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The German government wants to make renewable energies less bureaucratic and more popular – but the devil is still in the detail.

After months of delays, Solar Package I is set to pass through the Bundestag and Bundesrat in a fast-track procedure on Friday. This should significantly accelerate the expansion of solar energy once again and make it more attractive – including for tenants and balcony power plant operators. However, the latter will have to be careful even after the law has been passed.

After the coalition of the SPD, Greens and FDP had been arguing about individual passages of the Solar Package I legislation since December, they finally announced its completion just over a week ago. One of the major changes to the cabinet version is that the Solar Package I will not include subsidies for photovoltaic manufacturers. The FDP prevailed here, as well as on the question of who must tolerate the laying of power lines for renewable energy systems across their land. While the cabinet version still planned for this to apply to all owners in order to facilitate necessary measures for the energy infrastructure, this is now limited to public sector properties and not all of them either: the German Armed Forces are to be expressly excluded. The FDP, like the CDU and CSU, cited constitutional concerns about the planned far-reaching encroachment on private property rights as an argument.

Plug-in solar systems: waiting for legally compliant 800 watts despite solar package

In recent years, many suppliers of inverters have already provided the option of using software to switch from the upper socket feed-in limit previously permitted in Germany to the internationally standard 800 volt-amperes (VA). In regulatory terms, VA is the relevant measure of all things. This is because legislation and operational safety are concerned with how much electricity is fed into the grid and at what strength.

For most plug-in solar systems, the solar package now removes the restriction to 600 volt-amperes, which was previously the legal limit. Instead, the government draft and the coalition's agreement introduce a separate device class with a maximum limit of 800 volt-amperes and a maximum installed output of 2 kilowatts for the Renewable Energy Sources Act. However, the will of the legislator alone is not enough to provide definitive clarity for users. A new standard should create reliability here. The changes to the Renewable Energy Sources Act are rather an additional classification, which is primarily intended to reduce bureaucratic obligations.

For operators of a plug-in solar system, this will make many things easier in future. The Federal Network Agency had already simplified the registration procedure at the beginning of April, and with Solar Package I this will now be streamlined once again - from the time it comes into force, balcony power plants will no longer have to be registered with the grid operator by law, but only in the market master data register [1] with the supervisory authority. In the case of a full feed-in as an EEG system into the general electricity grid, however, nothing will change, including all associated obligations.

According to a spokesperson for the Federal Network Agency, however, "the legal situation that applied at the time of commissioning applies in principle." This means that anyone who has already plugged in their small power plant must legally follow the old rules here too – anyone who is still considering purchasing and connecting should wait for the formal entry into force, which is due to take place in just a few days. This is because the Bundesrat will probably also wave through the Solar Package I on Friday immediately after it has been passed by the Bundestag, after which the Federal President will have to officially sign it off – the changes will then come into force once they have been published in the Federal Law Gazette.

Beginning of May: New draft standard for plug-in solar systems

However, even after the solar package, an important technical standard is still missing for the legally unobjectionable feed-in of electricity for personal consumption from small solar systems with more than 600 volt-amperes: for months, experts have been discussing which technical requirements plug-in solar systems must meet for safe operation, even with higher feed-in power. Until now, manufacturers have had to provide individual proof that their components are safe – and if various components are combined to form a system, an electrician would in principle have to approve the plug-in solar system. Otherwise, operators may be exposed to safety and liability risks.

The responsible committee at the German Commission for Electrical Engineering (DKE) presented an initial proposal for a product standard last year, which was met with many objections. The standard would reverse the presumption rule: a plug-in solar system would be considered safe if it complied with the standard. A second draft is now to be published on May 3, which can also be commented on. This should address key questions, such as whether an earthing contact plug is sufficiently safe or whether a Wieland plug should be mandatory.

This process will then take another two months before the standard is adopted and manufacturers can refer to it. For consumers, this would provide simple clarity, especially for complete packages. In reality, however, this increase in the limit is only likely to help significantly increase the actual yield in very good conditions - but the cost of the changeover for many providers is also low. In reality, however, this hardly plays a role: 800 VA has long since established itself on the market. The Federal Network Agency expressly warns that "for systems with the option of switching between different power values, the highest switchable power is always relevant". Anyone whose system could feed in more would therefore also fall outside the new plug-in solar rules of the EEG.

Ferraris meter can stay for now and run backwards

However, another regulation will make things much easier for the plug-in solar world: the installation of a bidirectional meter, legally referred to as a "modern measuring system", or a smart meter, a so-called "intelligent measuring system", no longer has to take place before commissioning. Old induction meters may also continue to be used for the time being. Some of these meters will then run backwards - until they are replaced. This is because the modern variants must be available everywhere by 2032: up to 6,000 kWh annual consumption, a bidirectional meter will be sufficient; for higher consumption, it must be an "iMSys". Anyone who wants to avoid a smart meter for the foreseeable future despite such higher consumption could now be tempted to reduce their nominal consumption at the Ferraris meter using the power of the sun.

Even with the new regulations, the proper commissioning of balcony power plants will therefore remain a bureaucratic miracle for most citizens for the time being, which in reality is likely to be simply ignored. This is because the sales figures for balcony solar systems are at an extremely high level. 270,000 plug-in solar devices were officially registered with the Federal Network Agency [2] in 2023. In addition, there is a high number of unregistered micro power plants.

Storage systems can switch in and out of EEG funding

Battery storage systems also play a major role in the solar package. They are becoming increasingly popular, but also lead to some delimitation difficulties. This is because if they can also draw electricity from the general grid and store it temporarily, it does not automatically come from renewable energy sources. As a result, systems with storage facilities that not only store green electricity but also so-called grey electricity have so far generally been completely excluded from EEG funding - in other words, there is no feed-in tariff for solar power temporarily stored in them. The coalition has recently made further changes here.

There will be two options in future. The first: in future, battery storage systems can either be registered as part of renewable energy systems for two months and only be fed by them. Or in the other months as simple storage systems for better control of the overall grid-available electricity mix. Storage system operators can then switch between the models up to five times a year and still remain eligible for financial support under the Renewable Energy Sources Act for the periods in which they are filled with locally produced green electricity. The legislator then considers the uncertainty that there may also be residual fossil electricity in the storage facility at any given time to be negligible - the EEG remuneration is ultimately calculated according to the amount of electricity in the respective period.

The second option is to switch more quickly, without any frequency restrictions. However, this model still has a major catch: it must be technically ensured that only electricity from renewable sources can be stored during registered renewable periods. And immediately before the switch, the storage facilities must be demonstrably and extensively emptied. It is still unclear what this will look like in practice, and the legislators are aware of this: practical solutions still need to be found for these regulations, according to the explanatory notes to the regulations. The Federal Network Agency and the Federal Office for Information Security still have to develop specifications, including for the parameterization of the storage software, how empty a storage system must and may be at the time of replacement without discharging the battery excessively.

Getting on the roof should also be worthwhile for owners and tenants

New regulations for systems on apartment buildings could prove to be particularly relevant for tenants, houses with several owners and connected buildings such as rows of terraced houses. With shared building supply, the operator can become an additional electricity supplier for the users in the building - in addition to their normal electricity provider. Heise online has already explained [3] exactly how this works. Solar Package I now clarifies the rules for this: Electricity generated in this way may - the agreement makes this explicitly clear once again - also be stored temporarily. The latest amendments also clarify that the place of consumption does not have to be exactly where the electricity was generated - for example, wall boxes in garages or other connected components are also permitted. For both users and operators, shared building supply is an attractive model that can quickly pay off for everyone involved.

Also relevant for tenant electricity models: the minimum term should be two years in future. It is also clarified: Tenant electricity supply and tenancy agreement are not linked - however, the tenant electricity agreement will end automatically on the day the tenant moves out.

Airstream power plants as a beacon of hope

A currently not yet fully developed and non-solar technology has also been immortalized in Solar Package I during the consultations: Aero-wind power plants, known as onshore wind turbines in energy law terms. For over a decade, great hopes have been pinned on variants of this type of electricity generation: a flying object, usually a kite or similar to a glider, moves with the wind at a height of several hundred meters. In the process, a cable is pulled further and further upwards - and its pull generates electricity at a ground station, which could provide remarkable amounts of energy with considerably less construction effort. Once the pull is exhausted, the flying object descends and the "power cycle" starts all over again. Sufficient wind blows almost constantly in the air layers above the normal rotary-wing wind turbines. Such airborne wind turbines are currently still being tested, but they were given extensive regulations in the solar package shortly before the deadline. For example, they are no longer required to submit a site survey prior to construction - and a flat-rate reference value is set for the yield they achieve so that they are eligible for subsidies under the Renewable Energy Sources Act.

(dahe [4])

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Links in diesem Artikel:
[1] https://www.marktstammdatenregister.de/MaStR
[2] https://www.heise.de/news/Zahl-der-Balkonkraftwerke-wuchs-2023-stark-9589856.html?from-en=1
[3] https://www.heise.de/hintergrund/Gemeinschaftliche-Gebaeudeversorgung-Reform-fuer-PV-Strom-erklaert-9533873.html?from-en=1
[4] mailto:dahe@heise.de

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