The Solar package I brings with it a large number of changes and improvements that are intended to drive forward the expansion of renewable energies in Germany. The Federal Cabinet has already approved the "Draft law to increase the expansion of photovoltaic energy generation". Mid-August 2023 decidedbut the consultations on the so-called Resilience bonus repeatedly delayed an agreement. (We reported on this in August 2023: What does Solar Package I mean for companies?)
The legislative process only picked up speed again when the traffic light coalition was formed on April 15, 2024 to were able to agree on the draft of Solar Package I. The ratifications by the Bundestag and the Bundesrat took place on April 26, 2024. All amendments are now being drafted and will later be sent to the Federal President for signature. It is then expected to come into force at the beginning / middle of May.
Solar Package I will have an impact on the EEG and other energy industry laws as well as other directives and regulations. In contrast to our August 2023 report on Solar Package I, the entire catalog of measures has now been finalized. Here is an overview of the most important changes:
Solar package I: General measures
No "resilience bonus". The domestic solar industry demanded a higher feed-in tariff for solar systems that use European components. This is no longer part of the solar package.
No individual sector targets. Each sector was originally intended to pursue its own climate target and be measured against it. According to Solar Package I, all sectors are now culminating in an overall CO₂ emissions value. If individual sectors do not achieve their climate targets, they must submit immediate programs for further reduction measures for the following year.
Constant monitoring of climate targets. The CO₂ emissions of the sectors are constantly or continuously monitored and not evaluated retrospectively as in the past, so that developments can be reacted to more quickly.
Climate targets become mandatory. Germany is committed to reducing greenhouse gas emissions by at least 65% by 2030 and by at least 88% by 2040 (compared to 1990). To this end, the subsidy conditions are to be improved and the subsidy rates for solar energy increased. The expansion target for photovoltaics by 2030 is at least 80 GW in Germany.
Ground-mounted photovoltaics: cutting red tape and faster procedures
Solar parksEligibility will be increased from 20 to 50 MWp and there will be easier approval procedures in "disadvantaged areas". To this end, the EU emergency regulation on the accelerated approval procedure, which was due to expire in 2024, will be extended by one year. However, subsidized solar parks must meet minimum nature conservation criteria. In addition, the tender volume will be gradually increased to 2,075 MW. Simplified use of public roads is to be applied for laying the necessary connection cables, similar to telecommunications cables or high-voltage lines. However, the planned obligation to tolerate installation on private land was not implemented due to constitutional concerns raised by the CDU/CSU and the FDP. Bundeswehr properties are also excluded from this.
Argi-PV & Solar carportsIn future, there will be a new segment in tenders in which the elevation will be taken into account with a higher maximum value. Until now, the more complex mounting systems (from 2.1 meters) of large solar carports, Argi-PV, Floating-PV or Mooren were not taken into account.
Measures for larger photovoltaic systems on roof surfaces
Certifications for systems with an installed system output of up to 500 kW: If such PV systems are operated with a maximum feed-in power of 270 kW, they are exempt from system certification in accordance with VDE-AR-N 4110 exempted. A system certificate is therefore no longer required from 135 kW, but only from 500 kW installed system output.
Systems up to 400 kW installed system capacityfor communal building supply: According to the EEG, all PV systems with an installed system output of between 100 and 400 kW must be directly marketed. If such larger systems on residential buildings are optimized for communal building supply, this obligation can be waived. They may then feed their surplus electricity into the public grid free of charge. This is often cheaper than commissioning a direct marketer for small residual quantities of electricity.
Higher feed-in tariffHigher feed-in tariffs are planned for solar installations between 40 kWp and 750 kWp. An additional subsidy of 1.5 cents per kW is being discussed in order to increase the attractiveness.
Lowering of the tender limit: Mandatory participation in auctions for commercial roofs is to be reduced from the current 1 MWp to 0.75 MWp. Such systems must therefore receive a market premium if they wish to claim a subsidy. The volume of PV roof tenders is to be roughly doubled.
Simplified repowering: The Repowering of PV systems and the direct marketing of solar power from rooftop and ground-mounted systems are to be simplified. Both types of systems will no longer lose their EEG remuneration entitlement as a result of such measures.
New regulations for electricity storage in solar package I
Electricity/battery storageThey are now not intended to serve exclusively as intermediate storage for renewable energies. Electricity/Battery storage are now also eligible for funding if they are used as intermediate storage for conventional or gray electricity from the grid. This so-called multi-use application is intended to help stabilize the electricity grid. The former "exclusivity principle" has therefore been overturned, meaning that all battery storage systems benefit from the EEG remuneration.
Measures for smaller PV systems
Simplified grid connection for systems up to 30 kWpSimplified grid connection for PV systems, which was previously permitted for systems up to 10.8 kWp, will apply to systems up to 30 kWp in future. For operators, this means that their solar system is deemed to be approved if they have registered their new system with the grid operator and have not received any feedback within four weeks. This also applies to tenants of residential buildings and adjacent outbuildings, provided that the electricity generated is not fed into the public grid. As a result, the billing options should also become less complicated.
PV systems up to 25 kWpYou can now also switch to direct marketing without remote control. Remote control is therefore no longer necessary for such small systems.
Balcony power plantsRegistration and operation of balcony power plants is to be simplified. Registration with the grid operator is no longer necessary and a simple registration in the master data register is sufficient. In addition, the permissible size will be increased from 600 to 800 watts and electricity meters no longer have to be replaced before installation.
New regulations for wind power plants in Solar Package I
The construction of wind power plants is also to be accelerated. To this end, the authorities are designating acceleration zones in accordance with European law. The German government hopes that this will speed up procedures and reduce bureaucracy for wind farms. Aircraft wind turbines will also no longer require a costly site assessment in future. Their eligibility for funding under the EEG will be assessed using new yield reference values.
Conclusion
Solar Package I represents a necessary and overdue step towards a sustainable energy future. The wide range of measures will drive forward the expansion of solar energy and the energy transition in Germany. With a clear objective and improved framework conditions, the law creates an incentive for investment in renewable energies and contributes to the reduction of CO₂ emissions.