Looking forward to the upcoming publication of the procedures provided by art. 30 of DM 23 June 2016, on 9 August 2016, GSE has published on its website a note providing the reference framework for the management of maintenance and technological modernization of photovoltaic plants in Energy Bill.
Below is a brief review of main principles that, as of today, are the reference in the assessment of the communications submitted to GSE even before 30 June 2016.
Eligibility limits in case of work in incentive in Energy Bill.
In general, it is allowed to perform maintenance and modernization of photovoltaic plants in Energy Bill, provided that such measures comply with the requirements of the ministerial decrees under which the plants were admitted to incentives and that such interventions do not cause undue increases of national incentive spending.
Given that, in case of replacement of modules or inverters, the newly installed components must be new or reconditioned, the novelty is that, to avoid possible technical problems and make possible an eventual reconfiguration of generating strings, value increments of the nominal electric power may be admitted, provided that content within the following limits:
- up to 5% in the case of plants with a total output not exceeding 20 kW;
- up to 1% in the cases of plants with a total output exceeding 20 KW.
These limits refer to the total maximum increase obtained, also as a result of several interventions, throughout the period of recognition of incentives.
To cope with repair work, the Responsible Persons may use spare parts already in their possession or ownership of third parties, provided that the newly installed components comply with the relevant legislation.
Reporting requirements in case of work in incentive in Energy Bill.
The GSE provides a different discipline according to which the interventions of maintenance and modernization modify or not the characteristic data of the installations or configuration.
In the case of interventions that change the characteristic data or configuration, the Responsible Persons of the installations concerned will be required to communicate with the GSE a notice of the amendment within sixty days of completion of the intervention, the GSE reserving the right to initiate an administrative procedure verification in accordance with Law n. 241/90.
The same communication burden is applicable in the event of interventions that do not alter the characteristic data or configuration, with respect to which, however, the GSE sees no need to perform any verification process.
By way of example, the following types of interventions are considered not to alter the characteristic data or configuration:
- displacement of the inverter and electric minor components;
- replacement, removal, new installation of smaller electrical components when this does not lead to changes in the transfer system in network energy produced by the plant;
- ordinary intervention on the support structures of the modules, or building structures on which the system was installed.
Except in the case of inclusion in the electrical configuration of an energy storage system, no obligation to report is provided for plants with a nominal power of less than or equal to 3 kWp in regime of “Scambio sul Posto”.
Without prejudice to the reporting requirements, the possibility of submitting a request for intervention to the GSE preliminary assessment is limited to cases of maintenance work made necessary due to supervening grounds of public interest, acts of God, extraordinary and exceptional events or by events not depending on the will of the Responsible Person.
It is understood that, as a result of the fulfillment of reporting requirements, the Responsible Persons must also fulfill the payment of investigative costs as per Ministerial Decree of 24 December 2014.
Main differences with the previous legislation.
Waiting to better assess the scope, significant appears the introduction of the possibility to use percentage limits of increase in the value of the nominal power output.
It also seems essential the distancing from the previously applicable rules with regard to the reporting requirements. According to Technical Document Reference published last May 1, 2015, and then suspended, after a few weeks of good standing, on July 9, 2015, in fact, the Responsible Persons were required to submit such a start work communication and a notice of completion of work, while the verification process would have been initiated by the GSE only at the completion of works.
The hope is that, beyond any judgment on the value of the legal framework, the forthcoming procedures may set certain rules, such as to favor really a efficient management of PV systems in Energy Bill.