On 17/1/2018 the European Parliament approved an increase in the renewable energy target from 27% up to 35% of EU output.
Within the proposal of the ITRE Committee there is a section devoted to self-consumption in which it is specifically states that there will be no economic barriers to development – taxes, charges, fees or any type of charge that impedes or dissuades development.
Following this announcement it is considered that the so-called “Sun Tax” (RD 900/2015) will end.
The existing system in Spain has not helped to encourage property owners to instal solar power.
The current regulation in Spain is as follows:
1. Application of Self-consumption of solar energy:
According to article 2, the definition of Self-consumption covers any installation connected to a network, even if they do not put energy into the transport and distribution networks at any time.
The decree is not subject to isolated installations or generation groups used exclusively in the event of power interruption in the network.
2. Different Modes of Self-consumption:
- Type 1: Corresponds to own consumption not registered as a production facility. The consumer is the only subject.
- Type 2: Corresponds to a consumer associated with one or more production facilities registered in the register of electric power production facilities. Here we find the producer and the consumer.
3. Requirements for Type 1:
- The contracted power of the consumer will not exceed 100Kw.
- The power of the generation facility will be less than the contracted power.
- Both the owner of the consumption and the producer are the same.
- The generation facility and the supply point must comply with RD 1699/2011 that regulates the connection to the network.
4. Type 2 Requirements:
- The sum of the production powers of the different equipment that may exist will be the same or lower than the one contracted.
- All must go under the same owner.
- The production facilities must comply with the regulations of the electric sector (RD 1955/2000, RD 1699/2011, RD 413/2014).
5. Accumulation Batteries:
According to article 5 section 5, it is possible to use batteries, more specifically it says, “accumulation elements can be installed in self-consumption facilities”.
6. Connections:
The RD 900/2015 says that you must request a new connection or modify the existing electrical connection, with some nuances:
- Those in mode 1 with contracted power less than or equal to 10Kw, with zero injection device will be exempt from the payment of access studies and connection to the network.
- Those who have contracted power inferior or equal but with no zero injection device, or for those on mode 2, should comply with the regulations set out in RD 1699/2011.
7. Measuring Equipment:
RD 900/2015 requires the availability of measuring devices:
- Type 1: A team that records the net energy generated and other equipment independent of the previous one at the border point.
- Type 2: Bidirectional measurement equipment that measures the net energy generated and one that measures the total net energy consumed.
8. Taxes or additional charges:
There are two different types of taxes or charges, the variable on hourly self-consumption and the fixed one according to the power term.
9. Administrative Registry:
Currently all consumers must request registration on the administrative record of electricity self-consumption.
This corresponds to the General Directorate of Energy Policy and Mines of the Ministry of Industry, Energy and Tourism.
Registration must be carried out by the owner of the supply point or, failing that, by the installation company on behalf of the owner.
As you can see from the above, the current regulation covering renewable energy in Spain is very complicated.
The European Parliament´s approval of the renewable energy increase will now be negotiated between Parliament, Commission and Council.
We will have to wait and see how things turn out for the Renewables Directive and whether or not this really is the beginning of the end for the Spanish “Sun Tax”.
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