On February 21, 2017, the Italian Energy Services Operator – GSE S.p.A., published on its website the Procedures for the management of maintenance and technological modernization of photovoltaic plants in operation to which feed in tariffs have been granted (the “Procedures”).
1. General principles.
The Procedures provide different rules for maintenance and technological modernization so-called “Material” and maintenance and technological modernization so-called “Not material”.
In case of “Material” interventions, or interventions which involve changes to the relevant characteristic data or the plant configuration, the Responsible Persons (Soggetti Responsabili) are required to submit to GSE appropriate communication of the implementation of the intervention within 60 days from its completion. In case of “Not material” interventions, however, there is no obligation of communication.
The Responsible Persons of power plants of 3 kW or below are required to notify the realization of maintenance and modernization only if the intervention has led to an additional power without feed in tariffs, the installation of storage systems of energy produced or replacement of photovoltaic modules.
2. “Material” Interventions
Among the interventions so called “material” GSE includes the following.
2.1. Moving the plant.
In general, a photovoltaic system with incentives cannot be moved from the “site” of first installation. If the need for a dislocation is resulting from acts of God, it is advisable to submit to GSE a request for a preliminary evaluation of the intervention.
2.2. Moving plant’s components.
Within the same site, it is allowed to move individual components or groups of components, main or secondary, provided that the full compliance with the requirements of the Decree under which the plant was allowed to incentives is maintained.
2.3. Substitution of Plant’s components.
The replacement of major components (modules and / or inverters) and secondary components of photovoltaic plants in operation is permitted with newer technologically advanced components. If the Responsible Persons are in possession of spare components, they can use them as long as they provide proof of the date of supply (eg through purchase invoices and transport documents) and evidence of the attribution of the same components to the system (for example, by copying the O&M contract). The newly installed components must be new (or refurbished), must not come from other plants incentivized in the Energy Bill and must comply with the requirements of the Fifth Energy Bill. In case of replacement of modules, to make possible the possible reconfiguration of generating strings, GSE admits increments the value of the nominal electric power within the following limits:
– Up to 5% for the interventions on PV Plants which nominal power does not exceed 20 kWp;
– up to 1% for operations on PV Plants which nominal power does exceeds 20 kWp.
Both for the permanent replacement or temporary replacement, the Responsible Persons shall provide the GSE evidence of the final destination of the parts removed from the system.
2.4. Removal of PV modules.
The removal (decommissioning) of photovoltaic modules is always possible, and determines a reduction of the nominal power of the PV system, which, according to the decision of the Responsible Persons, may be temporary or permanent. In the event of permanent decommissioning, the Responsible Persons must send appropriate notification to the GSE and update the information recorded on Gaudì Terna system.
2.5. Interventions which change the construction of the civil buildings in which the system is installed.
As a consequence of modifications on the civil buildings where the system is installed, the mode of installation of the system itself can be affected. To the extent that such changes involve a different classification system, they could determine the remodeling of the initially recognized tariffs, the loss of any awards or bonuses or even the loss of the right to receive incentives.
2.6. Variations of the electrical configuration.
It happens with any installation work of electronic devices, such as optimizers and regenerators, change in the connection point or change in the energy network in the sale arrangements produced by the plant and / or the commercial system of exploitation of the same. These interventions are considered “material” when the relevant legislation has subjected the access to incentives or recognition of higher feed in tariffs, increases or premiums, particularly with reference to the sale scheme to the grid of the energy produced by the PV Plant (total or partial sale) and / or to the enhancement of sale regime (Ritiro Dedicato/Scambio sul Posto) adopted by the Responsible Persons.
2.7. Upgrades without incentives.
In case of interventions aimed at increasing the aggregate peak power of subsidized photovoltaic plants at the point of delivery to the grid, through the installation of modules and inverters, it will be necessary that:
- at the end of the intervention, the PV Plant is equipped with suitable measuring devices that allow to detect, separately the electric energy produced by the stimulated plant portion and that produced by the portion of the system not promoted;
- the revamping work is registered on the Terna portal Gaudì, in accordance with the provisions of the Grid Code, by creating:
– A new section of the plant and a new production unit, if the system before the upgrade intervention was only composed of one subsidized section with an all-inclusive tariff (tariffa omnicomprensiva);
– A new production unit if, before the upgrade, the system consisted of sections with a feed in tariff different than the all-inclusive tariff.
2.8. Installation of energy storage systems.
Key principles in the field of installation of energy storage systems are contained in the document named “Technical rules for the implementation of the provisions relating to the integration of electricity storage systems into the national electricity system pursuant to Resolution 574/2014/R/EEL” (Regole tecniche per l’attuazione delle disposizioni relative all’integrazione di sistemi di accumulo di energia elettrica nel sistema elettrico nazionale ai sensi della Deliberazione 574/2014/R/EEL).