We already have the new order of the CE Implementa. The Order TED/764/2024, of July 22, published in the BOE. And now the Resolution of July 26th, of the IDAE where the CE Implementa V and VI (for projects of less and more than 1 million euros) is called. The proposal is aimed at promoting investments in green infrastructure and the participation of actors not traditionally involved in the energy sector. On the definition of RECs and CCEs (Renewable Energy Communities and Citizen Energy Communities) nothing new under the sun. It is again insisted, as it could not be otherwise, on the open and voluntary character (art 2.6. and 2.7); as well as that they must “provide environmental, economic or social benefits to their partners or members or to the local areas where they operate, rather than financial gain.” Effective control is also described with the aim of preventing a single actor from being able to control the EC. The draft again talks about multicomponent projects: those presenting eligible actions from two or more action areas among the following action areas: Electric renewable energies and storage, Thermal renewable energies, Energy Efficiency and Sustainable Mobility.
Attention, the minimum of five partners or members is again mentioned, without taking into account that one of the partners is a local entity – the option had been considered that when there was a local entity, this requirement of five partners would not be considered as long as a framework of open and voluntary participation was guaranteed. It is explained that public entities may only be beneficiaries of this aid if they meet the conditions either to be a CCE or to be a CER. But this means that if public entities are not able to meet these conditions, they will have to set up a separate legal entity -and for this a transposition that includes the recognition of the ECs as public interest entities would be very appropriate to facilitate their participation-.
Eligible investments will include investments that increase the level of environmental protection resulting from the promotion of renewable electric and thermal energy, energy efficiency, electric mobility and demand management; the costs of execution of the works, including civil works and/or assembly of the installations; investment in equipment and materials related to the actions, including the installation or updating of any electrical element, including the transformer, connection works to the distribution network, sectioning and transformation centers and medium voltage connection; the accumulation and demand of electrical or thermal energy of consumer installations supplied by the project object of the aid, which help to optimize management and production; the development costs of management tools for the governance and/or administration of the energy community or the communication costs related to the fulfillment of the obligations of information and publicity. Eligible costs Eligible costs are the costs of managing the application and justification of the implementation of the aid actions, including the drafting of reports and other documentation required for the application and justification. They may reach up to 7% of the eligible cost, and may not exceed 50,000 euros (previously 10,000 euros).
The good… It is important to point out how far the aid goes: It is highly positive that it can be increased by 20 percentage points for beneficiaries in which both the number of partners or vulnerable members and the energy destined to them exceeds 50%. It is also very interesting that thermal renewables and electromobility can reach an aid intensity of 80% and 60%, thus emphasizing the two vectors that can accelerate electrification. On a positive note, it is worth mentioning that in terms of mobility, greater emphasis is placed on sharing (shared bicycles or shared electric vehicles (provided they are owned by the energy community) and the implementation of electric vehicle recharging infrastructure (previously, there was talk of implementing electric vehicle recharging infrastructure and acquiring “plug-in” electric vehicles and fuel cell vehicles for shared mobility). The most debatable aspect… The most debatable aspect is the evaluation criteria. In this order, the reduction in maximum aid is the most important factor, far ahead of the multicomponent factor, the governance model, the social impact or the value chain. Many of us would have liked the multicomponent elements, support for vulnerability, or participation mechanisms to end up weighing more. Now it weighs up to 70 points when in the previous order the range was between 0 and 15 points. The risk is that with this criterion, innovative projects will weigh less, and the one with the muscle to lower the reduction on the aid will weigh more. Before, the weight of the reduction of the aid did not weigh so much. Regarding the amount of aid, it should be recalled that the order fixes. Renewable electricity: up to 60% aid intensity; storage up to 30%; thermal renewables up to 80%; energy efficiency up to 30%; sustainable mobility up to 60% and demand-side management up to 40%. Regarding the July 26th call resolution published by IDAE of the EC Implementa 5 (projects of less than 1 million) and 6 (projects of more than 1 million) to which 30 million euros and 90 million euros are allocated. The need for the assets in which the investment is made to be owned by the energy community is maintained. The administrative feasibility will give 10 points (attention, projects that do not require a connection point will comply with this requirement), while the reduction on the maximum aid will be up to 70 points. Regarding renewable electric energies, it is established that the actions must have a storage system behind the meter to be eligible for subsidies. In other words, a clear signal is given in favor of storage, which must be able to store a minimum of 0.5 hour of the power of the electrical RES-E actions. For storage systems to be eligible, the condition must be that the storage is not directly connected to the grid, but will be part of the renewable energy and/or sustainable mobility installation. Storage facilities that do not exceed a ratio of nominal installed storage capacity versus generation power of 5 kWh/kW will be considered eligible. Regarding thermal renewables it should be noted that the actions will be centralized systems in collective residential buildings with more than five neighbors or in which a community of neighbors has been constituted, including premises belonging to SMEs or small businesses that belong to the energy community, as well as in publicly owned buildings of local entities that are part of the energy community (attention, this gives an opportunity for public buildings where the municipality participates in the community). In energy rehabilitation, the building must be owned by the community or a public building, something that will greatly hinder this action by the communities. And in sustainable mobility, it will be possible to promote and develop recharging points, and the comparison of electric vehicles as long as they are destined to shared electric mobility.
And now it’s time to get to work.The new call for applications will come out soon.And at SAMSO we are ready. Ready to define proposals. To promote them. To accompany them. To make it possible for the energy communities to be the new actor that is called for in the directives.
We help you to make it happen.
