous scientific assumptions, and whether what should be done or continue to be done in this regard as before. Regardless of the causes, we are witnessing above-average summer temperatures, short-term weather disasters with devastating effects, more frequent occurrences of floods or droughts, etc. People are becoming aware of such changes because they are part of their daily lives and, therefore, they are asking their governments for immediate actions and measures to make it easier to live in ‘new normal’ circumstances.

As a society, we act in slow motion. The measures that are now being implemented as a matter of urgency have been used as definitions in various UN and EU directives and agreements for decades. SDG program the UN 2030 Agenda and EU regulatory frameworks such as the The European Green Deal detail the necessary measures and ensure the financing of the transition towards sustainable investment and development to ensure that by 2050:

• No net greenhouse gas emissions;
• Establish economic growth that is not dependent on the use of carbon-footprint resources; and
• No person or region will be left behind in this transition.

Figure 1: SDG Objectives UN

Source: United Nations.

But as it usually happens, the key motivator for more noticeable changes will be a material benefit like Larry Fink, CEO Black Rock (otherwise an organisation that manages financial assets worth more than $10 trillion), ’We are not dealing with energy efficiency because we are "green" – but because it is profitable’ One of the recommended mechanisms for achieving the stated goals is the ESG regulation of the European Union. ESG regulations are designed to foster transparency, sustainability and ethical business practices. They aim to ensure that companies assess and disclose environmental, social and governance (ESG) factors that influence climate-related risks, sustainable business practices and compliance with regulatory standards, while not being a burden but an opportunity to improve their business.

2. ESG

What is ESG and what impact it has on all of us. ESG is an abbreviation of English words Environment, Society, Governance  It is based on the concepts of sustainable development, that is, establishing a balance between economic, social and environmental requirements in order to meet the needs of the present without jeopardizing (limiting) the possibilities of future generations. Equilibrium is not trivial because a whole range of criteria should be harmonized, which are usually presented as 3P (People, Planet, Profit) illustrated in Figure 2:

1. People – these indicators include social indicators such as community maturity, education, equality, social resources, health, quality of life, etc.;
2. Planet – includes indicators on natural resources, water and air quality, energy production and rational consumption, space management and uses of available land;
3. Profit – includes indicators covering economic activities, business profitability, economic development, investments, etc.

So, it is a complex optimization because it is necessary to find answers to a number of questions - how to ensure the development and well-being of people without destroying the environment and biodiversity, is further economic development at all feasible on the principles of exploitation of natural resources and unlimited consumption, or are there rational alternatives such as more intensive use of the principles of the circular economy? Finally, can profit generated by economic activities be distributed more fairly and enable more transparent reinvestment in sustainable development, especially in poorer environments. 

Figure 2: The concept of sustainable development and key issues

Source: Authors.

As pointed out in the introduction, the existing problems are global. No community can be isolated or secure. Therefore, joint action in optimization processes is needed. Without balance and mutual respect, progress will not be possible (without profit, there is no sustainable development, but it cannot be at the expense of people and the environment).

2.1. Meaning of ESG

The application of the ESG principles in companies can bring tangible benefits, so they should not be seen as an administrative burden, but as an opportunity for a transition with added value. It is possible to achieve numerous direct savings (lower consumption of raw materials, energy products, water, waste disposal, etc.), provide more favorable sources of financing or lower taxes due to the application of the ESG principle, but also indirect benefits such as a better reputation of the company or a market brand. The importance and great availability of financial instruments of the European Union for the purpose of company transformation, development of new products or services based on sustainability should not be diminished, which is an opportunity to conquer new markets. 

In the context of the Republic of Croatia, there is a high degree of compatibility of ESG goals with strategic goals defined by the National Development Strategy (NRS 2030), which is important because it has an impact on concrete development plans and the availability of funding sources such as NRRP 2021-2026 or ESIF 2021-2027. Most tenders have introduced ‘green’ scoring that assesses, for example, energy efficiency, the use of energy from renewable sources or the reduction of CO2 emissions, but also the establishment of appropriate policies, processes and systems to control environmental, social and governance challenges, with a focus on systemic approaches.

The implementation of ESG principles is different for individual organizations, but in most cases it is necessary:

1. Internal analysis of the organization's compliance with applicable ESG regulations;
2. Identification of strategic risks for the organization if ESG principles are not met;
3. Defining organizational goals for ESG application and transformational roadmap;
4. Application of ESG principles in the organization's business processes;
5. Evaluation and certification and
6. Reporting and promotion of results.

Different scientific research[1] prove a direct link between the application of the ESG principles and better business and financial results of the organizations that implemented them (better return on investment, lower capital prices, better perception of the organization by consumers and potential investors). Therefore, it can be concluded that investing in the implementation of ESG is not a cost and administrative burden, but a great opportunity to invest in the future of the organization, the development of new products and services, and ultimately its increase in profitability and benefits for employees, owners or shareholders.

2.2. Reporting on ESG measures

With more than 2,400 ESG regulations worldwide, it is clear that sustainability reporting is becoming a vital part of corporate compliance. In particular, the European Union has been at the forefront of these initiatives by introducing comprehensive ESG regulations that have far-reaching implications for companies operating under its jurisdiction. Understanding and complying with these regulations means not only complying with EU and national regulations, but also an opportunity to improve business, set standards for corporate responsibility and align with investors' and consumers' expectations. In general, for the understanding of ESG measures within the European Union, two regulations adopted in 2024, which regulate this area in detail, are crucial.

Corporate Sustainability Reporting Regulation

Corporate Sustainability Reporting Regulation[2] (Corporate Sustainability Reporting Directive – CSRD) marks significant progress in European Union legislative action, which aims to improve and broaden the scope of ESG reporting requirements for entities operating within the EU. This regulation is essential to foster a culture of transparency. It focuses on assessing the impact of all business activities on people and the environment. It aims to standardise and simplify ESG reporting across different sectors, ensuring that companies adopt sustainable business practices and address climate-related financial risks. The CSRD mandates comprehensive disclosure of ESG factors, such as data on carbon emissions, waste management, diversity and inclusion, workers’ rights and governance factors. By facilitating access to essential ESG data, the directive supports financial market participants and clients in making informed decisions, thereby integrating sustainability considerations into business strategies.

For those who are familiar with the Non-Financial Reporting Directive (NFRD), the CSRD is a revision and improvement of the existing rules on non-financial reporting. These “original” regulations only require large companies to publish their ESG results and do not go into the depth and detail required by the new reporting directives. The CSRD will extend the reach to a wider set of large companies, as well as listed SMEs and eventually non-EU companies and subsidiaries operating in the EU. Requirements will enter into force in a gradual timeframe depending on the classification of the company:

• 30 June 2023: The European Commission adopts a first set of reporting standards;
• January 2024: large listed companies (those with more than 500 employees) will have to monitor and collect ESG data under the CSRD (reporting year 2025);
• January 2025: each company that meets two of the following three criteria must monitor and collect ESG data under the CSRD: 250 workers, EUR 50 million in revenue or EUR 25 million on the balance sheet (reporting year 2026);
• January 2026: the date of entry into force of a law that will require most small and medium-sized enterprises (10-250 workers) to start reporting (reporting year 2027);
• January 2028: the effective date of compliance with the CSRD by third country companies (European subsidiaries of non-European companies with a turnover above EUR 150 million).

Sustainable Finance Disclosures Regulation (SFDR)

Regulation on disclosure of information on sustainable finance[3] (The Sustainable Finance Disclosure Regulation – SDFR) a European Union regulation is mandatory requiring financial market participants (FMPs) and financial advisors to disclose information on ESG risks and opportunities of their investment products. The most significant aspect of this legislation is that fund managers have to report quarterly detailed, quantitative data on behalf of their portfolio companies. The SFDR has three main objectives:

1. Elimination of greenwashing;
2. Liability for sustainability claims made by FMPs;
3. Improving the transparency of sustainable investment products in the European financial sector.

To meet these objectives, the SFDR will require two levels of disclosure in relation to the integration of sustainability risks and opportunities into their investment decision-making process. Level 1 requires FMPs to disclose whether and how sustainability risks are taken into account in their investment decision-making process. FMPs must also explain the likely effects of sustainability risks on the returns of the financial products they offer. This publication became mandatory in March 2021. Level 2 requires FMPs to disclose the principal adverse impacts of their investments on sustainability factors. This level of disclosure requires adherence to the regulatory technical standards (RTS) on ESG and became mandatory in January 2023. In June 2023, adherence to the Adverse Effects Principle (PAI) under the RTS also became mandatory. The PAI disclosures shall include details on sustainability risks such as greenhouse gas emissions, water consumption and impact on human rights. A detailed analysis of these regulations goes beyond this text, so we will focus on practical examples of how to achieve ESG goals, and how citizen energy communities can help in this context.

From all the above, it can be concluded that cooperation between companies and their employees within citizen energy communities can represent achievable possibilities of multiple benefits: workers in own production of renewable energy and achieving savings in self-consumption, and companies supplying renewable energy at lower and stable prices and achieving ESG targets.

3. ENERGY COMMUNITY OF CITIZENS

Citizen Energy Communities (ECECs) are business formations in which citizens, public authorities and entrepreneurs come together to benefit from the production, sharing and consumption of self-generated renewable energy.

3.1. Basic characteristics of citizen energy communities

They have been introduced into the legal system of the European Union by Directive (EU) 2019/944 of the European Parliament and of the Council since 5 June 2019. Introduced into the legal system of the Republic of Croatia through (partial) transposition of the Directive into the Electricity Market Act[4] (ZTEE) October 22, 2021.

The establishment, organization and operation of the ECG in the Republic of Croatia is determined by several regulations, the most important of which are: ZTEE, Law on Renewable Energy Sources and High-Efficiency Cogeneration (ZOIE)[5], Ordinance on licenses for performing energy activities and keeping a register of issued and withdrawn licenses for performing energy activities (Ordinance on licenses)[6], Ordinance on general conditions for the use of the network and the supply of electricity (Ordinance on general conditions)[7], Decision on the amount of fees for performing activities related to the regulation of energy activities (Decision on fees)[8], Law on Associations[9] / Cooperatives Act[10] and the Act on Financial Operations and Accounting of Non-Profit Organizations[11].

Entities affiliated to the ECG are allowed to carry out several activities[12]:

• Production of (renewable) electricity;
• Electricity supply;
• Power management;
• Aggregation;
• Energy storage;
• Energy efficiency;
• Charging of electric vehicles;
• Other energy services in accordance with the rules governing individual electricity markets.

It is important to point out here that all these activities may be carried out exclusively for members of the ECG. The most important and most mentioned service is the sharing of generated energy. What does that mean, in nature? In technical terms, it is not a question of one member directing its excess generated energy to another member. Excess generated and currently unspent energy of the member who produces energy with his plant is directed to the power grid. Another member who currently has a higher consumption than the production (or does not produce energy at all) settles its needs from the electricity system network. Energy sharing is “virtual” and takes place on an accrual basis through so-called “sharing keys”. At the end of each billing period, the distribution system operator shall distribute the excess generated energy among the ECG members using sharing keys. This calculation will be visible on the account of each ECG member, based on information on the use of energy from the grid and on the use of energy from ECG members distributed through the sharing keys.

Adjusting the ECG energy sharing keys with members of different characteristics (dynamics of production and consumption, purchase price of energy from the grid, capacity to take over surplus energy produced within the ECG, etc.) is particularly important because the optimal operation of the ECG will depend on their values. Optimal operation is understood here as an equal distribution of benefits and costs among ECG members.

3.2. Establishment and operation of EZG

The energy community of citizens is a business formation. According to the Directive, its legal form may be “... an association, a cooperative, a partnership, a non-profit organisation or a small or medium-sized enterprise, as long as such an entity may, acting in its own name, exercise rights and be subject to obligations;[13]However, as interpreted by the Ministry of the Economy (MINGOR)[14] the legal form is exclusively an association. Assuming that this interpretation is in the spirit of EU regulations and ZTEE, EZG is established in accordance with the Associations Act. The beginning of the establishment of the ECG is marked by the gathering of a group of citizens, public authorities and companies (or a combination) around the intention of establishing the ECG. The next step is to convene the founding assembly of the association where the founding members are present. The inaugural meeting shall adopt:

• Decision on the establishment of the association;
• Decision on the name of the association;
• Decision on the adoption of the statutes of the association;
• Decision on the election of representatives to the governing bodies of the association;
• Decision on the appointment of persons authorised to represent;
• The decision on the choice of the liquidator and
• Decision to initiate the procedure for entry in the Register of Associations.

In addition to these decisions, it is necessary to prepare a list of the founders of the association, an invitation to the founding assembly and minutes. All documents should be certified by the president of the association.

The statute of the association should include the objectives, areas of activity and activities of the association. The specificity of the energy community association are economic activities related to the provision of Article 26.11. ZTEE. Furthermore, the statute should cover the treatment of membership in the association, the resolution of disputes and conflicts of interest, the bodies of the association (e.g. assembly, president and deputy president, secretary, etc.), the manner of acquiring and disposing of property and the dissolution of the association. The statutes shall be signed by the president of the association and certified by the competent county administrative department for general administration. If the establishment of the association is carried out legally, the administrative department will issue a decision on the registration of the association in the Register of Associations of the Republic of Croatia. The expected period for these activities is between 1 and 3 months.

The establishment and registration of the association completed the first administrative step towards the ultimate goal of a functional energy community. The second step is obtaining a permit to perform the energy activity of organizing an energy community of citizens. This permit is issued by the Croatian Energy Regulatory Agency – HERA. This is a much more complex process than the founding of the association. The provisions of point 8 The Licensing Rules set out the documents and evidence that the Energy Community must collect and submit to HERA in order to obtain a licence to carry out energy activities:

• Application form for the issuance of a licence for the performance of energy activities;
• Extract from the Register of Associations of the Republic of Croatia;
• Constitutive act;
• A list of all members in the citizen energy community, showing for each shareholder or member data on (i) the type of legal or natural person, (ii) the place of residence, (iii) the percentage share in membership and actual control, (iv) the actual percentage share in membership or actual control of the citizen energy community;
• Statement by the responsible person that medium-sized and large enterprises do not have effective control over members of the citizen energy community;
• Extract from the relevant register by which the applicant proves that the citizen energy community operates on the basis of the law governing the financial operations and accounting of non-profit organisations;
• Evidence of technical qualification: (i) proof of ownership or of the right to use the premises, (ii) a description of the energy sharing information system, (iii) current contracts with other legal entities that have an impact on the technical qualification of the applicant, (iv) a three-year development and investment plan, (iv) conditions for participation in a citizen energy community;
• Evidence of professional competence: (i) an organisational chart, (ii) a list of employees, (iii) current contracts with other legal entities that have an impact on professional competence;
• Evidence of financial qualification: BON-1 and BON-2;
• Declaration of no criminal record.

Thus, a whole series of documents in which the content can be interpreted differently, so the help of those who have passed the process of obtaining a permit for energy activity will come in handy. The expected period for the implementation of this activity is between 4 and 7 months.

Once an ECG licence has been obtained, the third and final step to operational operation remains — practical energy sharing within the ECG. For this step, according to the statements of individuals from HEP ODS, we will have to wait until the end of 2024. Indeed, as pointed out above, energy sharing is a billing process and is managed by the distribution system operator. On the basis of the energy delivered to the grid by all energy generating members, the billing of off-takes and inputs in the billing period and the defined keys handed over to the distribution system operator, the operator shall draw up a shared energy matrix for each billing period for each member. However, before directly sharing energy within the ECG, it is necessary to improve measurement systems, collect data on the production and consumption of energy of members and calculate the best value of sharing keys in order for the association to operate in accordance with the regulations governing its business. At least 6 months should be set aside for these activities.

The citizen energy community is not a passive business entity. With the commencement of the activities for which it was established, various administrative and technical activities should be carried out on a continuous basis in order for it to become and remain a viable business entity. These are activities related to the fact that the legal form of this formation of associations and activities of performing energy activities. In this regard, account should be taken of the members' records, the inclusion of new members and the exclusion of existing members. It is necessary periodically to convene, prepare and conduct assemblies of society. It is necessary to create and administer a website in order to inform members and the general public about the situation in the community in a timely manner. Every transaction should be business-recorded, so it is necessary to take care of timely and legal keeping of business books. In this regard, the activities of reporting and submitting periodic financial reports are also related. Account should also be taken of the needs of existing and new members in terms of investment in technical capacities, for example the installation of renewable energy generation and storage facilities such as photovoltaic plants, vertical wind power plants, batteries, etc. Recently, there has been a growing public debate about the maintenance of facilities, so the professional and timely organisation of such activities will be of benefit to members. On the other hand, in technical terms, it is necessary to continuously monitor energy sharing flows and enable community members to report on energy sharing and payments at the end of each billing period. As these are numerous combinations, it will be important to organise a specific and situation-specific payment, i.e. the execution of shared energy payment transactions. These are specific computer programs for which continuous and reliable operation should be ensured. Finally, the markets in which the ECG participates are constantly changing, both from a technical and technological point of view and from a legislative and administrative point of view, and it is therefore necessary to inform members of those possibilities. Monitoring the development of these activities is of great importance because new technologies can contribute to aligning the consumption profile with the dynamics of energy production. The implementation of various artificial intelligence technologies in the business processes of EZG can contribute to the efficiency of work and the achievement of the purpose of the existence of an energy community.

4. EXAMPLES OF GOOD PRACTICES

In order to explore the relationship between citizen energy communities and environmental, social and governance (ESG) criteria, several factors need to be taken into account. Energy communities are groups of people or organisations that come together to produce, consume and manage energy locally, often focusing on renewable sources. They aim to increase energy efficiency, reduce greenhouse gas emissions and provide economic (and financial) benefits to the community. The ESG objectives are compatible with the objectives of joining the ECG.

Experience confirms this, as energy communities often promote renewable energy sources (sun, wind, etc.) that directly contribute to reducing the carbon footprint. Promoting local energy production can reduce dependence on fossil fuels by aligning with environmental sustainability objectives in ESG criteria. Energy communities also create new local jobs, contribute to the availability of cheaper energy and contribute to increasing the resilience of local populations to energy or financial stress. The ECG contributes to energy equality by giving communities control over their energy sources by aligning with the social aspect of the ESG. The third component of governance is also important – energy communities often act on the principles of democratic governance and community participation. This increases transparency, accountability and inclusive decision-making of ECG members by aligning with the ESG governance criteria.

Information on individual cases where citizen energy communities have been successful can provide insights on how to meet the ESG criteria. Examples may include community solar projects, cooperative-owned wind farms, etc. Unfortunately, since there are no operational ECGs in the Republic of Croatia yet, it is necessary to inform oneself on examples from the world.

Larsmo Vindkraft Oy, Finland

Larsmo Vindkraft Oy  set up by private individuals in the Larsmo area near Kokkola, Finland. The community's goal was to fund the exploration of wind potential and eventually build a wind farm in the region. This initiative was launched by a local resident interested in sustainability and renewable energy. The project has successfully promoted the local production of renewable energy, reduced CO2 emissions and encouraged the involvement of citizens.

Cooperative Lohtaja, Finland

In the early 2000s, the Lohtaja cooperative emerged as a solution for outdated heating systems on fuel oil in Finnish rural rural communities. The cooperative focused on using wood chips as a heating source, which was more cost-effective and environmentally friendly compared to oil. This initiative not only reduced heating costs, but also promoted the use of local renewable sources, aligning with environmental and social ESG criteria by improving energy security and supporting local economies.

Karise Permatopia, Denmark

Karise Permatopia is an eco-village in Denmark that focuses on sustainability in all aspects of its business. A community of 90 houses in a row is energy self-sufficient. It uses a geothermal heating system that is powered by locally produced renewable energy. It also owns and operates a wind turbine that contributes to the energy needs of the community and feeds charging stations for electric cars. This project is a good example of a holistic approach to sustainability that covers environmental, social and governance aspects.

Dindgen, Germany

In Dingden, Hamminkelna County (27,000 inhabitants), a civic volunteer initiative established to support the operation of a public outdoor swimming pool, is now using public rooftops to produce photovoltaic energy. The proceeds from the sale of electricity allow the company to financially support the municipality to ensure the maintenance of the pool. Dingden Outdoor Swimming Pools Society (DingdenFreibad-Verein Dingden e.V.) has 3,100 members (as of March 2019) and was established in 2000.

These examples illustrate how small energy communities and citizen initiatives successfully implement ESG-compliant projects, demonstrating environmental sustainability, social benefits and good governance practices.

In addition to examples of forming citizen energy communities in cooperation with cities and public authorities, experiences of active involvement of companies are also interesting, for which achieving ESG goals is particularly important. Achieving these goals, practice shows, is easier in cooperation with the local community, more specifically, by establishing the ECG. An example is the implementation of a programme in which a company assists its workers in the operations of supplying and installing photovoltaic installations on the roofs of their homes and then participates in joint energy sharing. It follows from practice that such initiatives and cooperation are a good way to achieve environmental, social and governance objectives. Here are a few arguments for this assumption:

Environmental impact

By encouraging the installation of photovoltaic installations, companies promote the use of renewable energy, which directly reduces the carbon footprint of workers in their homes and companies. This initiative also helps to increase the overall use of renewable energy in the community by contributing to environmental sustainability goals. Finally, companies can make efficient use of surplus energy, reducing dependence on non-renewable energy sources and promoting a more sustainable energy ecosystem.

Social impact

Supporting workers in the supply and installation of photovoltaic plants can reduce energy costs in their households, contributing to their financial well-being as well as to the satisfaction of work in the company. This initiative can serve as a model for other businesses and communities by demonstrating the benefits of using renewable energy and encouraging wider deployment. By implementing such programs, companies increase awareness and knowledge of renewable energy among their workers, but also across the community.

Impact of management

Sharing surplus energy with workers at competitive prices demonstrates a commitment to fair and ethical business practices. Such initiatives show a tendency to involve workers and other stakeholders by fostering a sense of community and participation in achieving a common purpose. Companies can highlight this programme in their ESG reports, demonstrating their commitment to sustainability and responsible management practices.

From the above it is worth highlighting a few guidelines. Firstly, it is important to ensure that the process of sharing excess energy is transparent and fair, with adequate prices that provide equal benefits and costs to all stakeholders. Secondly, activities should always be aligned with local public policies and regulations to avoid risks arising from non-compliance. Thirdly, it is important to provide support and training to workers on how to install and maintain photovoltaic plants, all in order to achieve optimal operation of the initiative. A good example in identifying such initiatives can be Google. It has developed a program for the establishment of renewable energy production systems through which it supports workers in the adoption of renewable energy solutions, including assistance in the installation of photovoltaic plants. Programmes based on crowdfunding principles that help workers and residents to establish energy communities at affordable costs and with the support of local authorities and/or companies could also play a significant role in the procurement of facilities.

In conclusion, the implementation of various programs to support and assist workers in the establishment of photovoltaic plants within citizen energy communities is in accordance with ESG principles and objectives. They promote environmental sustainability and support social well-being. Such initiatives can position companies as leaders in corporate responsibility and sustainability.

5. CONCLUSIONS

International practice, features of ESG and EZG and trends guided by domestic and EU regulations in the field of climate and environment, increasingly direct the attention of public and private management to the possibility of achieving ESG goals by cooperating with their workers in the form of citizen energy communities. Such cooperation can have a positive impact on the satisfaction and greater involvement of workers in achieving the strategic objectives of the company, but also the benefits of the company from supplying renewable energy at reduced and stable prices. Consequently, such cooperation can have a positive impact on ESG reports and reduce business risks.

---

[1] https://www.sciencedirect.com/science/article/pii/S221484502200103X

[2] https://eur-lex.europa.eu/legal-content/HR/TXT/HTML/?uri=CELEX:32022L2464

[3] https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R2088&from=EN

[4] NN 111/21, 83/23

[5] NN 138/21, 83/23

[6] NN 44/22

[7] NN 100/22

[8] NN 38/22

[9] NN 74/14, 70/17, 98/19, 151/22

[10] NN 34/11, 125/13, 76/14, 114/18, 98/19

[11] NN 121/14, 114/22

[12] ZTEE Art. 26.11.

[13] Point 44 of the introductory starting points.

[14] Report on the conducted consultation with the interested public on the Proposal of the Law on Amendments to the Law on the Electricity Market with the Final Proposal of the Law (PZ 516).

Views: 50