The Amend of the MEMR Regulation on Rooftop Solar PV Has the Potential to Undermine the Interest of the Residential Market

Jakarta, 6 January 2023 – The Ministry of Energy and Mineral Resources (MEMR) is revising the Minister of Energy and Mineral Resources Regulation No. 26/2021 concerning rooftop solar PV connected to the power supply grid owned by the holders of power supply business licence for the public interest (Izin Usaha Penyediaan Tenaga Listrik untuk Kepentingan Umum) or commonly referred to as IUPTLU. This change is intended to address the difficulties with installing rooftop solar PV that has occurred in the last year since the ministerial regulation was officially issued.

In the public hearing that was held on Friday, January 6 2023, the Ministry of Energy and Mineral Resources presented substance changes, including there is no limit to the maximum capacity of 100% installed capacity of a rooftop solar power plant, but based on system quota, electricity exports are abolished (no longer counted as bill deduction), capacity costs for industrial customers is nullified (no longer 5 hours), and the transition rules for existing customers are enforced within a certain time.

“Since it was promulgated in August 2021, MEMR Reg No. 26/2021 practically does not work because PLN refuses to implement it. As a result, the government’s target of 450 MWp of additional solar PV capacity in 2022 was not achieved. This revision seems to be a meeting point between the government’s interests and PLN and accommodates PLN’s interests in reducing the potential for electricity exports from solar PV users due to net-metering regulations considering the overcapacity conditions. But AESI regrets that this accommodation has the potential to reduce the economy and interest in residential rooftop solar PV, which has the potential to grow,” said Fabby Tumiwa, Chairman of the Indonesian Solar Energy Association (AESI) in Jakarta.

Since January 2022, 10-15% rooftop solar PV capacity restrictions have occurred in various regions in Indonesia for customers, both residential on the kilowatt scale to industrial customers with capacities on the megawatt scale. This capacity limitation discombobulated the provisions of MEMR Reg No. 26/2021 (maximum 100% installed electric power) and reduced potential customers’ interest to adopt rooftop solar.

In the proposed changes to the substance of the Ministerial Regulation, the capacity limit of up to 100% will not be reinstated but will be based on a quota system with first come, first serve. This change directly responds to capacity restrictions occurring in the field. However, the technical determination of system quotas needs to be clarified, especially concerning renewable energy development plans in the regions. In addition, the period for setting quotas per 5 years is too long due to the dynamics of electricity supply technology.

AESI supports the determination of quotas by taking into account the reliability of the IUPTLU electricity network but proposes that capacity quotas be determined every 2 years, with a review conducted every six months.

Eradicating net metering by eliminating the export of electricity to the PLN grid, which applies to all customer categories without exception, will have major impacts on the residential (household) market. The current economic level of rooftop solar PV is still influenced by net metering because the household load profile is mostly at night. The absence of exports will lessen the reduction in household electricity bills and extend the payback period for purchasing a rooftop solar system, making rooftop solar unattractive for household customers.

“A market survey conducted by the Institute for Essential Services Reform (IESR) in 7 provinces in Indonesia in 2019 – 2021 shows that the economy of solar PV is an important and determining factor for residential customers to use rooftop solar. The majority of respondents also want to get savings of at least 50% and clear and fast installation procedures,” added Marlistya Citraningrum, Manager of the IESR Sustainable Energy Access Program.

The National Strategic Project (PSN) for rooftop solar PV with a target of 3.6 GW in 2025 and achieving the 23% renewable energy target requires community participation. With just a 20% market share for R2 and R3 class customers (3,500 VA and above), there is a potential of 400,000 households throughout Indonesia – equivalent to 1.2 GWp of rooftop solar if each instals a minimum of 3 kWp.

The impact on residential rooftop PV will reduce the benefits of creating green jobs through small-scale solar PV installation businesses targeting the household market segment, which has started to grow since 2018. With the potential for adoption spread across various cities in Indonesia, the residential rooftop solar PV market also contributes to the opening of green jobs, for example, technicians and installers, and the growth of MSME rooftop solar PV installers. If the latest revision of the MEMR regulation is passed with the currently proposed clauses, the growth and opportunities of these green businesses will certainly be hampered. AESI and IESR recommend that net metering be implemented for residential customers with export-import calculations which can be discussed later.

In the public hearing, there were many questions raised by solar energy developers (developers), installers (EPC companies), local governments, and rooftop PV users.

AESI assesses that instead of supporting the renewable energy transition, the revision of this regulation will hinder the addition of rooftop PV. For this reason, AESI proposes that the export of electricity from residential customers is still permitted on condition that the installed capacity is 100% of the customer’s power. This provision is reviewed within 5 years or after the residential rooftop PV reaches a cumulative 5% of the total installed capacity of generators in the system. 

The Ministry of Energy and Mineral Resources has opened a channel for submitting input for this process until January 13, 2023.

India Targeting 200 GW of Renewable Energy in 2022: Is Indonesia Following? 

Jakarta, September 16, 2020 – Since the 2000s, the Indian government has shown its seriousness in developing renewable energy to meet domestic energy needs. Determined, the Indian government is ambitiously targeting the development of the renewable energy plant of 200 GW or 42 percent of total electricity generation by 2022.

The Indian government has been formulating an ecosystem to support the achievement of renewable energy targets in its policies and programs, such as the development of solar parks and solar cities. As a result, India began to show its position as a country that only had 10 MW of solar power plants in 2010, now reaching 88 GW in 2020.

Indian government’s achievement in accelerating renewable energy is something worthies that the Indonesian government should follow. To more understand the successful recipe of solar power plant development in India, the Institute for Essential Services Reform (IESR) conducted an online seminar entitled Bringing Indonesia to the Gigawatt Club: India Made It, and So Can We. This seminar brought together solar energy industry professionals from India to share their experiences and lessons learned. Kanika Chawla, Director of the Center for Energy Finance CEEW, India, and Kushagra Nardan, Co-Founder & President of SunSource Energy, India, were the speakers, meanwhile, as the responders were Harris Yahya as Director of Various New and Renewable Energy, Ministry of Energy and Mineral Resources, Cita Dewi, EVP of Renewable Energy at the State Electricity Company (PLN), Yohanes Bambang Sumaryo, Indonesian Solar Energy Association (Asosiasi Energi Solar Indonesia – AESI), and Fabby Tumiwa, Executive Director of IESR.

Kanika explained that one of the best practices of the Indian government is to establish a renewable energy market by profiling in detail its long-term targets. It has attracted many investors, both domestic and international, to participate because they can project their industries in the next five or ten years. Moreover, many investors are interested in involving, making price negotiations more competitive and cheaper.

“Solar and wind tariffs have seen an aggressive decline around the world but also in India more specifically, and more steeply, I would say it is very much based on the large market, the market design. If at first India was a price taker, now it is a price maker,” she said.

However, Kanika explains that along the way, the market identified various risks, such as the offtake risk (payment delays), curtailment risks where the grid unable to absorb the amount of energy produced, foreign currency exchange, land acquisition, and construction, and policies inconsistencies or changes in in-laws.

Kushagra added that the Indian government mitigated these risks by implementing clear and consistent policies, both in terms of the scale of utility to net metering. Responding to the conducive environment of renewable energy in India, his company has installed rooftop solar power plants in commercial buildings such as 10 MW in textile factories in northern India, floating solar in the oil company, and rooftop solar project at the Airport in New Delhi.

Furthermore, Kushagra also shared several steps that the Indian government has taken to realize the target of renewable energy development, for example, the existence of a specialized government body to achieve the National Solar Mission with Solar Energy Corporation Of India Limited (SECI) at the national level and various agencies at the state level.

Reviewing again, Fabby Tumiwa emphasized some important notes that deserve the attention of the Indonesian government to achieve the renewable energy mix target of 23 percent with 6.5 GW coming from solar power plants by 2025.

“Indonesia needs the support of legislation and regulations in implementing renewable energy targets into more concrete programs and projects. As in India, with its Renewable Purchase Obligation (RPO) stipulated in the Act, each state is required to set renewable energy targets as a priority to be achieved. Besides, the Indian government provides supporting funding through the National Clean Energy and Environmental Fund (NCEEF) and financial assistance to project developers and optimization of public funds. Also, they create various schemes for on-grid and off-grid solar. The bidding process has also become more competitive in the format of a large-scale reverse auction, which is effective and can attract low solar price bids,” he emphasized.

The procurement process in the form of a reverse auction that is well designed, carried out efficiently and transparently, and on a large scale is one of the supporting factors in driving the competitiveness of solar power generation and results in a much lower generation price compared to fossil energy. Also, Fabby explained that the role of state governments in India is essential in the acquisition of land for the solar park scheme. The Indian government is acting directly to provide the area and build complementary infrastructure. In Indonesia, the provision of land is often constrained by permits and inadequate location, which then causes land acquisition consuming a large portion of the capital expenditure for solar power plant development.

“Regulations related to renewable energy in the form of presidential regulations are being processed. No government body specifically deals with renewable energy. Of course, there is no RPO policy in Indonesia. I think this policy is good to emulate, ” he explained.

Concerning the funding and investment issues of solar power plants, the Indonesian government is also establishing communication with international organizations. Harris also sees the problem of land acquisition as an ongoing problem in Indonesia. He hopes that in the future, he can discuss with the ministries and organizations in Indonesia, so it will be easier for investors to develop their solar power plant business. Meanwhile, both Cita and Yumarno expressed their appreciation for India’s success in managing the various risks that exist and providing proper solutions for achieving its renewable energy targets. Cita said that PLN is open to conduct deeper discussions with India in adopting learning steps for Indonesia’s progress in the field of renewable energy.

Presentation materials

KC - India's energy transition IESR -15Sep20


Kushagra Nandan- SunSource Energy