Unintelligible Documents and Unsettled Electricity Prices: The "Confusion" of New Energy Investment Under Document No. 136

Distance Notice on Deepening the Market-Oriented Reform of New Energy On-Grid Electricity Prices and Promoting the High-Quality Development of New Energy [NDPRC (2025) No. 136] More than two weeks have passed since the release of Document No. 136, which has caused a collective "major shock" to the new energy industry, including wind power, photovoltaics, and energy storage, lasting 15 days.
A person in charge of an industry think tank said that recently they have received several waves of business leaders from central and state-owned enterprises, and their questions are basically concentrated on: How to calculate the future new energy power plants? What should be used as the reference standard for investment decisions?
The inability to proceed with investment decisions has caused a corresponding chain reaction. "The industrial supporting facilities and other fees agreed upon with the local government are now suspended, waiting for the project to be recalculated before making a decision." A business leader of a central enterprise's provincial company told PV people.
The inability to "price" new energy projects is a huge challenge for most private enterprises and resource fees in the industry. Some private enterprises said: "For projects that have just received indicators or have already negotiated EPC contracts, but cannot be connected to the grid before June 1, renegotiation is required after the new policy. Due to the inability to determine the rate of return, these projects must be prepared for the inability to trade in the short term."
This is the norm for the new energy industry, especially for those engaged in development and investment business, since the release of Document No. 136.
Currently, The industry's biggest confusion about Document No. 136 lies in the inability to understand the document and the unclear new energy trading electricity price behind it. The uncertain electricity price completely subverts the existing calculation model, and many projects have been put on "hold".
 

Unintelligible Documents and Unsettled Electricity Prices

As a guiding policy for new energy to participate in electricity market transactions, Document No. 136 is a set of electricity market rules combined with the development of new energy. However, for new energy development and investment businesses, Document No. 136 is a cross-industry document, with terms such as mechanism electricity price, long-term transactions, spot markets, and volume and price reporting being unfamiliar vocabulary.
" I recognize every word, but when put together, I still can't summarize what specific impact it will have on new energy power stations ." An industry insider sighed.
"After reading the new document, there are still many unclear points. For example, the document requires that "existing projects should be properly connected with existing policies related to the scale of power generation with guarantees by various places." Does this "existing policy" refer to the policies currently implemented in various provinces, or will there be adjustments? How is the mechanism electricity price calculated? How will the mechanism electricity price of each province be determined? What will be the impact on the new energy on-grid electricity price? Is there a reference range?" A person in charge of a certain power design institute told PV people.
"After the release of Document No. 136, many owners came to consult the design institute's opinions. Previously, project calculations were handled by the design institute, But now we can't give any suggestions, there are too many unpredictable boundaries. ”
In addition to the bewilderment of investors, many provincial energy authorities also find the document quite difficult to understand. According to PV people, in order to better promote the rules and details of the document, the price authorities held a policy promotion meeting in Jinan, Shandong last week, providing a detailed interpretation of the details of Document No. 136 so that each province can better understand the spirit of the document.
PV people also learned that recently, in related business areas, from distributed to centralized, from photovoltaics to energy storage, from groups to provincial companies, from investment enterprises to equipment manufacturers, they are all inviting or looking for relevant policy-making departments of the government, electricity market professionals, etc., to help them analyze and understand "Document No. 136." Many local companies of central state-owned power enterprises have specifically organized thematic seminars to study the impact and countermeasures of "Document No. 136."
In addition to the unclear electricity price and inability to calculate the return, the industry's Another major confusion about "Document No. 136" is concentrated in the implementation level 。
"Document No. 136" was formulated by the National Development and Reform Commission and the National Energy Administration. It is a macro-oriented framework policy document that stipulates the general direction of new energy on-grid electricity entering the market for trading and provides a basic framework for electricity trading price settlement. However, the specific electricity price settlement model and details are delegated to local provinces - "Each province should formulate and implement a specific plan before the end of 2025."
The answers to many questions will have to wait until provincial regulations are introduced.
 

Response Paths Under Document No. 136 ‍‍‍‍‍‍‍‍‍‍‍‍‍‍‍‍‍‍‍

Faced with the new policy, in addition to constantly trying to understand the possible impact of the new policy, the industry is also seeking ways to deal with the many uncertainties.
A relevant person from a central enterprise told PV people that the group's current First measure Is to sort out the progress of existing projects, first ensuring that fast-progressing existing photovoltaic projects can be connected to the grid before June 1, and wind power projects may be ensured to be connected to the grid before December 30.
From the spirit of Document No. 136, existing projects will most likely still implement the relevant documents previously issued by various provinces, and will not cause major fluctuations in income, This is relatively clear at present, so rushing to install before May 31 is still the top priority for the industry 。
Secondly In the face of adjustments to electricity price policies, the first reaction of many investment enterprises is "how to pass the review"? "Investment enterprises will not stop investing because of the new policy. How to invest? How to make decisions is the focus of the next step, especially how to replace the previous investment return model to make investment decisions? "
According to PV people, some companies are currently considering controlling the initial investment cost in different provinces to reduce the foreseeable electricity price risk. "Since the electricity price has become floating, the higher the investment cost, the higher the future income risk, so the initial investment cost must be controlled." An industry insider introduced.
Under the current general decline in equipment prices, the industry generally expects that the control of power plant investment costs The first "fire" will be directed at resource fees, and reducing non-technical costs will become an important impact of Document No. 136 on the industry 。
On the other hand In the face of the reality of electricity price fluctuations, investment enterprises are also looking for a standard that may be used as a reference for investment decisions in the future, such as Electricity cost Compared with the uncertain electricity price, the electricity cost can relatively calculate a range.
 

Cost per kilowatt-hour formula
In the calculation context of cost per kilowatt-hour, power generation is crucial, and this is also a point worth paying attention to in the future technological iteration and innovation of new energy equipment.
Some enterprises engaged in new energy development are beginning to investigate data on the power supply and demand structure and nodal prices in various regions, to provide a reference basis for the site selection of incremental projects 。
It is foreseeable that 2025 will be another challenging year. Document No. 136, like a final kick, strongly promotes the wind and solar power generation industry to truly enter the electricity market this year. Under Document No. 136, the technical threshold for the development and investment of new energy power plants has been significantly raised, and this document will also truly achieve guiding new energy investment to "valuable" places through market signals.