1) Why “hybrid” is a legal concept in Turkey—not just an engineering choice
In Turkey, “hybrid power plant” is not merely a technical design where two resources produce electricity at the same site. It is also a regulatory classification that determines:
- whether the project is treated as a single facility under one pre-license/license or as multiple facilities,
- which permitting and grid-connection rules apply to the main source and the auxiliary source,
- what limitations exist on installed power, active output, and settlement/payment,
- how the plant can participate in support schemes (and which part of generation is eligible),
- and what happens when an operator wants to convert an existing plant (e.g., a wind farm adding solar, or a hydro plant adding floating solar).
Turkey’s secondary legislation makes this explicit through two separate—but connected—lenses:
- Electricity market licensing rules define multi-source facilities (and their sub-types), plus the conversion conditions. (LEXPERA)
- Renewable certification/support rules define “hybrid facility” for YEK certification and YEKDEM registration purposes, and they limit support treatment to the renewable portion.
Understanding these two lenses is the difference between a project that is “permit-ready and bankable” and a project that later discovers its assumed revenues or capacity use cannot be recognized under settlement rules.
2) The legal taxonomy: what counts as a hybrid / multi-source facility?
2.1 Multi-source electricity generation facility (licensing lens)
The licensing amendments introduce a broad umbrella concept: “multi-source electricity generation facility” (birden çok kaynaklı elektrik üretim tesisi). Legally, it is defined as a category that includes four sub-types: (i) united renewable, (ii) united, (iii) supporting-source, and (iv) co-firing facilities. (LEXPERA)
Within this model, Turkish law also distinguishes:
- Main source (ana kaynak): the source chosen in the pre-license/license application, and
- Auxiliary source (yardımcı kaynak): other source(s) used in the same facility, different from the main source’s type. (LEXPERA)
This “main/auxiliary” framing is critical because many obligations are assessed through the main source, sometimes by aggregating main+auxiliary installed power, and because the law places strict limitations on changing that relationship. (LEXPERA)
2.2 Sub-types you will encounter in practice (and what they mean)
Turkey’s licensing definition set includes:
- United electricity generation facility (birleşik elektrik üretim tesisi): a single electricity generation facility established to generate electricity from more than one energy source, connected to the grid from the same connection point. (LEXPERA)
- United renewable electricity generation facility (birleşik yenilenebilir elektrik üretim tesisi): same architecture as above, but all sources are renewable. (LEXPERA)
- Supporting-source electricity generation facility (destekleyici kaynaklı): a single facility where another energy source is used in the thermal conversion process in addition to the main source. (LEXPERA)
- Co-firing electricity generation facility (birlikte yakmalı): a facility where a renewable auxiliary source is burned together with a non-renewable main source in the same facility. (LEXPERA)
When clients say “hybrid,” they most commonly mean wind + solar at the same grid point, which typically fits into a “multi-source” architecture. But the legal net is wider: the same framework also covers thermal and process-based combinations through supporting-source and co-firing models. (LEXPERA)
2.3 “Hybrid facility” in the renewable support lens
Separately, the renewable certification/support regulation defines hybrid facility as a facility generating electricity using two or more energy sources, provided that at least one is among the renewable sources covered by the regulation.
This definition matters because support eligibility is not automatically “whole-plant.” In YEKDEM registration, the rule is explicit: for hybrid facilities, the application covers the amount generated from the renewable energy source under the regulation, whereas for non-hybrid plants the application covers the full licensed production amount.
3) The core legal status rule: one facility, one license—auxiliary is treated as part of the main unit
A key compliance advantage of Turkey’s multi-source model is that it can be structured as one facility under one license, which is exactly why investors often use it to “fill” existing connection capacity.
The licensing amendment states that the auxiliary source unit used in multi-source facilities is treated as a unit of the main-source facility, and the facility is evaluated within a single pre-license or license. (LEXPERA)
This is the central legal status point you can use when explaining hybrid structuring to investors and lenders: the law recognizes the auxiliary unit as legally embedded in the licensed facility rather than a separate plant—provided the project stays within the conversion and configuration rules.
4) Two development pathways: build hybrid from day one, or convert an existing plant
Hybrid projects in Turkey typically follow one of two legal routes:
Route A — New pre-license / license application as a multi-source facility
If the project is designed as a united renewable or united facility from inception, the application must define the main source and the auxiliary source. Certain obligations are then evaluated through the main source by considering the combined installed power of main + auxiliary for specific requirements. (LEXPERA)
A practical implication: documentation and obligations that normally attach to the main source may be assessed by taking the combined installed power into account (for the items listed in the regulation’s amendment text). (LEXPERA)
Route B — Convert an existing licensed or pre-licensed plant into a multi-source facility
The higher-frequency market use case is conversion: a project company holds a wind pre-license/license and wants to add solar within the site, or a hydro plant wants floating solar units.
Turkey’s licensing amendment establishes the conditions for such conversion (“tadil”):
For pre-licensed plants (conversion during the pre-license stage)
The conversion can be accepted if, among other conditions:
- the project does not extend beyond the area recorded in the pre-license,
- the total electrical installed power recorded in the pre-license does not change,
- the existing connection type, connection point, and voltage level do not change, and
- where the auxiliary source is wind or solar, the technical evaluation by the Energy Affairs General Directorate (EİGM) is suitable. (LEXPERA)
Hydro-based pre-licenses require additional DSİ involvement (e.g., DSİ suitable opinion, and for floating solar or solar on hydro canal/reservoir areas, DSİ leasing arrangements). (LEXPERA)
For licensed plants (conversion after obtaining the generation license)
The conversion can be accepted if, among other conditions:
- the project does not extend beyond the area recorded in the license,
- the total electrical installed power recorded in the license does not change,
- the existing connection type, connection point, and voltage level do not change, and
- where the auxiliary source is wind or solar, EİGM’s technical evaluation is suitable; for hydro-based plants, DSİ suitable opinion is required. (LEXPERA)
Why this matters commercially
These conditions mean hybrid conversion is not a backdoor capacity expansion. It is legally designed to use existing licensed parameters (site and connection) while optimizing resource complementarity.
From a transactional perspective, this is also why hybrid conversion is often done as a license amendment closing condition in acquisitions: if you buy a wind asset intending to add solar, the value uplift is only real when the conversion fits these strict criteria.
5) Grid connection and competition rules: the auxiliary source is treated differently, but not “unregulated”
Hybrid structuring in Turkey is often motivated by a simple economic reality: connection capacity is scarce and expensive. The licensing amendment provides a meaningful procedural advantage:
For auxiliary sources in united facilities, all provisions of the connection/competition article apply except the provisions relating to “competition” (i.e., capacity allocation by contest) for the auxiliary source. (LEXPERA)
This does not mean the auxiliary source is free from grid rules. It means the auxiliary unit is processed within a framework that does not force it through the same competitive allocation route as a standalone new plant—subject to the facility’s compliance with the multi-source model and the conversion limitations.
In practice, the project still needs to be engineered and documented so that the single connection point and the licensed active output limits are respected, especially where settlement/payment is capped.
6) Active output and payment caps: the hidden clause that can destroy naive revenue models
One of the most overlooked provisions in Turkey’s hybrid framework is the output/payment cap for certain multi-source facilities.
The licensing amendment provides (in summary) that, in united renewable and united facilities, the active output deliverable to the system cannot exceed the total electrical installed power of the main-source units whose provisional acceptance is completed, and if production exceeds the energy amount corresponding to that capacity, no accrual and no payment is made for the excess production. (LEXPERA)
What this means for investors
If you are modeling a wind + solar hybrid where solar output pushes total generation above what is recognized for payment under this rule, your merchant model may not be realizable as assumed. The best practice is to structure the operating profile and internal dispatch logic so the plant’s output stays within the legally recognized envelope—or to align commissioning/acceptance sequencing so the recognized main-unit capacity reflects the intended operational ceiling.
What this means for contracts
In offtake agreements (corporate PPAs), “deemed energy,” “curtailment,” and “no-payment” risk must be allocated with precision. If the legal framework says excess production does not create a payable settlement item, a buyer cannot reasonably demand delivery-based damages for an amount that is legally non-payable under the applicable settlement logic.
7) Technical evaluation: adding solar to an existing plant is paperwork-heavy for a reason
For the most common conversion type—adding a solar unit as the auxiliary source within an existing plant site—Turkey’s technical rules are concrete and geometry-based.
The Energy Ministry’s technical assessment document for solar units within multi-source facilities sets out, among other points:
- the assessment covers applications where the auxiliary source is solar and the project is a multi-source facility, including conversion of an existing pre-license/license by installing a solar unit within the plant site,
- submissions include site layout plans and a .kml digital file describing the plant site(s),
- the solar “plant site” may consist of multiple polygons (each treated as a plant site definition),
- each polygon’s corner points must be numbered in sequence, and a minimum installed power density requirement must be satisfied,
- and most importantly: the solar plant site submitted for conversion must be within the site of the main-source plant.
This is not a mere formality. In litigation and compliance reviews, inconsistent polygon files, mismatched coordinates, or “site creep” beyond the licensed site boundary can become the central defect that blocks conversion or triggers enforcement.
8) Hydro + floating solar (and canal/reservoir solar): DSİ is not optional
The licensing amendment expressly addresses floating solar units and certain solar installations on hydro facilities’ canal/reservoir surfaces. It ties such configurations to DSİ documentation and leasing arrangements. (LEXPERA)
For clients, the practical lesson is straightforward:
- If the main source is hydro and the auxiliary solar is planned on water surfaces inside the hydro plant’s site definition, the project must be designed as a DSİ-coherent file from the start.
- Procurement and financing should anticipate DSİ’s timetable and document style (leases, consents, and technical approvals), because a missing DSİ step can invalidate the conversion timeline even when EMRA-side licensing is otherwise clean. (LEXPERA)
9) Support mechanisms and certificates: how to protect “eligible” renewable output inside a hybrid plant
9.1 Hybrid definition for YEK support
Under the renewable certification/support regulation, a hybrid facility is one that uses two or more sources, at least one of which is among the covered renewable sources.
9.2 YEKDEM registration and the “renewable portion only” rule
If the plant seeks to participate in YEKDEM, the regulation’s registration rule is explicit:
- For hybrid facilities, the application covers only the electricity generated from the renewable source under the regulation.
This is often the defining revenue issue in projects where one component is renewable and another is not (or where measurement/attribution matters). The “hybrid” structure can support bankability, but only if metering and reporting can demonstrate the renewable-origin portion with defensible documentation.
9.3 Practical compliance: measure first, litigate never
The same regulation contains an entire section dedicated to “Hybrid facilities,” which signals that attribution and determination of renewable-based generation is not left to informal practice.
For a project company, this means that metering design, SCADA reporting, and internal generation records should be treated like financial statements—because a later dispute about “which MWh is eligible” is rarely solved cheaply.
10) Common disputes in hybrid projects—and how to prevent them
Dispute A — “This is a capacity increase, not a conversion”
Hybrid conversions are permitted only within strict boundaries: no change in total electrical installed power, no change in connection point/voltage level, and no expansion beyond the licensed site. (LEXPERA)
Prevention: build a compliance memo and a single source-of-truth site file (KML, maps, site boundary) before any procurement contract is signed.
Dispute B — “Your solar site is not inside the main plant site”
The technical assessment framework requires the solar site for conversion to sit inside the main plant’s site.
Prevention: coordinate legal and engineering teams on polygon mapping; do not let EPC contractors “optimize layout” beyond the permitted polygon without revisiting the licensing file.
Dispute C — “Excess generation is not payable”
United and united renewable facilities can face non-payment for production beyond the recognized envelope tied to accepted main units. (LEXPERA)
Prevention: design dispatch/controls and commissioning sequencing with the payment cap in mind; reflect it in offtake terms.
Dispute D — YEK certificate / YEKDEM eligibility challenges
Hybrid plants are treated differently for YEKDEM registration: only the renewable portion is within the application scope.
Prevention: metering/attribution architecture and documentation discipline from day one.
11) Investor-grade checklist for hybrid plants (wind + solar, solar + hydro, and other combinations)
- Choose the legal model: united renewable vs united vs supporting-source vs co-firing. (LEXPERA)
- Confirm main/auxiliary classification and lock it into governance documents. (LEXPERA)
- Route selection: new pre-license or conversion of an existing pre-license/license. (LEXPERA)
- Conversion conditions check: site boundaries, total installed power, connection parameters. (LEXPERA)
- EİGM technical evaluation readiness for auxiliary wind/solar. (LEXPERA)
- Polygon/KML integrity: solar site inside main plant site; numbering and density requirements.
- DSİ pathway for hydro-related solar configurations (including floating/canal/reservoir layouts). (LEXPERA)
- Payment cap model: verify whether project assumptions rely on generation that could be legally non-payable. (LEXPERA)
- Support scheme strategy: identify whether the plant qualifies as hybrid under YEK rules and how renewable portion is demonstrated.
- Contract alignment: EPC scope, milestones, acceptance sequencing, and offtake terms must reflect licensing and settlement realities. (LEXPERA)
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