June 2011 update
The draft of Royal Decree to improve legal-administrative framework was favourable informed by Comisión Nacional de la Energía (CNE) but final approval is delayed and is now estimated for second part of this year.
This Royal decree will include, in addition to items indicated in the December 2010 update, the possibility of connecting to the Low Voltage internal grid of the owner of the PV installation, when the owner, as a consumer, connects to the Utility grid in Medium Voltage
A Regional and National Workshop took place. The Result Assessment already issued significant agreement with utilities in the National and Regional Workshops to streamline administrative procedures and improve time response for connection to the grid.
Only fees for capacity studies made of one main utility is life, and there are good prospect that this utility also would remove this administrative cost.
Net metering identified in the "National Workshop" as a potential by-pass of the register and market annual cap that the government is not yet ready to abolish. The government is studying net metering and requested to PV LEGAL/ASIF during the National Workshop to contribute with ideas for an optimal design.
The regional government of Castilla La Mancha changed in June 2011 from a center-left to a center-right party, which implies a total change of political structure, causing certain impact in the PV LEGAL efforts made so far with the former officials.
December 2010 update
The draft of Royal Decree to improve legal-administrative framework was finalised, agreed with government and passed the Comisión Nacional de la Energía (CNE). Now it is pending of final approval (expected for the first quarter of 2011). This decree, when approved, will:
- Remove the need to obtain an administrative permit for all PV installations of up to 100 kWp connected to the low voltage grid.
- Introduce a major simplification of the procedure for connecting PV installations of up to 20 kWp to the grid, provided the PV installation is associated to an electrical consumption of equivalent or higher power at the same connection point.
- Provide for a reduction of bureaucracy for connecting PV installations of up to 10 kWp as these will be permitted to connect to the internal low voltage electricity network, instead of connecting to the medium voltage grid.
Additional and significant legal-administrative improvements for PV installations of up to 10 kWp will also be introduced as the owner of PV installations will have the possibility to consume on site the electricity generated. This net-metering framework foreseen by the decree will however need additional detailed regulation which will be addressed within PV LEGAL.
Legal-administrative procedures are also considered a barrier for the development of PV by the Spanish government in its Plan de Energías Renovables 2011-2010 (PER) now under preparation, and suggested actions for simplification of legal-administrative procedures are being discussed in the meetings with the entity in charge of preparing the report (Institute for Diversification and Saving of Energy, IDAE).
The current focus of the Spanish Government lies on economic issues related to PV and not on improving legal-administrative procedures. Therefore, it is currently very difficult to convince the government to implement the PV LEGAL proposals, like removing the existing market cap, as the government may consider this suggested action as incompatible with the desired tight economic control.
Status as of April 2010
Improvements of the legal-administrative framework are currently being discussed in Spain. First results of the PV LEGAL project have been presented to the Spanish Government. The following proposals have already been fed into the Royal Decree draft which is currently being discussed by the Spanish Parliament: removal of the need to obtain an administrative permit for all PV installations of up to 100 kW and connected to the low voltage grid; simplification of the procedure for connecting PV installations of up to 20 kW to the grid provided the PV installation is associated to an electrical consumption of equivalent or higher power at the same connection point; additional and significant legal-administrative improvements for connecting PV installations of up to 10 kW to the grid; reduction of bureaucracy for connecting PV installations of up to 10 kW and located inside an internal electricity network as it would be permitted to connect to the internal low voltage network, instead of connecting to the medium voltage grid.