Since Shandong, a major province in new energy, issued the solicitation draft for the supporting document for the implementation of the first Document No. 136 on May 8th, multiple provinces have followed suit. On May 29th, Inner Mongolia issued an official reform implementation plan, which is the first officially implemented undertaking plan in the country.
With the efforts of various regions, the implementation of "Document No. 136" has accelerated. The advent of the full marketization of electricity prices is completely reshaping the survival logic of photovoltaic power generation:
Before the release of "Document No. 136", the income of photovoltaic power generation came from two parts: guaranteed procurement and market transactions; after "Document No. 136", the income of photovoltaic power generation still comes from two parts: mechanism electricity price income and market transactions.
In addition to the change in the names of income items, "Document No. 136" has greatly advanced the time for the full entry of photovoltaic power generation into the market, intensifying the fluctuations in the quantity and price of photovoltaic power generation. Both the electricity price and the electricity volume of new energy connected to the grid are facing a high degree of uncertainty, followed by the uncertainty of 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. Then, after the implementation of "Document No. 136", can photovoltaic power generation, especially incremental projects, smoothly pass through the narrow gate of full market entry?
The era of great changes in quantity and price fluctuations is coming
After the release of "Document No. 136", local supporting policies have followed closely. Currently, the official documents of Inner Mongolia, Shandong, and Guangdong have been issued, and provinces and regions such as Zhejiang, Jiangsu, Hunan, Hubei, and Liaoning have also successively solicited opinions from relevant units on the implementation plans.
After the implementation of "Document No. 136", the profit model of photovoltaic power generation will change significantly. In comparison, the impact of the new policy on incremental photovoltaic power generation projects is greater than that on existing projects.
"Document No. 136" emphasizes the continuity of the income of existing photovoltaic power generation projects. Therefore, the mechanism electricity prices stipulated in the local supporting policies for existing projects are basically aligned with the benchmark coal - fired electricity prices in each region, which is relatively considerable.
For example, the mechanism electricity price for existing projects in Inner Mongolia is 0.3035 yuan per kilowatt - hour, and the implementation period is the reasonable utilization hours in the full life cycle 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 tax, and the implementation period is based on the remaining reasonable utilization hours in the full life cycle. The mechanism electricity prices in both places fully comply with the requirements of "Document No. 136".
The mechanism electricity price for existing projects is the same as the original guaranteed procurement electricity price, which provides a relatively good guarantee for the income of existing projects. However, the problem with existing projects is that there is great uncertainty in the electricity volume of the market transaction part. In fact, with the rapid development of photovoltaic installations in various regions, the actual utilization rate of photovoltaic power generation projects has been significantly decreasing.
Statistics from the existing power stations held by a central power enterprise show that in the first quarter of 2025, the average power curtailment rate of new energy power stations reached 17%, and the power curtailment rates in all regions have increased. Among them, the average power curtailment rate in the northwest region basically reached 30 - 40%, and in some areas of Xinjiang, it even exceeded 50%; the power curtailment rate of some stations in regions such as Shandong and northern Jiangsu also reached 30%; the power curtailment rate in the southwest region began to approach 20%.
Compared with existing projects, incremental projects not only have difficulty in guaranteeing the mechanism electricity price, but also the mechanism electricity volume is uncertain.
In the local supporting policies, Shandong has not yet clarified the total scale of competitive electricity volume, the upper and lower limits of competition, and the implementation period of the mechanism electricity price for incremental projects. It only mentions that "in principle, the upper limit of the first - round competition shall not be higher than the average settlement price of this type of power source in the previous year", and "the lower limit of competition shall be reasonably determined by referring to the cost per kilowatt - hour (excluding income) converted from the advanced power station construction cost level (including only fixed costs).".
Guangdong has stated that the scale of competitive electricity volume will be announced before the competition. The upper limit of the declared proportion of mechanism electricity volume is linked to the proportion of mechanism electricity volume of existing projects and shall not be higher than 90%. The implementation period is 14 years for offshore wind power projects and 12 years for other new energy projects. The Guangdong plan does not directly state the upper and lower limits of the mechanism electricity price for incremental projects.
Based on the above local plans, it is currently clear that the uncertainties of incremental projects mainly include the following aspects:
First, the upper limit of the mechanism electricity price will be lower than that of existing projects (aligned with the benchmark coal - fired electricity price). If the lower limit of the mechanism electricity price for incremental projects is set very low, it is likely to induce low - price competition.
Second, the mechanism electricity volume of incremental projects will definitely decline in the long term. For example, the Guangdong plan clearly states that the upper limit of the declared proportion of mechanism electricity volume is linked to the proportion of mechanism electricity volume of existing projects and shall not be higher than 90%, which shows a downward trend year by year.
Third, regarding the implementation period of the mechanism electricity price and mechanism electricity volume, the implementation period of existing projects is basically the reasonable utilization hours in the full life cycle of photovoltaic power generation or 20 years after the project is put into operation. Shandong has not yet clarified the implementation period of the mechanism electricity price and mechanism electricity volume for incremental projects, while Guangdong has directly reduced it to 12 years. Currently, there is a consensus in the outside world that the implementation period of the mechanism electricity price and mechanism electricity volume for incremental projects will definitely show a significant downward trend.
In summary, combined with the decreasing electricity volume in the market transaction part year by year, the fluctuations in the quantity and price of incremental photovoltaic power generation projects will continue to deepen.
Distributed photovoltaic power generation needs to pay fees
In the future, in addition to the uncertainty of electricity volume and price, the impact of full market entry on distributed photovoltaics is that distributed photovoltaics will need to "pay" for power generation in the future.
The "Administrative Measures for the Development and Construction of Distributed Photovoltaic Power Generation" clearly states that "for distributed photovoltaic power generation projects that supply power to users through dedicated lines, both the power generation and power - using parties shall bear government - imposed funds and surcharges, system standby fees, policy - based cross - subsidies, etc. in accordance with relevant regulations, and fairly assume corresponding responsibilities and obligations."
"Natural person household - use distributed photovoltaics are exempt from government - imposed funds and surcharges and system standby capacity fees. For the self - generated and self - used electricity volume of distributed photovoltaic power generation, government - imposed funds and surcharges levied on electricity volume, such as the renewable energy price surcharge, are exempted."
In the future, distributed photovoltaic power stations need to share the costs of "government - imposed funds and surcharges, system standby fees, policy - based cross - subsidies, etc.". These costs have always been shared by coal - fired power, hydropower, nuclear power, and even centralized photovoltaics that entered the market earlier. In the future, except for natural person household - use photovoltaics, other distributed photovoltaics will participate in the sharing.
So, how much are these costs approximately? Under the same level, the transmission and distribution prices charged by power grid companies to entities such as coal - fired power, including cross - subsidies and government - imposed funds and surcharges, are generally above 0.2 yuan per kilowatt - hour. This does not include the complex and difficult - to - identify "system standby costs".
The so - called "system standby costs" mean that distributed photovoltaics are random, intermittent, and volatile, requiring standby power sources and auxiliary services such as peak regulation. When distributed photovoltaics cannot generate electricity or the generated electricity is insufficient, users still need to obtain electricity from other power sources. Since standby power sources (such as coal - fired power, hydropower, nuclear power, etc.) have costs, and the power grid's hardware infrastructure also requires standby costs, distributed photovoltaics need to participate in the sharing of these costs.
Currently, there are still questions about the "reasonable payment of relevant fees" for distributed photovoltaic projects. For the self - generated and self - used electricity volume of the project, does it need to pay fees? What specific fees need to be paid? According to what standards should the fees be paid? For example, how should the transmission and distribution fees for distributed photovoltaic projects be paid? Currently, the industry is calling for the exemption of transmission and distribution fees for self - generated and self - used electricity volume.
Of course, although there are disputes over some details, overall, it is just a matter of paying more or less. Distributed photovoltaics will no longer have the opportunity to "free - ride" as before. Paying for power generation is inevitable, which will further erode a part of the income.
The tug - of - war between reducing electricity prices and controlling costs
The policy - makers had anticipated the turbulent era that photovoltaic power generation would face when entering the market. The introduction of the mechanism electricity price and mechanism electricity volume policies is to stabilize photovoltaic power generation appropriately during the quantity and price fluctuations, allowing it to make a transition and avoid capsizing in the rough waves.
However, the question is, how many effective resources can the policy actually provide to help photovoltaic power generation get through the transition period and finally enter the era of full - scale market transactions?
"Document No. 136" clearly states that the funds for the mechanism electricity price come from the system operation fee. That is to say, providing a mechanism electricity price and mechanism electricity volume for photovoltaic power generation, this money will ultimately be reflected in the terminal electricity price. If the terminal electricity price rises too much, there will be strong reactions from all parties. Therefore, the mechanism electricity price and mechanism electricity volume are actually restricted by the pressure to control and reduce electricity prices.
For example, the supporting plan for "Document No. 136" in eastern Inner Mongolia stipulates that no new energy projects put into operation after June 1, 2025, will be included in the mechanism electricity volume for the time being, which means that new projects will participate in market competition with the full electricity volume. Will the northwestern provinces, which are rich in new energy, follow this policy of eastern Inner Mongolia in the future?
For the "Three North" regions, the new energy industry is still one of the pillars of economic and social development. Therefore, more favorable electricity price policies are needed compared with other provinces to attract new investments. Designing a certain proportion of mechanism electricity volume can help achieve this goal. However, at the same time, there are a large number of electricity - price - sensitive users in the "Three North" regions, which also makes the formulation of electricity price policies require extra caution.
In the eastern load - center provinces, although they are mostly large electricity - consuming provinces, under the comprehensive pressure of economic development, employment stability, and investment promotion, they are all seeking to reduce electricity prices.
For example, provinces such as Zhejiang, Jiangsu, Hunan, and Hubei have taken measures to stabilize and reduce electricity prices. At the press conference on Zhejiang's economic policies in 2025 held on January 23rd, Zhejiang proposed to strive to reduce the industrial and commercial electricity price in the province by 0.03 yuan per kilowatt - hour in 2025, with an obvious intention to promote investment promotion by reducing electricity prices.
Against the background of various regions seeking to stabilize and reduce electricity prices, the guarantee strength of the mechanism electricity price and mechanism electricity volume should not be overestimated.
On the one hand, the policy support for photovoltaic power generation cannot be too strong. On the other hand, the system cost of photovoltaic power generation is constantly rising.
The high system cost of photovoltaic power generation is because its power generation is random, intermittent, and volatile. Therefore, other power sources and even the power grid are needed to "accompany". In terms of power sources, some industry insiders have made a simple calculation. Originally, 1.2 kilowatts of coal - fired power could supply power to 1 kilowatt of users. However, in the new - type power system, "1.2 kilowatts of new energy + 1 kilowatt of coal - fired power" are needed to correspond to 1 kilowatt of users. In this way, the 1 - kilowatt coal - fired power that is usually not in operation needs to be frequently started and stopped to provide peak - regulation services for new energy.
For coal - fired power peak - regulation, when new energy cannot generate electricity, coal - fired power should generate at full capacity; when new energy generates weakly, coal - fired power should reduce its output; when new energy generates strongly, coal - fired power should be shut down for standby. During the start - stop and output - adjustment processes of the unit, not only does the overall utilization hours of coal - fired power decrease significantly, but also the cost of coal - fired power increases significantly.
In terms of the power grid, for example, distributed photovoltaics rely heavily on the construction of the distribution network, but the two major power grid companies have insufficient enthusiasm for distribution network construction. The reason is that the ratio of transmission and distribution prices between the high - voltage - level transmission network and the low - voltage - level distribution network is 7:3, but the construction cost ratio is the opposite, 3:7. In this situation, power grid enterprises lack the motivation to build the low - electricity - price, high - cost distribution network because it is "thankless".
Yu Yixin, an academician of the Chinese Academy of Engineering, once said bluntly that the fundamental contradiction of the distribution network is the contradiction between high construction costs and low utilization rates. To develop distributed photovoltaics, a large amount of money is spent on building the distribution network, but its utilization rate is very low, which is also one of the reasons for the high system cost of photovoltaic power generation.
In general, on the one hand, there is a need to stabilize and reduce electricity prices, while on the other hand, the cost of photovoltaic power generation is rising steadily. Under the squeeze of these two forces, how can we have overly high expectations for the mechanism electricity price and mechanism electricity volume after the full - scale entry of photovoltaic power generation into the market?
Photovoltaic power generation will definitely pass through the door of market entry in the end. However, this door is destined to be a "narrow door". Although the process is difficult and there are many challenges, after passing through, it will enter a new era - a new energy era with photovoltaics as the main energy source.
This article is from the WeChat public account
"Huaxia Energy Network", author: www.hxny.com, published by 36Kr with authorization.