Hello Mr. Fell,
I'm writing to suggest several simplifications to the photovoltaic EEG rules for your consideration.
- The use of a defined cut-off to characterize Heavy Electricity users should be avoided because it encourages gaming. Consider having a system where all usage up to X gigawatt hours is subject to the full EEG surcharge. A second usage category between X and Y would be subject to a reduced surcharge. All usage beyond Y could be exempt or subject to a minimal surcharge.
- You could use similar rules for the EEG payments. As things stand you have three payment Steps based on installed capacity: a < 10 kW bracket, a 10 to 40 kW bracket and a 40 to 1000 kW bracket. Your brackets should be based on electricity. Your Step 1 payment would be for the first 10 MWh per year of backfeed regardless of system size. Your Step 2 payment would be paid on the next 30 MWh of backfeed. All remaining production would get the Step 3 rate.
- Alternatively, the EEG payments for Step 1 and 2 could be consolidated because they are already so close to each other. Then you'd only have two payment steps: Step 1 for all excess production up to 40 MWh and Step 2 for everything else. Simple.
- As far as I can tell the rooftop vs. ground mount distinction should be eliminated.
Good luck with your good work.