ROOFTOP SOLAR POWER PLANT

Since 15 November 2018, Indonesian Government represented by the Ministry of Energy and Mineral Resources (“MEMR”) has fully supported and provided facilities for the use of Solar Power Plant especially for Rooftop Solar Power Plant (known as PLTS Atap) (“Solar Power Plant”) by customers of PT Perusahaan Listrik Negara (Persero) (“PLN”), which evidenced by the issuance of Regulation of the Ministry of Energy and Mineral Resources Number 49 of 2018 of Utilization of Rooftop Solar-Power Systems by Customers of PLN (“Reg 49/2018”). Reg 49/2018 stipulates the use of Solar Power Plant for its own interest, which means for PLN customers who intend to install Solar Power Plant on their properties.

Regulations : 

Reg 49/2018 is one of the government’s efforts to achieve the target for the use of renewable energy, especially for Solar Power Plant for its own interest, which is included in the General Plan for National Energy (Rencana Umum Energi Nasional)

 


(“RUEN”). RUEN is targeting the use of solar energy in the amount of 6.5 GW in 2025 and 45 GW in 2050 or equal to 22% of the solar use potential in a total of 207,9 GW.

[1] Presidential Regulation Number 22 of 2017 of General Plan for National Energy, Appendix 1, page 64.


 

Reg 49/2018 has been amended twice in 2019, with the first amendment in the Regulation of the Ministry of Energy and Mineral Resources Number 13 of 2019, and the second amendment in the Regulation of Ministry of Energy and Mineral Resources Number 16 of 2019  (“Solar Power Plant Regulation”). Moreover, the government has also issued a Regulation of Ministry of Energy and Mineral Resources Number 49 of 2018 (“Reg 12/2019”) that regulates on the licensing requirements for Power Plant for its own interest, including but not limited to Solar Power Plant for its own interest.

Solar Rooftop

On November 2020, the government has issued Law Number 11 of 2020 on Job Creation (“Job Creation Law”), which amended some provisions on Law Number 30 of 2009 on Electricity (“Electricity Law”). In its amendment, the Job Creation Law abolished the licensing nomenclature for providing electricity for its own interests, which was previously named as operation license (known as izin operasi), amended to business license for the supply of electricity for its own interest. In principle, this is just a change in nomenclature to harmonize the name of licenses for carrying out electricity supply for its own interest. Job Creation Law also amended the government’s authority to issue operation license and operation worthiness certificate (known as sertifikat laik operasi), which was previously under the authority of the local government, become the central government authority under the Job Creation Law. As of today, Job Creation Law is not fully implemented yet considering this type of law is a brand-new law product in Indonesia that potentially needs time to implement the law. However, we are still waiting the government to issue the implementing regulation of the Job Creation Law in its amendment in Electricity Law.

Solar Power Plant Regulation has opened new challenges to Solar Power Plant business industry in Indonesia.

 

License Perspective

Based on the license perspective, Solar Power Plant companies and PLN customers are no longer need to be worried on their Solar Power Plant legality with notes that the Solar Power Plant companies and the PLN customers have to cooperate to fulfil the following requirements:

  1. PLN customer is required to obtain a PLN’s approval on the Solar Power Plant installation prior to starting the installation;
  2. For capacity below 500 kVa, PLN customer must submit a report to MEMR at least once;
  3. For capacity over 500 kVa, PLN customer must obtain a business license for supply of electricity for its own interest (izin operasi) and operation worthiness certificate in order to operate the Solar Power Plant.

Due to the dynamic changes in regulations related to Solar Power Plant in Indonesia, potentially causing different interpretations resulting in miscommunication between the stakeholders, i.e., the local PLN, the Local MEMR and the Solar Power Plant customers. In the licensing process implementation, this issue potentially will trouble PLN customers to obtain all the required licenses. Hopefully, this tiny issue will not lower the interest of the use of Solar Power Plant in Indonesia with notes that the government needs to adjust a few provisions in the next regulation amendment and also conduct massive outreach to all stakeholders in the regions.

 

Business Perspective

Solar Rooftop

Based on the business perspective, Solar Power Plant company and PLN customers have to limit their Solar Power Plant capacity which shall be limited to a maximum capacity of 100% of PLN connected power, otherwise PLN will not approve the Solar Power Plant installation. Although  there are limitations for the capacity of Solar Power Plant, on the other hand, PLN customers may conduct export-import energy activity with PLN. PLN customer who utilizes Solar Power Plant can sell the excess energy produced by Solar Power Plant to PLN, provided that PLN only pay for 65% of exported electricity e.g., if the excess energy exported to PLN is 100 kWh, then PLN will only pay for 65 kWh which will be calculated as a deduction from the customer’s electricity bill for the following month.

Before October 2019 After October 2019
Capacity Charge = inverter’s total capacity (kW) x 40 (hours) x electricity tariff Capacity Charge = inverter’s total capacity (kW) x 5 (hours) x electricity tariff

Since October 2019, the government has been lowering the capacity charge for industrial PLN customers which was regulated in the previous and current regulation as follow:

Furthermore, the above capacity charge is only applied for industrial PLN customers with on-grid Solar Power Plant, while non-industrial PLN and off-grid Solar Power Plant customer are exempted from capacity charge provision.

This new regulation that lowers the capacity charge certainly brings fresh air to industrial PLN customers who intend to utilize Solar Power Plant, which evidenced by the annual growth of Solar Power Plant utilization in Indonesia. By the end of 2018, the number of Solar Power Plant customers were 609 users, increasing to 1,580 customers by December 2019[2] and as of October 2020, 2,566 Solar Power Plant customers with total capacity of 18 MW.[3] In order to achieve RUEN’s target for the use of solar energy, the government will also impose an obligation to utilize Solar Power Plant with minimum 30% of the rooftop area of all government buildings in Indonesia and an obligation to utilize Solar Power Plant  with minimum  25% of luxury house’s rooftop, housing complex, apartments, and housing complexes through building construction license.[4]

 


[2] Institut for Essential Services Reform, “Diskusi Media: Dampak Pandemi COVID19 pada Sektor Kelistrikan Energi Terbarukan di Indonesia”, https://iesr.or.id/diskusi-media-dampak-pandemi-covid19-pada-sektor-kelistrikan-energi-terbarukan-di-indonesia” (accessed on 28 January 2021).

[3] Humas EBTKE, “Akselerasi Pengembangan PLTS Atap, Kejar Target Bauran EBT” https://ebtke.esdm.go.id/post/2020/11/20/2698/akselerasi.pengembangan.plts.atap.kejar.target.bauran.ebt?lang=en(accessed on 27 January 2021).

[4] Presidential Regulation Number 22 of 2017 of General Plan for National Energy, Appendix 1, page 79.

[5] Indonesia Clean Energy Development, “Proyek Listrik Surya Atap untuk Gedung Pemerintah dan
Fasilitas Umum di Aceh”, http://www.iced.or.id/id/indonesia-proyek-listrik-surya-atap-untuk-gedung-pemerintah-dan-fasilitas-umum-di-aceh/ (accessed on 27 January 2021).


 

On 2019, Central MEMR has issued MEMR Circular Letter Number 363/22/MEM.L/2019 to government agencies at the local and national levels to encourage the installation of Solar Power Plant in government office buildings, which aims to save fuel, reduce greenhouse gas (GHG) emissions and reduce government budget through saving electricity.[5] This circular letter is one of the government commitments to support the use of Solar Power Plant in Indonesia and, hopefully, the government will continue to issue relevant circular letters and even obligations to install Solar Power Plant on government buildings in Indonesia.

 

Reference : 

[1] Institut for Essential Services Reform, “Diskusi Media: Dampak Pandemi COVID19 pada Sektor Kelistrikan Energi Terbarukan di Indonesia”, https://iesr.or.id/diskusi-media-dampak-pandemi-covid19-pada-sektor-kelistrikan-energi-terbarukan-di-indonesia” (accessed on 28 January 2021).

[2]Humas EBTKE, “Akselerasi Pengembangan PLTS Atap, Kejar Target Bauran EBT” https://ebtke.esdm.go.id/post/2020/11/20/2698/akselerasi.pengembangan.plts.atap.kejar.target.bauran.ebt?lang=en (accessed on 27 January 2021).

[3] Presidential Regulation Number 22 of 2017 of General Plan for National Energy, Appendix 1, page 79.

[4] Aceh”, http://www.iced.or.id/id/indonesia-proyek-listrik-surya-atap-untuk-gedung-pemerintah-dan-fasilitas-umum-di-aceh/ (accessed on 27 January 2021).

[5] Indonesia Clean Energy Development, “Proyek Listrik Surya Atap untuk Gedung Pemerintah dan

Fasilitas Umum di Aceh”, http://www.iced.or.id/id/indonesia-proyek-listrik-surya-atap-untuk-gedung-pemerintah-dan-fasilitas-umum-di-aceh/ (accessed on 27 January 2021).

 

Author :

Syaugi Saleh, S.H.

As a leading Renewable Energy Service Company (RESCO) in Indonesia, focusing on solar energy system, SUN Energy continues to champion the importance of affordable, reliable, sustainable, and eco-friendly energy for all.

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