A few more barriers to be commented…

The post yesterday about RD 1699/2011 concerned the opacity of the distribution system and the introduction of administrative barriers by the Ministry.  In this post we will follow the same format and continue to examine the administrative barriers of RD 1699/2011, comparing earlier drafts with later drafts.  

There´s a new article that was introduced in the second and third draft that states:

The applicant shall receive a maximum term of 15 months for the installation to be entered in the registry of pre-allocation or in the administrative record for production facilities upon accepting the proposal from the distributor.   Once registered, the duration of the connection point shall be maintained upon cancellation.  

This means that if the applicant, through no fault of their own, fails to meet the 15 month deadline then they are denied access to the network. An example of this is the moratorium RDL 1/2012 which states that the applicant could lose its access while indefinitely waiting for acceptance into the network. Article 5.8 does not contain a clause that makes an exception for people who get denied access due to no fault of their own. This clause is a good example of how not to gradually eliminate administrative barriers as it, in fact, increases administrative barriers.