REGULATORY OPINIONS AND RECOMMENDATIONS

Opinion and Evaluation on the Draft in General

Offer

Draft Article

Opinion and Evaluation

Offer

1- ARTICLE 5

Joke (2)

Clause d)

While 1 YEK-G document is issued for every 1 MWh of production, the full documentation of these integer productions, however, results in the non-documentation of fractional productions below 1 MWh, which results in a loss in this sense. Creating a transfer mechanism for productions below 1 MWh, combining them with productions below 1 MWh in the following periods, and documenting them as they reach the full number, will prevent a loss in this sense.

ç) 1 (one) YEK-G certificate is issued for every 1 MWh of documentable production amount. The remaining fractional part of the production amount, which is below 1 MWh, is transferred to the next production period and evaluated here. This follow-up is carried out by the Market Operator. Transactions regarding transfer are regulated in the Principles and Procedures.

2- ARTICLE 5

Joke (2)

Clause d)

Considering that the system is just starting to be established, it would be beneficial to keep the validity period of YEK-G documents longer than 12 months until a deep market is formed. This is also the case for some similar ones in Europe. In this way, the possibility of these documents being evaluated and sold will increase.

The YEK-G certificate is valid for 24 (twenty-four) months from the end of the production period of electrical energy produced from renewable energy sources within the scope of this Regulation.

3- ARTICLE 5

Joke (2)

Clause e)

Considering that it may be subject to international agreements, it would be good to include English explanations of the relevant information headings in the document.

e) Each YEK-G document to be issued shall contain the following information in Turkish and English:

4- ARTICLE 6 Paragraph (3)

The fact that unlicensed producers cannot become YEK-G Certificate system users actually results in electricity produced from green sources not being documented and not being evaluated within this framework, which is not in line with the spirit of this regulation. In fact, a YEK-G certificate should be obtained for each MWh of electricity produced in an unlicensed facility but sold as surplus, and through these unlicensed producers should also be able to become YEK-G Certificate system users.

Unlicensed producers can also become YEK-G document system users through the electricity they produce.

5- ARTICLE 6 Paragraph (4)

The producer who wants to should not be prevented from registering his production in systems other than YEK-G. However, the sale of a YEK-G document in more than one such system should be prevented. In short, registration is possible but duplicate sales should be impossible. This can actually be controlled in a very simple way; despite the control, duplicate sales can be severely penalized and thus the document holder can be deterred from such a business with the penalty. However, the possibility of registering in more than one system will both cause the producer to choose the one with the more suitable price for redemption and thus increase his income, and will also increase the energy supply in the YEK-G system from the first day, and increase the number of documents and users.

Legal entities that are licensed to other systems that aim to provide information on the quality of energy outside of the YEK-G system can participate in the YEK-G system and the organized YEK-G market. However, participants undertake to take measures to prevent duplicate exports and redemptions in these other systems and YEK-G. The sanctions and penalties they will face if they fail to fulfill their commitments are regulated in the Procedures and Principles.