German industry federation BDI has called for new renewable power sites subsidised under the country's renewable energies law (EEG), to equally qualify for guarantees of origin (GOO).
The demand forms part of a raft of recommendations the BDI published last week and addressed to the next federal government following general elections in September.
Under existing legislation, renewable sites receiving market premiums or feed-in tariffs (FiT) under the EEG cannot generate GOOs. The EEG justifies the "multiple sale ban" as power consumers already pay for the green quality through the EEG levy, which is levied on all non-exempted power consumption. But the BDI argued that since the EEG levy is now part-financed through general taxation, the justification for the ban is losing its stringency.
The economy and energy ministry has pledged to gradually reduce the EEG levy to zero over the next few years, by having it entirely funded through general taxation.
The ministry said this week that it is looking at the multiple sale ban in connection with "electricity labelling issues". Given the "high complexity" of the issue, and the "constitutional questions" it raises, the ministry said that a "deepened analysis" will be necessary, and that any conclusions will be drawn in the next parliamentary period.
A paper published last year by Wurzburg-based environmental and energy law foundation Stiftung Umweltenergierecht (SUER) suggests that generating GOOs for EEG sites could be designed as a voluntary option. Site operators would have their EER remuneration reduced by the market price of the GOO.
Limiting GOOs to new sites under only the EEG would have the advantage of avoiding a "flooding" of the European GOO market — this would be the case if existing sites could qualify, given Germany's large volume of renewable power generation, the paper said.
The EEG levy has been capped at €65/MWh this year — compared with the over €90/MWh it could have reached. The government will plough around €11bn into maintaining the cap in 2021, by pushing proceeds from the new domestic CO2 price in the heating and transport sectors, and from general taxation, into the EEG account.
EEG levy phase-out raises PV investment issues
The economy and energy ministry's plans to gradually push the EEG payments into general taxation will have an impact on investors' motivation, an energy expert warned.
SUER energy law expert Thorsten Mueller said that the high EEG levy has played a big role in incentivising investments in rooftop PV capacities for years, as this would allow companies to at least partially avoid paying the levy, in addition to receiving subsidies in the form of market premiums or FiTs. If the levy is financed through general taxation, part of the incentive will end, and it is unclear what the consequences could be, Mueller said. He suggested that demands by the opposition Green Party, to make rooftop PV mandatory at least on new and public buildings, could to an extent be viewed as a "compensation" for the EEG-levy phase-out, as it could trigger another wave of investment.
But plans to phase out the EEG levy should not be viewed as a sea change, Mueller said — the EEG levy is bound to decline anyway, as older renewables sites with their high FiTs gradually leave the system. But the government would be pulling forward the effect — and significantly so, Mueller said.
