Specific problems mentioned in this document are stated as follows:
1. Distinguishing between RSP and GSP projects:
- The current big obstacle is the definition of construction works and the basis for determining the type of RSP: in case of existing civil constructions (head offices, factories, schools, commercial centers, industrial zones, etc.), the provisions provided in Decision 13/2020/QD-TTg are met. However, many RSP projects with a capacity of less than 1MW are now implemented in the model of agricultural farms, then the basis for determining whether it is an RSP project or not is unclear and it requires specific guidance from the authorities.
- Determination of "photovoltaic panels installed on the roof" according to Decision 13/2020/QD-TTg is also difficult because the form of "roof" is very diverse in form of roof panels and roofing methods while the rules for determining the roof are not so specific. Many projects are installed on support frames located in garden land, agricultural land in the model of farming economy, the main purpose is to produce solar energy in order to enjoy the energy back fed tariff applicable for rooftop solar energy. Some projects use even solar panels as a roof cover in a proper space apart to get light for the animals and plants below, then install additional roofing sheets below the purlin to be recognized as RSP projects.
Due to the above unclear guidelines for determining a RSP project, it is difficult for Power Corporations/Power Companies in determining the correct application of electricity purchase and sale prices according to Decision No. 13/2020/QD-TTg.
1. A number of RSP systems are invested in clusters with a total capacity of over 1MW (while the capacity of each system is lower than 1MW) at the same location, owned by a single investor and connected to one point or more points. In this case, can they be considered as many RSP independent systems and power purchase agreements can be signed with the investor and will it require an electricity operating license?
2. In case an investor wishes to purchase a cluster of adjacent solar PV systems on the same land lot, with a total capacity of over 1MW. So, after the transfer, will the investor required to have an electricity operating license?
3. In case an investor wants to take advantage of the roof of office buildings, the operating house, the kitchen, the motel, the garage for employees, the factory, the warehouse, etc., within a solar power project, a hydropower, a thermal power plant site, etc., to invest in rooftop solar energy and propose to install separate meters, sign power purchase contracts for additional installed components such as RSP systems. In this case, can the energy purchase and sale be made separately?
4. Is solar energy business specified on the list of conditional business lines and does it require additional business registration procedures in accordance with the current Law on Investment?
5. Local regulations on tax administration, invoices for non-businesses (households, offices, schools, etc.); management of construction, land, etc., are also confusing the power companies when implementing the guidelines on the RSP.
7. Technical difficulties:
- Circular No. 39/2015/TT-BCT and Circular No. 30/2019/TT-BCT only regulate technical requirements for solar power plants connected to medium- voltage grids and solar power systems connected to low-voltage grids, but no technical requirements for the RSP systems connected to medium-voltage grids. If the solar power systems connected to the medium-voltage grids must apply technical requirements for solar power plants connected to medium-voltage or higher voltage grids according to the above Circulars, it will not be feasible and very difficult for investor in implementation.
- Technical standards for RSP: Currently, there are no regulations by state management agencies on technical standards for materials and equipment of solar power systems to ensure efficiency, quality of electricity as well as standards of safety for construction works, fire and explosion prevention for the RSP systems.
- There are no specific regulations on installation of switchgear, protective equipment, grounding, lightning protection for buildings, specifications on supervision, switching off/reducing generation power of RSP projects on order of the load dispatching commander in case of failure or overload of the power grid.
Recommendations from EVN to MOIT
In order to promote development of renewable energy in Vietnam, especially for rooftop solar power, EVN recommends and proposes the Ministry of Industry and Trade the following contents:
1. To consider and give guidance on specific criteria of distinction between RSP systems and grid-connected solar power systems, facilitating in determining the purchase price of energy from solar power systems in accordance with Decision No. 13/2020/QD-TTg of the Prime Minister.
2. Solar power systems with a capacity of up to 1MW, connected to a voltage level below 35kV, with solar panels mounted on a bracket system (with or without a roof), partially installed on the roof, partially on the ground; RSP systems in industrial parks which both buy energy from EVN for use and sell energy to EVN's grid through a 110 kV transformer shall be recognized as RSP to encourage all economic sectors to participate in RSP investment and development and EVN will sign contracts and pay electricity bills to such investors in accordance with Decision No. 13/QD-TTg of the Prime Minister.
3. For the model of agricultural farms combining solar power, an RSP with a capacity equal or lower than 1MW is recognized as RSP.
4. For agricultural farms with solar power systems installed with a total capacity higher than 1MW, MOIT is requested to guide on procedures and order for installation, connection agreement, acceptance of safety, fire and explosion, environmental protection, etc.
5. Power Corporations/Power Companies are permitted only to agree to connect and sign power purchase contracts for the RSP systems without overloading the 110kV transformer station in the locality.
6. To add regulations on technical requirements for RSP systems connected to medium-voltage grids in Circular No. 39/2015/TT-BCT and Circular No. 30/2019/TT-BCT in accordance with the reality and to ensure feasibility for investors.
7. To direct the Departments of Industry and Trade to unify regulations, create favorable conditions and encourage investors to participate in RSP installation.
RSP investors are highly expecting the mentioned problems as well as some proposals of EVN will be soon resolved and specifically instructed by MOIT, in addition, it is necessary to promote the effect of power resource enhancement in the coming period, in line with the Government's policy on encouraging development of renewable energy.