The Spanish Photovoltaic Union (UNEF) has expressed concern over the slowdown of self-consumption in Spain, which, as of the third quarter, shows a 15% drop 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%). This trend is evident when comparing the closure of the third quarter of this year with the closure of the previous quarter, where a 12% decrease is recorded (-27% residential, -9% industrial, and +5% commercial).

In light of this situation, UNEF has responded to the public consultation by the Ministry for Ecological Transition and the Demographic Challenge on the new Royal Decree for self-consumption, emphasizing the need for measures to revitalize this sector, which is essential to meeting the objectives set out in the National Integrated Energy and Climate Plan (PNIEC).

“We are the country of the sun, with the best industry talent and the best resource in our environment. We are in an indisputable advantageous position to advance in the energy transition and smart cities. With simple measures that streamline the processing of self-consumption projects and maximize their performance, we can take a giant step towards this,” commented José Donoso, General Director of UNEF.

Simplification and Incentives

UNEF advocates for the transposition of the European Renewable Energy Directive, which includes most of the measures proposed by the association, particularly in the areas of storage, aggregation, and energy communities.

In order to promote collective self-consumption and the development of energy communities, UNEF calls for the elimination of the requirement to install a net generation meter in certain cases where it may be redundant if the goal is to share surpluses and not generation, as well as the development of a collective self-consumption manager role to expedite the procedures for this type of self-consumption, or specific regulations for energy communities, among other proposals.

Among other proposals, UNEF suggests simplifying procedures, advocating for measures such as the exemption from the access and connection permit for installations not only with 15kW of installed power, as is the case now, but also for any installation that, despite having higher installed power, does not inject more than 15kW into the grid.

They also request extending the possibility of simplified processing for installations with up to 100kW of installed power to 450kW of access capacity, which would allow these to benefit from the simplified compensation mechanism or the possibility for distributors to modify the access contract directly based on the information provided by the Autonomous Communities.

They also consider tax incentives necessary, such as a reduced VAT rate of 0%, and improvements to the electricity bill so that surpluses can compensate all components of the bill, not just the energy term. Additionally, UNEF considers it necessary to increase the variable portion of the tolls to increase savings, in line with Europe. Spain is currently the second country in Europe with the lowest variable portion in the toll scheme, which acts as a significant disincentive to the installation of self-consumption.

The current Royal Decree in force on self-consumption (RD 244/2019) includes few specifications regarding the role of storage behind the meter. With the reduction in battery costs and its essential role for the development of self-consumption, UNEF believes it is necessary to regulate the role of storage associated with self-consumption installations to encourage its installation.