Die Durchsetzung der „Verordnung Nr. 136“ wird beschleunigt. Kann die Photovoltaikbranche erfolgreich die „enge Pforte“ des Marktzutritts passieren?

Since May 8th, when Shandong Province, an important province for renewable energy, issued the first draft of a supporting document for the implementation of Regulation No. 136, several provinces have followed suit one after another. On May 29th, Inner Mongolia issued a formal reform implementation plan, which is the first formally implemented takeover plan in the whole country.

With the efforts of different regions, the implementation of "Regulation No. 136" is accelerating. The beginning of the full marketization of electricity prices completely reconstructs the survival logic of photovoltaic power generation:

Before the release of "Regulation No. 136", the income from photovoltaic power generation came from two parts: guaranteed acquisition and market transactions; after "Regulation No. 136", the income from photovoltaic power generation still comes from two parts: mechanism electricity price income and market transactions.

Besides the change in income items, "Regulation No. 136" has greatly advanced the time for the full market entry of photovoltaic power generation and intensified the quantity and price changes of photovoltaic power generation. Both the electricity price and the electricity quantity of renewable energy at grid - connection face high uncertainty, which in turn brings uncertainty to investment returns.

Whether future photovoltaic power plants can survive depends on the overall environment of the electricity market and their ability to participate in market transactions. So, let's ask ourselves whether photovoltaic power generation, especially incremental projects, can successfully pass through the narrow gateway of full market entry after the implementation of "Regulation No. 136"?

The era of quantity and price uncertainty has begun

After the release of "Regulation No. 136", the supporting regional policies quickly followed. So far, the formal documents of Inner Mongolia, Shandong and Guangdong have been issued, and provinces such as Zhejiang, Jiangsu, Hunan, Hubei and Liaoning have successively solicited opinions on the implementation plans from relevant units.

After the implementation of "Regulation No. 136", the profit model of photovoltaic power generation will change significantly. In comparison, the new policy has a greater impact on incremental photovoltaic projects than on existing projects.

"Regulation No. 136" emphasizes that the income of existing photovoltaic projects must be continuous. Therefore, the mechanism electricity price set by regional supporting policies for existing projects usually corresponds to the regional reference electricity price for coal - fired power plants, which is relatively attractive.

For example, the mechanism electricity price for existing projects in Inner Mongolia is 0.3035 yuan per kilowatt - hour, and the validity period is the number of hours of rational use over the entire service life or 20 years after the project is put into operation; the mechanism electricity price for existing projects in Shandong is 0.3949 yuan per kilowatt - hour including taxes, and the validity period is determined according to the remaining number of hours of rational use over the entire service life. The mechanism electricity prices in both regions fully meet the requirements of "Regulation No. 136".

The mechanism electricity price for existing projects is consistent with the original guaranteed acquisition electricity price, which makes the income of existing projects relatively secure. However, the problem with existing projects is that the electricity quantity in the market transaction part is highly uncertain. In fact, the actual utilization rate of photovoltaic projects has dropped significantly because photovoltaic power plants in different regions have expanded rapidly.

Statistical data from the existing power plants of a central power enterprise show that the average electricity curtailment rate of renewable energy power plants in the first quarter of 2025 reached 17%, and the electricity curtailment rate increased in all regions. In particular, the average electricity curtailment rate in Northwest China basically reached 30 - 40%, and in some parts of Xinjiang even exceeded 50%; the electricity curtailment rate in some power plants in regions such as Shandong and Northern Jiangsu even reached 30%; the electricity curtailment rate in Southwest China began to approach 20%.

Compared with existing projects, not only is it difficult to guarantee the mechanism electricity price for incremental projects, but also the mechanism electricity quantity is uncertain.

In the supporting plans of different regions, Shandong has not yet determined the total quantity of bid - offered electricity, the upper and lower limits of bids, and the validity period of the mechanism electricity price for incremental projects. It only mentions that "in principle, the upper limit of the first bid should not be higher than the average settlement price of the same type of power generation in the previous year" and that "the lower limit of the bid should be reasonably determined based on the cost level of advanced power plants (including only fixed costs) and the costs converted into electricity quantity (excluding profit)."

Guangdong has stated that the quantity of bid - offered electricity will be announced before the bid, that the upper limit of the registration proportion of the mechanism electricity quantity is consistent with the proportion of the mechanism electricity quantity of existing projects and is not higher than 90%, and that the validity period is 14 years for offshore wind power projects and 12 years for other renewable energy projects. Guangdong's plan does not directly specify the upper and lower limits of the mechanism electricity price for incremental projects.

In summary, from the above regional plans, it can be seen that the uncertainties of incremental projects mainly lie in the following aspects:

First, the upper limit of the mechanism electricity price will be lower than the mechanism electricity price for existing projects (which corresponds to the reference electricity price for coal - fired power plants). If the lower limit of the mechanism electricity price for incremental projects is set too low, it can easily lead to price competition.

Second, the mechanism electricity quantity of incremental projects will surely decline in the long term. For example, Guangdong's plan clearly stipulates that the upper limit of the registration proportion of the mechanism electricity quantity is consistent with the proportion of the mechanism electricity quantity of existing projects and is not higher than 90%, which is a trend of annual decline.

Third, it concerns the validity period of the mechanism electricity price and the mechanism electricity quantity. The validity period for existing projects is usually the number of hours of rational use over the entire service life of the photovoltaic power plant or 20 years after the project is put into operation. The validity period of the mechanism electricity price and the mechanism electricity quantity for incremental projects has not been determined in Shandong, while Guangdong has directly reduced it to 12 years. Currently, there is a broad consensus that the validity period of the mechanism electricity price and the mechanism electricity quantity for incremental projects will surely decline significantly.

In summary, the quantity and price uncertainty of incremental photovoltaic projects will be further intensified due to the annual decline in the electricity quantity in the market transaction part.

Distributed photovoltaic power plants have to pay fees

In the future, the full market entry of photovoltaic power generation will not only bring uncertainty to electricity prices and electricity quantities but also affect distributed photovoltaic power generation - distributed photovoltaic power plants will have to pay "fees" for power generation in the future.

The "Administrative Measures for the Development and Construction of Distributed Photovoltaic Projects" clearly states: "If a distributed photovoltaic project builds a private power supply line to supply power to a consumer, both the power generator and the power consumer must, in accordance with relevant regulations, bear state funds and surcharges, system reserve fees, political cross - subsidies, etc., and fairly share the corresponding responsibilities and obligations.

"Residential households with distributed photovoltaic power generation are exempt from state funds and surcharges as well as system reserve fees. For the self - consumption electricity quantity of a distributed photovoltaic project, state funds and surcharges calculated based on the electricity quantity, such as the surcharge for renewable energy, are exempt."

In the future, distributed photovoltaic power plants must share costs such as "state funds and surcharges, system reserve fees, political cross - subsidies, etc." These costs have long been shared by coal - fired power plants, hydropower plants, nuclear power plants, and even centralized photovoltaic power plants that entered the market earlier. In the future, all distributed photovoltaic power plants, except for residential households with photovoltaic power plants, must participate in cost - sharing.

How much are these costs approximately? At the same tariff, the grid - use and power - transmission price that the grid enterprise charges from coal - fired power plants and other power generators, including cross - subsidies and state funds and surcharges, is usually over 0.2 yuan per kilowatt - hour. This does not even include the complicated and difficult - to - determine "system reserve fees".

The so - called "system reserve fees" arise because distributed photovoltaic power generation is random, intermittent, and fluctuating. Reserve power sources are needed, and auxiliary services such as load regulation must be provided. When a distributed photovoltaic project cannot generate electricity or the generated electricity quantity is insufficient, consumers must obtain electricity from other power sources. The reserve power sources (such as coal - fired power plants, hydropower plants, nuclear power plants, etc.) incur costs, and the hardware infrastructure of the grid also has to bear reserve costs. Therefore, distributed photovoltaic power plants must participate in sharing these costs.

Currently, there are still questions regarding the "reasonable payment of relevant fees" for distributed photovoltaic projects. Does the self - consumption electricity quantity of a project need to pay fees? What specific fees need to be paid? According to what criteria should the fees be paid? For example, how should the grid - use and power - transmission costs of a distributed photovoltaic project be paid? Currently, industry representatives demand that no grid - use and power - transmission costs should be paid for the self - consumption electricity quantity.

Naturally, although there are disputes in some details, overall, it is only a question of whether to pay more or less fees. Distributed photovoltaic power generation no longer has the opportunity to "get by" as before. Paying fees for power generation is inevitable, which will further reduce a part of the profit.

The conflict between reducing electricity prices and controlling costs

The uncertainty that photovoltaic power generation faces during market entry was foreseen by policymakers in advance. The introduction of the policy of mechanism electricity price and mechanism electricity quantity is intended to stabilize photovoltaic power generation a little during the era of quantity and price uncertainty and enable a transition period so that it does not sink in the waves.

The problem, however, is how many effective resources the policy can provide to help photovoltaic power generation through the transition period and finally lead it into the era of full market participation?

"Regulation No. 136" clearly states that the money for the mechanism electricity price comes from system operation costs. That is to say, if photovoltaic power generation is granted a mechanism electricity price and a mechanism electricity quantity, this amount will ultimately be passed on to the end - consumer electricity price. If the end - consumer electricity price rises too much, the reaction from all parties will be very strong. Therefore, the mechanism electricity price and the mechanism electricity quantity are actually restricted by the pressure to control and reduce electricity prices.

For example, the supporting plan for "Regulation No. 136" in the eastern region of Inner Mongolia stipulates that no renewable energy projects put into operation after June 1, 2025, will be included in the mechanism electricity quantity. This means that new projects must participate in market competition with their entire electricity quantity. Will the northwestern provinces, which are rich in renewable energy, follow this policy of the eastern region of Inner Mongolia in the future?

For the "Three - North" regions (Northeast, North, and Northwest China), the renewable energy industry is still one of the pillars of economic and social development. Therefore, more favorable electricity price policies are required compared to other provinces to attract new investments. Setting a certain proportion of the mechanism electricity quantity can help achieve this goal. At the same time, there are many electricity - price - sensitive consumers in large numbers and sizes in the "Three - North" regions, which means that electricity price policies must be formulated with special caution.

The eastern provinces, which are load centers, are usually electricity - consuming provinces. But under the combined pressure of economic promotion, employment security, and investment promotion, they all strive to reduce electricity prices without exception.

For example, provinces such as Zhejiang, Jiangsu, Hunan, and Hubei have taken measures to stabilize and reduce electricity prices. At the press conference on economic policies of Zhejiang in 2025 on January 23rd, Zhejiang aimed to reduce the industrial electricity price in the whole province by 0.03 yuan per kilowatt - hour in 2025. The intention to attract investments by reducing electricity prices is very obvious.

In view of the efforts of different regions to stabilize and reduce electricity prices, one should not have overly high expectations for the strength of the guarantee of the mechanism electricity price and the mechanism electricity quantity.

On the one hand, the state's support for photovoltaic power generation cannot be too great. On the other hand, the system costs of photovoltaic power generation are constantly rising.

The system costs of photovoltaic power generation are high because power generation is random, intermittent, and fluctuating. Therefore, other power sources and even the grid have to "keep up". Regarding power sources, an industry expert has made a simple calculation. Previously, a 1...