Operational guide
WEEE from PV - Operational procedures for PV modules
waste disposal on incentivized plants
GSE - Gestore dei Servizi Energetici SpA
WEEE FROM PV
The new regulation
The aim of the present guide is to provide technical and analytical insights on the new document published in GSE website the 14thof December, titled «Istruzioni operative per la gestione e lo smaltimento dei pannelli fotovoltaici incentivati (Operational instructions for waster management of modules of incentivized plants». The regulation follow the legislation introduced with the law decree no. 49/2014, the national implementation of 2012/19/UE directive on WEEE - Waste Electrical & Electronic Equipment.
The present analysis refers only to «professional» WEEE, that is, waste from PV modules that comes from plants bigger than 10 kWp.
The regulation defines,inter alia, a withholding quota as warranty deposit to cover costs for collection and disposal of modules from plants incentivized with Conto Energia mechanisms.Rules apply to the following incentive schemes:
• I Conto Energia (MD 28 July 2005 and DM 6 February 2006);
• II Conto Energia (MD 19 February 2007);
• III Conto Energia (MD 6 August 2010);
• IV Conto Energia (MD 5 May 2011): PV plants commissioned within 30thJune 2012 and concentrated PV plants (title IV);
• V Conto Energia (MD 5 July 2012): integrated PV plants with innovative characteristics and concentrated PV plants .
GSE specified that plants under IV Conto Energia, commissioned after 1stJuly 2012, and under V Conto Energia,with above-mentioned exceptions,are
not subject to the quota withholding. Such plants, in respect to the requirements of MD 5 May 2011 and MD 5 July 2012 as well as the “Disciplinare Tecnico” (http://www.gse.it/it/salastampa/GSE_Documenti/Disciplinare%20Requisti%20per%20i%20Consorzi%20FTV.pdf), have already joined a collective system or consortium able to guarantee the correct collection and disposal of modules at plant decommissioning. In some way, plants owners already payed for modules disposal buying modules from a “certified” producer.
In addition, GSE specified that plants not subsidized with Conto Energia are not subject to the new regulation. Therefore, plants under support mechanism such as, Scambio sul Posto, Prezzi Minimi Garantiti, SEU and fiscal deduction, are not subject to the quota withholding.
GSE reminds that, following law provisions, responsibility of WEEE management remains on the holder for the entire disposal process. Abandonment and uncontrolled deposit are forbidden.
WEEE FROM PV
The procedures
Holders of professional WEEE from PV modules have to deliver the waste,by means of individual system, collective system, consortium, subject qualified
for management of the specific EWC codes (European Waste Catalogue) or carrier, to an authorized treatment plants
(https://www.cdcraee.it/GetHome.pub_do).
Funding of collection, transportation, treatment, recycle and disposal activities are on:
• WEEE holder, for PV panels introduced in the market before 12thApril 2014 (Historical WEEE);
• WEEE producer, for PV panels introduced in the market before 12thApril 2014 (New WEEE);
In both cases the holder, which is the plant owner, is required to transfer the module to be disposed to a treatment plant. Within 6 months to the delivery, following document have to be submitted to GSE:
• dichiarazione di avvenuta consegna del RAEE derivante dal pannello fotovoltaico incentivato in Conto Energia appositamente compilata e firmata (declaration of WEEE delivery, compiled and signed);
• copia del formulario di identificazione dei rifiuti (FIR) (copy of waste identification catalogue);
• certificato di avvenuto trattamento/recupero rilasciato dall’impianto di trattamento (certificate of recycle/disposal released by the treatment plant).
After a documental check on the compliance of disposal procedures, GSE refund the withholded deposit.
In case of substitution, plant owner can ask the installer/distributor to collect the old panel following one-by-one procedure. In this case, documentation to be submitted is the same required in disposal procedure, with the addition of:
• copia dello schedario di carico e scarico rilasciato dall’installatore/distributore (ove previsto dalla norma) (copy of load/unload catalogue released by
installer/distributor).
Plant owner have to upload data of new model in GSE portal.After the documental check, GSE refund withholded deposit for disposed modules and retain the quota for the new module.
Procedures are managed through a dedicated web portal.
As a last resort, holder of professional WEEE can delegate GSE to manage the collection and disposal activities. In this case, GSE will use the withholded deposit to fulfill all required activities, with the possibility to ask additional quota in case the deposit will reveal to be not sufficient for the overall process.
WEEE FROM PV
The withholding quota
Withholding quota is equal to 10 €/panel for professional WEEE.
Such value can be updated by GSE on a yearly basis following considerations on, inter alia, potential improvement on PV module waste treatment process and technologies. Nevertheless, update mechanism has not been defined in a transparent and verifiable way. Additionally, procedures for partial reimbursement has not been defined in case withholded deposit exceed the updated value.
GSE specify that from the 15th year of tariff, withholding quota might be subject to plant-specific redetermination, in order to consider technical specification, distance from treatment plant and other variables.
The withholding quota is interest-bearing: in case of refunding the deposit will be paid increased with interest matured at market conditions. Despite the positive financial impact, at this point no clear indication has been provided to the definition of the market interest rate. It is clear how considering Euribor rather than 10 years government bond might originate significantly different interests.
The quota is withholded annually at the first FiT payment, starting from the 11thyear for the following 10. Annual quota is calculated with a formula
which define a decreasing trend for professional WEEE.
For illustrative purposes in the following table it can be found an estimate of the yearly quota for three 999 kWp PV plants, with module of 240 Wp, 220 Wp e 180 Wp.
For 1 MW plant the total deposit withholded in 10 year should be considered in a range from 40.000 € up to 55.000 €.The panel-based quota is clearly disadvantageous for plants with older generation modules, with lower efficiencies and thus lower peak power.
Module power Total deposit 11° year 12° year 13° year 14° year 15° year 16° year 17° year 18° year 19° year 20° year 240 Wp 41.625 € 7.568 € 6.811 € 6.055 € 5.298 € 4.541 € 3.784 € 3.027 € 2.270 € 1.514 € 757 € 220 Wp 45.409 € 8.256 € 7.431 € 6.605 € 5.779 € 4.954 € 4.128 € 3.302 € 2.477 € 1.651 € 826 € 180 Wp 55.500 € 10.091 € 9.082 € 8.073 € 7.064 € 6.055 € 5.045 € 4.036 € 3.027 € 2.018 € 1.009 €
WEEE FROM PV
Impacts and first considerations
The financial impact of the annual quota is not negligible.Annual quota will directly impact cash flows affecting debt sustainability and covenants as well as potential distribution to shareholders. However, in order to properly estimate financial impact, interest rate on deposit will need to be better defined by GSE.
It has been performed an analysis to estimate the financial impact for the three 1 MW plant of previous example, assuming they have been commissioned in 2011.
From our preliminary valuation, financial impact in terms of loss in present value of a 1 MW plants, assuming cost of equity of 8% and deposit interest of 3%, might reach up to 9.000 € (about 1% of equity present value). Of course, assuming higher cost of equity or lower deposit interest rate, financial loss will increase.
Such impact has been estimated assuming that annual quota will not be fiscally deducible, treated as a deferred revenues / receivable from GSE. Such aspect will need to be clarified by fiscal authorities. In case annual quota will be considered a deducible cost, financial impact will be lower, partially compensated by low taxes.
In conclusion, from our preliminary analysis of the regulations we have the following considerations:
• Update of withholding quota mechanism is not transparent and objectively defined, plus no procedure for partial reimbursement in case of decreasing quota are provided;
• There is no incentive for plants owners that might want to operate PV plants beyond the end of tariff right period (e.g. revamping);
• It has not been defined in a clear way the interest rate that will be used to capitalize the deposit;
• No difference for models technology and weigh has been considered (crystalline silicon, thin film, etc.);
•
Module power Total deposit Deposit + Interest @3% Delta Present Value @8% 240 Wp 41.625 € 50.366 € -6.481 € 220 Wp 45.409 € 54.945 € -7.070 € 180 Wp 55.500 € 67.155 € -8.641 €
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