These measures, they point out, are necessary to achieve the objectives of the PNIEC
If we compare the end of the third quarter of this year with that of last year, self-consumption has decreased by 15%, falling by 22% in the industrial sector, 5% in the residential sector and 1% in the commercial sector
To reverse this situation, the sector proposes specific measures to promote collective self-consumption and energy communities, simplify and adapt administrative procedures and encourage storage behind the meter
The Spanish Photovoltaic Union (UNEF) has expressed its concern about the slowdown in self-consumption in Spain, which at the end of the third quarter registered a fall of 15% compared to the first three quarters of last year, mainly in the industrial sector (-22%) but also in the residential sector (-5%) and in the commercial sector (-1%). A trend that is also evident if we compare the end of the third quarter of this year with the end of the previous quarter, where a 12% decrease was recorded (-27% residential, -9% industrial and +5% commercial).
Given this situation, UNEF has responded to the public consultation of the Ministry for the Ecological Transition and the Demographic Challenge on the new Royal Decree on self-consumption, stressing the need to adopt measures to revitalize this sector, essential to meet the objectives established in the National Integrated Energy and Climate Plan (PNIEC).
“We are the country of the sun, with the best talent in the industry and the best resource in our environment. We are in an indisputable position of advantage to advance in the energy transition and smart cities. With simple measures that simplify the processing of self-consumption projects and maximize their performance, we can take a giant step towards this,” said José Donoso, general director of UNEF.
Simplification and incentives
UNEF advocates the transposition of the European Renewable Energy Directive, which includes most of the measures proposed by the association, especially in terms of storage, aggregation and energy communities.
In order to promote collective self-consumption and the development of energy communities, UNEF advocates the elimination of the obligation to install a net generation meter in certain cases where it may be redundant if the objective is to share surpluses and not generation, as well as developing the figure of the collective self-consumption manager to speed up the procedures for this type of self-consumption, or specific regulations for energy communities, among other proposals.
Among other proposals, UNEF proposes the simplification of procedures, advocating measures such as the exemption of the access and connection permit for those installations not only with 15kW of installed power as until now, but also any other that, even with greater installed power, does not inject more than 15kW into the network.
They also ask to extend the possibility of simplified processing of the current 100kW of installed power to the 450kW of access capacity, which would allow the latter to benefit from the simplified compensation mechanism or the possibility of modifying the access contract directly by the distributors based on the information sent by the Autonomous Communities.
It also considers tax incentives necessary, such as VAT reduced to 0%, and improvements in the electricity bill so that the surpluses can compensate for all the components of the bill, not just the energy term. In addition, UNEF considers it necessary to increase the variable part of the tolls to increase savings, in line with Europe. Spain is currently the second country in Europe with the lowest variable part in the toll scheme, which is a significant disincentive to the installation of self-consumption.
The current RD in force on self-consumption (RD 244/2019) includes few specifications on the role of storage behind the meter. With the decrease in the cost of batteries and their essential role in the development of self-consumption, UNEF considers it necessary to regulate the role of storage associated with self-consumption facilities to encourage their installation.
