We often hear people who have either recently moved to Spain, or who are visiting from other Northern European countries, say that they are surprised to see so few houses with solar panels here when there is so much sunshine. It does seem strange that in countries such as Germany or the UK, for example, with much lower solar radiation than Spain, there are many more photovoltaic self-consumption installations. Some industry experts, including the PV industry association (UNEF) put the blame for this on the Royal Decree 900/2015 saying that it sets unnecessary administrative barriers and that it is discriminative against PV.
What is the Royal Decree (RD) 900/2015? This is the regulation in Spain that governs the renewable energy facilities that produce electricity supply for self-consumption. In other words, it aims at regulating the solar electricity system that you may wish to install at your home to generate your own electricity, as well as regulating larger commercial installations.
One of the reasons for its unpopularity, was that the RD 900/2015 introduced what has become known as the “sun tax”. However, there is a lot of confusion and misinformation about the sun tax and it does not in fact apply to consumers who intend to consume the electricity generated by their own system and who have an installation of less than 10kW. The RD 900/2015 establishes two kinds of models:
Type 1 Supply with Self-Consumption. This is where the electricity generated is less than 100kW and is only generated for self-consumption. If there is any surplus electricity, there is no payment for this – the electricity is generated on a “use it or lose it” basis.
Type 2 Generation with Self-Consumption. This is where any excess electricity generated from the system can be exported to the grid and payment is made for it. For this kind of installation, a grid access charge is made (sun tax) but with exceptions, one of which is for systems less than 10kW. This means that you can have a grid connected system at home and send any excess electricity that you do not use yourself back to the grid for which you will receive payment and so long as the system is less than 10kW, you will not pay the “sun tax”.
As well as introducing restrictions on self-consumption, the RD is also seen as having raised institutional barriers which may prevent a user generating his or her own electricity. The requirement that the solar electricity installation must be approved by the electricity provider and the user must register as a self-consumer are viewed as barriers. Failure to register, or noncompliance with the rules means that the user and the installer may be subject to fines which can range from €6000 to €60000.
Whilst this can help explain why you don’t see more PV panels on people’s houses currently here in Spain, hopefully the situation will change in future. Each autonomous community does have a certain amount of control over its own destiny and some regions are keen to promote renewable energy solutions. There are also companies who can help you ensure that your new PV system is approved, installed and registered correctly and that you receive payment for any excess electricity you send back to the grid. With the cost of electricity continuing to rise, solar is a good investment.