Electricity from commercial photovoltaic systems is undoubtedly ecological and sustainable. If it is sold to third parties, it should be labeled and treated as such from the very first kilowatt hour. For this purpose Guarantees of origin (HKN) for the producer. These are stored in a digital register of guarantees of origin and redeemed when a sale is made.
For the operator and investors of a previously non-subsidized PV system this trade in guarantees of origin is a not insignificant Source of income. Especially when it comes to certifying PV electricity and issuing HKNs puts the brakes on bureaucracy in Germany on a massive scale. No wonder, since it dates back to a time when only a few coal, gas or nuclear power plants generated electricity. Even if the solar system is installed on the same site where one or more tenants consume the PV electricity directly, problems are already occurring.
Environmental assessments for guarantees of origin are cumbersome, time-consuming and costly
node.energy, partner of CUBE CONCEPTS, has now commented on this. "In practice, it is currently almost impossible to have the electricity generated certified via guarantees of origin. This electricity must therefore be declared as "gray electricity" based on the current electricity mix in Germany." The entire HKN system is still based on the assumption that the electricity generated always corresponds to the Detour via the public grid and a dealer reaches the end consumer.
With a tenant electricity model, however, the electricity is sold directly and directly to the tenant on site. The electricity seller's photovoltaic system can even be installed on the roof of the same property where the tenant consumes it. Nevertheless, the inflexible bureaucratic processes are complied with. In such an environmental assessment, the PV system and its components are checked and additionally compared with the registration. Matthias Karger, CEO of node.energy, explains: "An environmental assessment not only costs a disproportionate amount of time, but also makes applying for the guarantees of origin so urgently required by the industry absolutely unprofitable."
Automatic metering systems must be sufficient to generate guarantees of origin
Operators must have all components certified before and at the latest when commissioning a large photovoltaic system on a commercial property. In addition, commercial PV systems require extensive electronic monitoring, measuring and control units for electricity tax registration anyway. This is required by the redispatch procedure and was stipulated in the EEG. In a public statement, node.energy therefore calls on the BMWK, representing the opinion of around 1,000 operators of such systems, to abolish the requirement for environmental reports and replace it with simple proof of the amount of electricity generated using a calibrated measuring system.