Spain's UNEF Proposes Extending Additionality Standard for Data Center Renewable Energy to Six Years

en.Wedoany.com Reported - The Spanish Photovoltaic Union (Unión Española Fotovoltaica, UNEF) has submitted multiple proposed amendments to the draft royal decree on energy requirements for data centers. Its core demands include extending the additionality standard for renewable energy facilities supporting new data centers to six years, implementing time-matching requirements in phases, and requiring that the power supply certification mechanism retain greater flexibility. UNEF believes that the draft decree's approach of linking data center facility construction with renewable energy generation deployment is positive in direction, but that overly rigid certification rules could raise costs for electricity consumers and also hamper financing for new renewable energy projects and data center development.

Regarding the additionality standard, UNEF advocates extending the period applicable to renewable energy facilities supporting new data centers to six years. The association points out that too short a period would compress the supply of qualifying generation, making it harder to finance new projects and limiting the expansion of electricity-consuming facilities. Extending the period could also unlock existing renewable energy volumes, bringing into use electricity that currently cannot actually be generated due to technical or economic curtailment. UNEF also proposes that this period range could be gradually narrowed in the future.

On time matching, UNEF recommends that compliance requirements be implemented progressively. The association states that the 80% renewable energy coverage target is not incompatible with its position, but that compliance should initially be verified annually and then shift to quarterly matching. The relevant transitional arrangements should be written into the royal decree to provide predictability and legal certainty for investment.

Technical curtailment has also been included in UNEF's proposed amendments. The association requires that if renewable energy facilities supporting a data center are curtailed due to system technical constraints unrelated to their own operation, the electricity that could have been generated should be counted toward time-matching and additionality assessments. UNEF believes this would prevent constraints arising from grid capacity or grid development from being passed on as compliance obligations that producers and consumers cannot directly control.

Regarding power purchase agreements, UNEF calls for relaxing the types of renewable energy power purchase agreements (PPAs) that can be used to demonstrate compliance. The association believes that the more flexible the contracts, the more fully supply options can compete, and the easier it is for new renewable energy capacity to obtain financing; for data centers, it would also increase the options for locking in electricity over the long term.

Another UNEF recommendation is for regulation to guide hybrid configurations combining renewable energy facilities with energy storage. Combining photovoltaics with batteries or other technologies can not only extend the duration of renewable energy supply and reduce curtailment, but also improve the utilization of existing power infrastructure and enhance system flexibility.

UNEF emphasizes that the regulatory goal should be to have the additional electricity demand of data centers met mainly by renewable energy, while implementing the requirements within a framework that is both technically and economically feasible. UNEF General Manager José Donoso said: "If we intend to seize the opportunity of highly competitive electricity prices brought by photovoltaics to develop data centers, then the regulations established must be flexible and conducive to the profitability and financing of these facilities."