Quo vadis Italy? Barriers, new regulations and future FiT

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? Barriers, new regulations and future FiT Andrea Zanolla, Assosolare 1 PV in Spain: market analysis a nd barriers A conference of the Spanish Photovoltaic Industry Association (ASIF) Madrid, October 6th, 2010 Hotel Meliá Barajas. Catamarán St., 1. Barajas.

ABOUT US Founded in 2006, Assosolare is the Italian National Photovoltaic Industry Association. The association i is devotedd to the promotion and development of the photovoltaic sector in Italy and represents about 70 member Companies. Assosolare is engaged in promoting the creation of a national legislative framework able to allow for a real development of the PV market in the Country. Recognised as an authoritative actor in representation of the interests of the PV sector towards the Institutions. 2

ABOUT US Ati Active in the discussioni and negotiation gtiti of the new laws and regulations concerning the PV sector and its stakeholders Member of Confindustria Energia (Confederation of Italian Energy Industry) Member of C.N.E.S. (National Solar Energy Commission); coordinator of Business Community Group ( Gruppo Imprese ) Participates in the taskforce instituted by AEEG (the Italian Electric Energy and Gas Authority) for monitoring of renewable energy sector Has founded and coordinates with BSW Solar (GER) the NNPVA Europe, the European PV association network Member of EPIA Italian partner of the EU Project PV Legal (IEE Program) 3

PV LEGAL Project cofinanced by the European Commission (Intelligent Energy Europe Program). Goals: analysis and reduction of legal administrative barriers for the PV sector in Europe. Actions: Research on administrative procedures in 12 Countries (concluded in March 2010) Highlight and analysis of major legal - administrative barriers (concluded Marzo 2010) On line database. Procedures, duration, waiting times, difficoulty in12 countries. (June 2010) Drafting and presentation of National Advisory Papers Organisation of National Forums to present the Advisory Papers (Italian Forum 8 Sept. 2010) Workshops targeted to the institutions, policy and decision makers, (2011) www.pvlegal.eu l 4

PV LEGAL 5

PV LEGAL National Advisory Paper (Italy) The Preliminary Advisory Paper highlights and analyzes the major legal administrative barriers for the installation of PV systems in the Italian framework, keeping into account the recent (and ongoing) evolutions. National guidelines and Autorizzazione unica Environmental Impact Assessment Landscape authorization Grid (structural issues) and connection procedures Real estate taxation for ground mounted PV systems Fire prevention safety rules for PV on commercial buildings 6

NATIONAL GUIDELINES AND AUTORIZZAZIONE UNICA 7

NATIONAL GUIDELINES Decree 387/2003 reception of Directive 2001/77/EC, establishes: the legal bases for the incentivation of PV in Italy (art.7) generall rules for the authorization i of PV systems. Above 20kW the Autorizzazione i unica procedure is required (art. 12) Guidelines for the authorization process foreseen by art. 12 approved in July 2010! Published in the O.J. n. 219 of 18 September 2010 Regionsi have 90 days to comply. After thatt period the National Guidelines overrule Regional laws when not compliant 8

7 years of delay caused... NATIONAL GUIDELINES Regions adopted own regulations for the Autorizzazione unica. Different rules for each Region. Differences also at local administrative levels Virtuoust Regions vs. Inefficient i or restrictive titi ones Non uniform development of PV in the County Uncertainty for PV market actors (waiting times, costs, delays, legal issues,..) Delays and administrative problems led to a huge amount of appeals to the Regional Tribunals (TAR). Regional Laws challenged and blocked. Constitutional Court banned some provisions of Regional laws, particularly Puglia and Calabria that were allowing DIA (simplified administrative procedure) up to 1 MW (instead of 20kW as foreseen by 387/2003) NOTE: Legge Comunitaria 2009 (L 96/2010). O.J. n. 146 of 25 June 2010. DIA up to 1 MW NOTE: Legge Salva DIA (L 129/2010) O.J. n. 192 of 18 August 2010. Systems authorized by regional laws (DIA up to 1 MW) must start operating within 150 days =16 Jan 2010. 9

NATIONAL GUIDELINES What s changed? More uniformity in the authorisation procedures in Italy Better development of PV market (qualitative & quantitative), also for Regions in delay More transparency and simplicity: Exemption cases clearly defined Regions must provide information on procedures and actors involved in the authorization phase Environmental and territorial compensation towards Municipalities - max 2% Expenses for administrative burden compensations max 0,02% of the investment Provisions to fight speculation have been introduced Penalties in case of delays (art. 14.16) have been introduced (but not well defined) DIA (start o activities declaration), Now SCIA (Simplified DIA) for roof mounted systems DIA (SCIA) also for ground mounted systems up to 1 MW (provision of Legge Comunitaria 2009) 10

Are we sure? NATIONAL GUIDELINES On paper the Guidelines are well drafted and represent a real turning point in Italy. Their effectiveness will need to be monitored and assessed. Regional response and compliancy with the national framework will need to be monitored and assessed. Regions still hold much of the power and responsibility on the control and functioning of the procedures Territorial and local Authorities are at the same time fundamental blocks of the authorization procedures. Their cooperation is therefore needed. Political willingness, efficiency, personnel issues, are factors that can determine the success of the Guidelines or hamper the development of the PV sector in Italy. Recourse to tribunals is always a way, but it is not an effective one, mainly because of the long waiting times and costs involved. Points of non applicability of the Guidelines? At study. Position of the Regions that recently approved provisions to simplify administrative procedures? At study. 11

NATIONAL GUIDELINES Source PHOT TOVOLTAIC Rif. 12.1 12.1 12.2 EXEMPTIONS FROM THE AUTORIZZAZIONE UNICA Conditions to be respected Installation type Further conditions Power (kw) PV Systems adhering or integrated to the roof with the same inclination and orientation of the slope and whose components do not modify the shape of the building PV Systems built on existing buildings or in their pertinences On buildings. The total surface of the modules of the PV System is not superior to that of the roof on which they are positioned. Systems not falling in the field of application of Cultural or Heritage protections Built outside "zone A" territory as from Decree 1444/1968 none All 0-200 12.2 None (ground mounted) none 1000* All building regime Communication (to the Municipality) Communication (to the Municipality) DIA (Municipality) DIA (Municipality) *Limit defined by the Legge Comunitaria 2009 and not yet taken into account in the Guideline text. 12

LANDSCAPE AUTHORIZATION 13

LANDSCAPE AUTHORIZATION Landscape authorization: The procedure can be a stand alone one or fall within the Autorizzazione unica Lenghty procedure (up to 110 days). Often integrations are required (increasing waiting time) No clear rules or standard evaluation criteria (aesthetic criteria vs. wider RES angle) High level of discretionality by the specific territorial office involved (veto power) Very high percentage of territory covered by landscape restrictions Regulation DPR 09/07/2010 n. 139, entered into force the 10th September 2010 simplifications for the landscape authorization for PV systems up to 25 square meters (3kW). Reduced waiting times from >100 to max 60 days for minor entity interventions (see above) Systems not falling into minor entity category will undergo same procedures as before. Further simplifications and common sense exemption cases needed (i.e. BIPV). 14

GRID INFRASTRUCTURES AND SPECULATION ISSUES 15

Grid connections - speculation Problems GRIDS & CONNECTIONS distortion of market conditions: few speculators monopolize a territory and create difficult conditions for smaller (real) investors Inflation of land value & prices (+permissions) Virtual reservation of capacity (only 2 nd choice point of connection available) increase costs of bureaucracy Jams administrative offices with huge number of virtual requests (i.e. STMG, DIA) Solutions Possibility to request connection only after authorizations are obtained Additional i l caution which h is lost if no system is built TICA (Regulation for active connections) Rrevised in August 2010 by the Authority (AEEG). Deliberation ARG/elt 125/10 Dispositions to fight speculation and virtual reservation of grid capacity Bank warranty for connections in critical areas. Warranty is lost when the terms of validity of the forecast budget for the connection expire or in case the authorizations are not achieved. NOTE: new TICA under evaluation. Some doubts are present. 16

GRIDS & CONNECTIONS Grid infrastructures Problems Insufficiency of transmission and distribution grids, particularly in the southern Regions Saturation (real and virtual) of the grid capacity Grid not built to support distributed generation NonN predictability of PV production Solutions Plans for the implementation of grid infrastructures (Plans are running TERNA) Plans already exist but are long term ones. Need to prioritize interventions Smart grid solutions & forecast systems (Pilot projects are present). Need to mainstream best solutions. Storage systems 17

QUO VADIS ITALY? III CONTO ENERGIA 2011-2013 18

OVERVIEW Results in 2010: Currently: 1,6 GW installed 2,5 GW of cumulative power foreseen by the end of 2010 Average power of installed systems raising: from 8kW in 2006 to 18 in 2009 to over 22 in 2010. Future of PV in Italy (III FiT scheme) 3GW cap 2011 2013. Trends lead to foresee the reaching of the 2020 cap in 2013-14 8 GW cumulative cap by 2020 but with actual trends, the cap could be reached already in 2013. 15 GW could easily be reached (underestimated potential). Need to revise the target to 2020 The National guidelines should improve the efficiency of the authorization process Uniformity in the procedures should bring a more even development of PV in Italy Easier administrative procedures will foster roof mounted PV on commercial (and residential) buildings. 19

III FiT SCHEME III Conto energia approved in July 2010 (State-Regions Conferece) Pubblished in the O.J.: 24 August 2010 FiT: applicatins from 2011 to 3013. FiT valid for 20 years Who may apply: individuals, legal entities, public bodies and condominiums Target of additional installed power:3000 MWp within 2013 (+14 /24 months after cap is reached) Target 2020: 8000 MWp Tariffs: gradual decrease during 2011as in Table 1; annual cuts of 6% in 2012 and 2013 Classes of power: new subdivision in 6 classes of power (see tables 1 and 2) 20

III FiT SCHEME Premiums for: PV systems stems associated to efficient use of energy (max + 30% on the awarded arded tariff) PV systems in commercial, industrial or degraded areas (+5% on the awarded tariff) PV Systems for Municipalities with less than 5000 inhabitants (+5% on the awarded tariff) PV used in substitution of asbestos roofs and covers (+10% on the awarded tariff) PV systems allowing predictable input (+20% on the awarded tariff) Special tariffs for: PV systems with innovative integration characteristics: 0,44 up to 20 kwp; 0,40 between 20 and 200 kwp; 0,37 over 200 kwp (guidelines to be issued by January 2011) Concentration PV systems: included d with special tariffs. Cap of 150MW of total installed power. Cut 2% yearly Greenhouses, shelters, acoustic barriers... Systems whose modules are building elements of greenhouses, shelters, acoustic barriers: the tariff is equal to the arithmetic average of the tariffs for roof mounted and other systems in each power class (see Table 3) 21

III FiT SCHEME Table 1 Plant Operation CORRESPONDING TARIFF - year 2011 A) B) C) Systems starting operation after December 31st 2010 Systems starting operation after April 30th 2010 and Systems starting operation after August 31st 2010 and and within within within April 30th 2011 August 31th 2011 December 31th 2011 Roof Roof Roof Other PV Other PV Other PV mounted mounted mounted systems systems systems PV systems PV systems PV systems [kw] [ /kwh] [ /kwh] [ /kwh] [ /kwh] [ /kwh] [ /kwh] 1 P 3 0,402 0,362 0391 0,391 0347 0,347 0,380 0,333 3<P 20 0,377 0,339 0,360 0,322 0,342 0,304 20<P 200 0,358 0,321 0,341 0,309 0,323 0,285 200<P 1000 0,355 0314 0,314 0,335 0,303 0314 0,314 0,266 1000<P 5000 0,351 0,313 0,327 0,289 0,302 0,264 P>5000 0,333 0,297 0,311 0,275 0,287 0,251 22

III FiT SCHEME Table 2 FiT reductions by power class in 2011 (3 periods) Tariffs reduction % (3 periods 2011) Reduction % of tariffs in 2011 (3 periods) 1 period (Jan-Apr) 2 period (May-Aug) 3 period (Sept-Dec) Roof-top mounted * Other PV Systems Roof-top mounted * Other PV Systems Roof-top mounted * Other PV Systems Power class % % % % % % Class 1 (kwp) 1 P 3-4,825-5,768-7,429-9,673-10,034-13,317 Class 2 (kwp) 3 < P 20-6,452-7,011-10,670-11,674-15,136-16,612 Class 3 (kwp) 20 < P 200-6,810-7,209-11,235-10,678-15,920-17,616 6 Class 4 (kwp) 200 < P 1000-7,591-9,233-12,797-12,413-18,263-23,108 Class 5 (kwp) 1000<P 5000-8,632-9,522-14,879-16,460-21,387-23,686 Class 6 (kwp) >5000-13,317-14,147-19,044-20,506-25,292-27,444 * Roof top mounted tariffs are compared to partially integrated systems tariffs 23

III FiT scheme 2011-2013 Tabella 3 Tariff cuts for greenhouses and similar vs. 2010 TARIFFS FOR GREENHOUSES, SHELTERS, ACOUSTIC BARRIERS Tariffs 2010 Tariffs 2011 & Cut % vs. 2010 Partial integration Full integration I period 2011 Partial integration Full integration II period 2011 Partial integration Full integration III period 2011 Partial integration Full integration 0,42 0,47 0,38-9,56% -18,79% 0,37-12,64% -21,56% 0,36-15,60% -24,21% 0,40 0,44 0,36-11,17% -19,00% 0,34-15,38% -22,85% 0,32-19,85% -26,92% 0,38 0,42 0,34-11,63% -19,62% 0,33-15,40% -23,06% 0,30-20,87% -28,03% 0,38 0,42 0,33-12,93% -20,81% 0,32-16,96% -24,48% 0,29-24,51% -31,34% 0,38 0,42 0,33-13,58% -21,40% 0,31-19,83% -27,08% 0,28-26,33% -33,00% 0,38 0,42 0,32-18,00% -25,42% 0,29-23,73% -30,63% 0,27-29,98% -36,31% The cuts heavily affect a segment of the market that could have fostered positive synergies with agriculture and other sectors. 24

MARKET RESULTS Data GSE 31 August, 2010 Total number of systems: 94.957-1 and 2 FiT - cumulative Total installed power: 1,5 GW - 1 and 2 FiT - cumulative Class kw Number Power (kw) 1 1 P 3 41.952 112.300 2 3 < P 20 46.459 359.121 3 20 < P 200 5627 5.627 353.248 4 200 < P 1000 858 552.815 5 P > 1 61 147.608 Total 94.957 1.525.092 25

MARKET RESULTS Data GSE 31 August, 2010 Number and power of installed systems by year. Average power by year. GSE data 31 August 2010 CLASS 1+2+3 CLASS 4 CLASS 5 1 kw P 200 kw 200 kw P 1 MW P > 1000 kw TOTALE AVERAGE Number Power (kw) Number Power (kw) Number Power (kw) Number Power (kw) Power (kw) 2006 1.402 9.437 0 0 0 0 1.402 9.437 6,7 2007 6.238 48.108 36 21.960 0 0 6.274 70.068 11,2 2008 23.871 209.678 216 114.936 6 13.793 24.093 338.407 14,1 2009 38.960 358.885 387 258.339 39 101.226 39.386 718.450 18,4 2010 (Aug) 23.612 198.614 219 157.530 16 32.589 23.847 388.733 Expected: >22 94.083 824.722 858 552.765 61 147.608 95.002 1.525.095 26

MARKET RESULTS Cumulative number and power of systems per class Number and power by class 359.121 600.000 500 000 500.000 112.300 400.000 552.815 353 248 353.248 300.000 200.000 100.000 41.952 46.459 0 Number 147.608 5.627 CLASSE 1 858 CLASSE 2 P Power (kw) Power (kw) 61 Number CLASSE 3 CLASSE 4 CLASSE 5 27

MARKET RESULTS Number of running systems by Region 16.000 14.000 12.000 10.000 8.000 6.000 4.000 2.000 Number 0 28

MARKET RESULTS Installed power by Region (Aug 2010) 350.000 300.000 250.000 200.000 150.000 100 000 100.000 50.000 Power 0 29

MARKET POTENTIAL Market potential - study of the Energy & Strategy Group (Politecnico di Milano University). In the most conservative hypothesis of the study, the total theoretical potential to 2020, estimated taking into account only small % of the available surface fit for PV installations is of about 40 GW. That might increase taking into accout more optimistic percentages. New residential buildings Commercial surfaces of the GDO 20% of greenhouses on agricultural land Portual areas 1% of the overall uncultivated / scarcely productive lands TOTAL 5,20 GW 0,68 GW 5,80 GW 0,25 GW 27,8 GW 39,33 GW 30

Thank you for the attention! www.assosolare.org 31

BACKUP: GSE data DATS GSE August 31, 2010 CLASS 1 (kwp) CLASS 2 (kwp) CLASS 3 (kwp) CLASS 4 (kwp) CLASS 5 (kwp) First and second FiT 1 P 3 3 < P 20 20 < P 200 200 < P 1000 P > 1000 TOTAL Number Power Power Power Power Power Power Number Number Number Number Number (kw) (kw) (kw) (kw) (kw) (kw) PUGLIA 2.484 6.679 3.461 25.460 446 24.652 279 248.969 1 1.661 6.671 307.421 LOMBARDIA 6.831 18.138 6.696 52.924 870 58.227 63 27.994 11 14.951 14.471 172.234 EMILIA ROMAGNA 4.032 10.458 3.790 30.505 686 44.027 66 32.962 4 7.983 8.578 125.935 LAZIO 2.673 7.041 2.859 21.125 201 12.197 30 17.027 9 52.771 5.772 110.161 VENETO 4.219 11.207 5.149 37.088 485 32.431 48 21.850 4 4.730 9.905 107.306 PIEMONTE 3.352 8.936 3.605 29.799 450 31.185 51 24.042 9 13.227 7.467 107.189 MARCHE 1.683 4.435 1.558 12.461 294 20.426 69 36.854 4 10.275 3.608 84.451 TRENTINO A.AA 1.956 5.424 2.358 21.988 475 27.712712 57 24.598 0 0 4.846 79.722722 SICILIA 2.401 6.595 2.670 19.131 173 10.811 24 15.655 6 15.479 5.274 67.671 TOSCANA 2.963 7.741 2.970 24.736 219 14.120 27 14.018 3 6.014 6.182 66.629 SARDEGNA 2.922 8.102 2.547 18.102 80 5.113 21 15.066 4 5.264 5.574 51.647 UMBRIA 1.139 3.194 1.091 8.760 209 11.504 31 19.214 2 4.779 2.472 47.451 FRIULI VEN. GIULIA 1.701 4.674 2.922 19.497 134 8.772 11 5.225 0 0 4.768 38.168 CAMPANIA 1.023 2.802 1.313 10.165 157 9.170 25 15.364 0 0 2.518 37.501 BASILICATA 372 1.038 417 3.473 394 19.426 17 11.547 0 0 1.200 35.484 CALABRIA 797 2.197 1.242 9.276 140 8.478 18 11.313 1 3.298 2.198 34.562 ABRUZZO 554 1.479 1.106 8.944 139 9.901 13 7.762 1 2.469 1.813 30.555 MOLISE 97 267 172 1.427 24 1.770 4 1.553 2 4.707 299 9.724 LIGURIA 702 1.766 458 3.541 39 2.522 4 1.802 0 0 1.203 9.631 VALLE D'AOSTA 51 127 75 719 12 804 0 0 0 0 138 1.650 41.952 112.300 46.459 359.121 5.627 353.248 858 552.815 61 147.608 94.957 1.525.092 Total ITALY GWp 0,10 0,31 0,31 0,46 0,12 1,31 32