EAG's photovoltaic subsidies - only well-intentioned?
After repeated delays, the regulation for the renewable investment subsidies was finalised. The basis is the Renewable Energy Expansion Act (EAG). In 2022, around 300 million euros will be available to support photovoltaics, hydropower, wind power and biomass. The first funding round for photovoltaics started on 21 April.
Subsidy played off against subsidy?
The application for the photovoltaic subsidy no longer runs through the climate and energy fund as before, but through the OeMAG. For the past 14 years, Kommunalkredit Public Consulting has processed the funding applications. The end came abruptly: since the end of April, anyone looking for the "Klien" funding has only found the information that the funds have been used up and the program is closed. There is or was no transitional period. The funding pot for systems that have just been completed or those that are under construction is closed, although the Klien funding track should have run until December 31, 2022. It remains to be seen whether goodwill and interim solutions will be found.
But before we talk everything down at this point, let's take a closer look at the new regulation.
What is new and good about the subsidy for photovoltaics?
One thing is certain: the funding pot has never been that big! 240 million euros are available for photovoltaic systems and electricity storage. While in 2020 systems with a capacity of 350 megawatts were installed, in 2021 it was about 450 megawatts. With the new funding, 1,000 megawatts of capacity would be possible.
Another good thing is that the period between applying for funding and mandatory completion has been extended. Previously it was twelve weeks. Now it is six months, with an option for a three-month extension. And that will probably be needed, because neither craftsmen nor parts are easy and quick to come by.
There is also a change in the area of permits: In the previous funding scheme, these could be presented within the aforementioned period of twelve weeks. Now they have to be available at the time of application. In any case, the bureaucratic hurdles will not be eased.
The size limit of 200 kWp has also been dropped with the new regulation. Previously, the subsidy was only available for photovoltaic systems with up to 200 kWp, but there is no longer a size limit in the Renewable Energy Sources Act. The investment subsidy is also awarded for plants with a size of up to 1,000 kWp.
Photovoltaics on buildings, sealed surfaces and open land
In the new EAEC, the area potential is extended to agriculturally used areas or those in grassland.
Traditional ground-mounted systems still receive a 25% discount on the subsidy, but exceptions are provided for (see §6 (2) of the ordinance).
For example, photovoltaic systems on fences, car park roofs, landfills, mining sites and railway facilities are put on an equal footing with conventional rooftop systems and systems on paved surfaces such as asphalt and concrete. This allows for exciting solutions on former industrial and commercial sites, for example, but the real potential in this area is very small.
The most radical innovation, however, is that photovoltaic systems are subsidised on land previously used for agriculture and on grassland. Prior to this, a rededication is necessary. The decision on dedication remains with the municipalities and provinces. The 25-percent subsidy reduction for ground-mounted systems is thus a desired steering measure in the direction of roof-mounted systems and photovoltaics on already sealed surfaces.
The criticism of the EAEC lies in the detail
As is so often the case, the really critical aspects lie in the details. Fritz Binder-Krieglstein has very skilfully summed this up in his article on Ökonews . He even describes the ordinance on photovoltaic subsidies as "a bad joke". Somehow we have to agree with him here. After all, what is the point of all the good approaches if the bottom line is only half measures with no practical relevance?
All the official channels have to be completed before the project is commissioned. How should these official channels be accounted for by the companies? Should or even must they make advance payments?
Four different funding calls and several categories are planned. In addition, there are different quantities per year and different call durations - the confusion is perfect.
Storage systems are only subsidised for new installations or extensions, and all customers who already have a photovoltaic system and cannot extend it do not receive any storage subsidies. Storage expansions are no longer subsidised at all.
A new inverter is also not subsidised, because it does not count as an extension. At least one photovoltaic module must be added.
Construction and completion of plants within six months of the subsidy contract (even with an extension of three months) is simply illusory given the current delivery and waiting times!
Small photovoltaic systems cost more per kWp than large ones. Unfortunately, this is not taken into account in the current scale of subsidies. The "small ones" are getting the short end of the stick - once again.
And now? What can we conclude? Unfortunately, once again a good idea was put into practice in a semi-optimal way. The time would have been right and sufficient to really become an international role model here. While in many places the farsightedness of politicians is still a long time coming, we at my-PV recommend the following steps.
1. Hold on and get every possible subsidy, even if it is not decisive.
2. Have all suitable areas of your roof filled with photovoltaic modules.
3. Maximise self-consumption and your degree of self-sufficiency with solutions from my-PV and suitable storage media.
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