Under Document No. 136, non-technical costs are 'killing' new energy investment

Document No. 136 propelled new energy into the electricity market, hoping to reduce the industry's non-technical costs through price adjustments. However, after six months, non-technical costs have not decreased or been eliminated as expected. Non-technical costs of 0.25~0.3 yuan/watt still widely exist in the development phase, and the collection of land taxes during the operation period has become comprehensive and stricter.

The core risk of electricity price reduction, coupled with the chronic problem of non-technical costs, is making the boundary conditions for photovoltaic project development investment increasingly stringent. 。

Multiple state-owned enterprise investors have been consulted, and the general feedback is that the conditions for photovoltaic project approval are becoming increasingly stringent, and the development of new projects has almost completely stalled. According to our understanding, a state-owned enterprise group experienced losses in its nationwide photovoltaic power plant assets in a certain month this year.

In the face of numerous uncertainties brought about by the first year of Document No. 136, Non-technical costs such as land and industrial support also urgently need to 'de-involution'. 。

Non-technical cost risks under Document No. 136

Non-technical cost issues such as land and industrial support have been a long-standing topic in the industry. However, with Document No. 136 promoting the full entry of photovoltaics into the market and the implementation of a new mechanism for electricity price bidding, the industry's sensitivity to non-technical costs has further increased.

In 136 New energy investment under Document No.: Industrial support provided, money spent, but quotas lost We observed that projects with high upfront industrial support costs have started to show clear losses, some investors have won bids but then abandoned them, and some photovoltaic quotas have even gone through multiple rounds of idle circulation.

"We invested 3 billion yuan in supporting industries in this region to obtain a certain volume of quotas. After Document No. 136 promoted the full entry of photovoltaics into the market, it is estimated that these quotas will be difficult to start construction in the short term," an investor told us. In fact, from the current perspective, industrial support, grid connection fees, and other non-technical costs have not been reduced under Document No. 136. In a 1GW offshore wind power project investment by a state-owned enterprise investor, the local government's demands amounted to 20 billion yuan, accounting for nearly 20% of the total. 。

Previously, in Multiple provinces levy land taxes on a comprehensive area basis, 136 Making photovoltaic 'accounting' under Document No. even more difficult We observed that due to multiple provinces starting to levy land taxes on photovoltaics, and some regions levying taxes on a comprehensive area basis, multiple state-owned enterprises have calculated land taxes based on comprehensive collection when making investment decisions on photovoltaic projects. After the rule change, no photovoltaic projects have recently met the income calculation conditions.

A state-owned enterprise investor said, "Photovoltaics are basically unfeasible now; the rate of return cannot be calculated, let alone the land taxes; the risk is too great." Another state-owned enterprise investor said, "After the completion of construction and grid connection before 2024, there are no plans for further construction. The group's strategy is currently very conservative."

Multiple developers pointed out that the risk of photovoltaic land taxes lies mainly in the unclear collection standards. Arbitrary discretion by local governments will severely disrupt investors' income calculations, especially in the face of the fiercely competitive mechanism-based electricity pricing model under Document No. 136; no one dares to take risks.

According to the China Photovoltaic Industry Association's "China Photovoltaic Industry Development Roadmap (2024-2025)", non-technical costs account for about 20% of the total investment cost of photovoltaics, approximately 0.6 yuan/watt. If land taxes and industrial support fees are added, Non-technical costs will approach 1 yuan/watt. 。

Non-technical costs urgently need 'de-involution'.

Although the current de-involution in the industry has driven up prices in the industrial chain, downstream investors are not very accepting of price increases for photovoltaic components. According to the latest quotes from InfoLink, centralized photovoltaic components are mainly priced at 0.61~0.68 yuan/watt.

The publicly announced winning bids of some mainstream power investors also confirm this. Recently, the winning bid price for the 170MW photovoltaic component centralized procurement by State Power Investment Corporation was 0.619 yuan/watt, while the winning bid price for the 2.7MW photovoltaic component centralized procurement by Huaneng Power International was 0.608 yuan/watt.

According to publicly available statistics, recently, large state-owned enterprises such as Datang and China Energy Investment have successively terminated the bidding for over 5GW of photovoltaic EPC projects, while China Energy Engineering Corporation, State Power Investment Corporation, and China Resources Power have successively terminated the bidding for over 55GW of photovoltaic components.

An industry insider pointed out, "After Document No. 136 promoted the full entry of photovoltaics into the market, with neither electricity prices nor electricity volume guaranteed, investment enterprises are either lying flat, terminating projects, or adopting a wait-and-see attitude... Component price increases are meaningless. 。”

In fact, compared to the current situation of downstream investment, the fluctuation of photovoltaic component prices is not the key. Previously, developers pointed out that even if components were given away for free, it might not stimulate downstream investment. The key is to start from policy aspects such as electricity prices.

Multiple investors believe that the uncertainty of electricity prices is the main reason why various sectors in the industry dare not invest. If uncertainties such as industrial support, land costs, power restrictions, and component price increases are added, downstream photovoltaic investment will "basically not be done."

A component price increase of around 0.1~0.2 yuan/watt versus non-technical costs of nearly 1 yuan/watt; it is self-evident which link has greater price reduction potential. A state-owned enterprise investor pointed out that a system cost of 0.12 yuan/watt corresponds to a 1 cent/watt reduction in electricity price. In the face of current low electricity price expectations, cost compression of non-technical costs is crucial.

However, the pressure and risks on the investment side have not yet been fully transmitted to the non-technical cost side dominated by local governments.

Meeting Notice In 2025, China's new energy development is entering a new stage. In the long run, deserts, gobi areas, and barren lands with abundant land resources will remain the main sites for centralized wind and photovoltaic projects. The 2025 Shagohuang Photovoltaic Integrated Development Forum will be held in Ordos, Inner Mongolia on August 22, 2025. The meeting will discuss topics such as development policies, cost and economic efficiency, key technology discussions, and equipment selection for Shagohuang new energy bases, contributing to the smooth achievement of China's dual-carbon goals and promoting the coordinated development of new energy and ecology.