In Italy there have been continuous modifications of the incentive system for RES (CIP6/92 old incentive system, Tradable Green Certificates (TGC), feed in tariff from 2012 under DM 6 July 2012 and later on under Decree 23 June 2016, by 2005 I, II, III, IV and V Conto Energia for solar energy), causing uncertainty to RES plant operators. This is due to a general political uncertainty because of continuously changing governments. According to associations the installation rate of renewable energy plants has been very low for the past 5 years due to the fact that the emanation of the new renewable energy decree for 2018 - 2020 ("DM FER1"), which is necessary to restart the sector, is still awaited since two years. This uncertainty does not allow them to know in advance which type of tariff they will benefit from, which makes it difficult to establish their business plan. For example, on 29 June 2016, the national government published DM 23 June 2016 with substantial delay, as it was supposed to be published in December 2015 at the latest. This decree supported the deployment of RES, except PV, until the end of 2016. This brief life span has attracted much criticism as it has not given to investors the certainty they needed to commit their financial resources. The DM 23 June 2016 envisaged the same modalities as its previous decree (DM 6 July 2012): direct access, registration and competitive auctions. Beyond the delay, the other problem is that the maximum capacity quota set for incentives is much lower than the applications received and the Government does not have additional funds to be allocated for more renewable energy applications. In addition, the remuneration level of this support scheme is low.

As of May 2019 this barrier still persists. The national government is enacting the Decree on the RES Support Scheme 2018-20 ("decreto FER1") with two years delay. This time, unlike the decrees before, it also includes PV. The support scheme was originally supposed to be published at the beginning of 2018. However, as of April 2019, the process is still ongoing. Currently, the draft has been sent to the European Commission, which has some critical points to discuss with Italy. Those negotiations between the Italian government and European Commissions take place at the moment and are expected to be terminated within the next couple of months in 2019. Furthermore, biomass, biogas, offshore windpower, innovative geothermal, thermodynamic solar will not benefit from the new support schemes. Hence, the incentives for these RES will have to be laid down in another decree ("decreto FER2"), for which the Ministry of Economic Development has not yet published a draft.

First of all, the effects of this barrier could be less severe if the RES producers were given the possibility to know the rules, procedures and the remuneration level in advance. For example, the above-mentioned Decree of 23 June 2016 came in force 1.5 year later than expected. Another important point should be to perpetuate the indirect measures to promote RES, such as tax deductions (ruled in Italy by regulations that change year by year and that are not known in advance). Moreover, an important contribution to reduce the impact of this barrier could be the definition of new support systems for the different application of RES from electricity or heating, using economic resource not linked to the electricity bill. For example: the long awaited (and not yet complete) regulation to incentive biomethane.

Frequent modifications of the incentive schemes for RES have created continuous uncertainties about access to support. The stability of incentives is necessary to finance RES investments. From 2013 this issue became evident, as DM 6 July 2012 has introduced procedures that do not guarantee the access to incentive. If banks do not have the necessary guarantees from operators to support the financing, they do not grant the loans.

Some contacted stakeholders have outlined how the Decrees introduced in July 2012 and June 2016 have introduced demanding administrative requirements as well as a limit to the amount of plants that could receive the incentive. Because of this limit, it may be that not all plants that apply would be granted access to the support scheme at the end. Considering that in general the economic viability of a RES-E investment still depends on support schemes, stakeholders have reported that banking institutions are being more cautious to grant loans for such investments, making it in turn more difficult for producers to actually undertake the investment for a new plant. The Ministry of Economic Development (MiSe) has addressed the problem with the introduction of the National Fund for Energy Efficiency on 7 March 2018 (legislative decree n.102, 4 July 2014). The Fund aims at supporting private and public investments aimed at reducing energy consumption, building or expanding grids for district heating, requalifying existing buildings.

In particular, 30% of the resources will serve as collaterals on single financing operations while the remaining 70% will be used to issue loans at low interest rates and favorable conditions. The Fund currently amounts to € 150 million invested by the MiSe, and will be endowed with other € 100 million between 2018 and 2020. Additional capital will be provided by the Ministry of Environment. The fund will be managed by Invitalia.

Restrictions related to the protection of the environment, landscape and historical/artistic heritage can be imposed by various administrations. Authorities in tourist areas or places with cultural or historic value are also stricter. The permits from superintendencies, when necessary, can lead to considerable delays. As far as large-scale RES installations are concerned, they must go through an environmental impact assessment (“Valutazione di Impatto Ambientale – VIA”) to evaluate their impact on the environment and landscape. In 2015, the Government published guidelines for this assessment to harmonise the procedures among the different regions and give clarity to the whole process. In 2017 the government introduced a simplified procedure on environmental matters ("provvedimento unico regionale") with the purpose of bringing together in a single provision the release of VIA and the release of any other authorization or consent in environmental matters requested for the construction and operation of a project. This law is in line with the EU-objectives of simplifying the Environmental Impact Assessment. In December 2018, the Constitutional Court with sentence n. 198/2018 has definitively confirmed the legitimacy of the simplified procedure against numerous Regions and autonomous provinces claims on the ilegitimacy of the simplified procedure due to the increasing centralization of competences. However, the problem remains for small-scale RES installations. Although for these installations, a simplified process for planning permits was established, the law was issued at national level but its implementation depends on the regional level. Therefore, some regions impose environmental, historical and touristic constraints also in the use of simplified procedures. As a consequence, time delays can vary according to the territorial offices concerned.

Regarding small-scale projects, in some regions 5 kW and up to 20 kW installations requires only a Simple Communication (CS), which is an extremely simple procedure, and the standard procedure called “Simplified Permission Procedure” (PAS) is not required. Simple Communication should be implemented in all the regions.

In January 2012, incentives for PV systems on agricultural lands were put to an end (with the exception of some projects already underway), which led to a drastic decrease of that market segment. This measure was introduced by the Law Decree 1/2012, converted in Law by L. 27/2012, which entered in force on 25 March 2012. Since then, no other support measure was implemented to replace it and this represents a barrier because a part of the PV potential in Italy remains untapped. As of 2019, the problem is still relevant. Indeed, the draft of the first Decree for the RES support schemes 2018-20 (FER 1) does not contain any incentives for PV plants on agricultural lands.

The installation of PV panels on greenhouses could represent a solution to the problem of the end of incentives for PV systems with modules located on agricultural surfaces. In this regard, one possibility could be to encourages the development of more transparent solar panels and the selection of suitable PV plants adapted to greenhouses, which are characterised by a poorly lit environment. The large availability of surfaces ensured by greenhouses and farm buildings could thus be exploited by farmers while respecting the environmental and landscape equilibrium of land.

Long waiting times may be experienced between the time in which the request for accessing the scheme is firstly filed and the time in which the producer starts receiving support. The problem has been addressed with the Ministerial Decree (M.D.) of 16 February 2016, which has introduced the "Conto Termico 2.0". In order to have access to the support schemes, the eligible actors must present an online application to the Gestore dei Servizi Energetici (GSE) within 60 days from the conclusion of the intervention. The time before the payment of the first installment has been reduced from 180 days to 90 days. Furthermore, the GSE has published the "catalog of domestic appliances" (which includes small appliances with power up to 35 kW) for which the access to the support schemes is characterised by a simplified procedure.

A low degree of standardisation for the grid connection procedures, especially for the application of PV installations, has sometimes been highlighted, yet with much less frequency than in the past. There might be some delays and cases of difficult communication and exchange of information with the local grid operators. Differences can depend on the territorial offices involved, or on different grid operators.

If the obtention of the connection estimate is delayed, there is an indemnification of € 20 per day for every working day late (e.g. after the 20 days foreseen for systems below 100 kW). If the aforementioned delay is over 60 working days, the applicant may inform the Authority (AEEGSI) in order to take adequate measures, including, where applicable, the starting of replacement procedures. Through the implementation of this measure, delays in the connection procedure have been reduced. Thus, it is suggested to extend this measure to all installations with capacity more than 100 kW.

The decree “DM 23 June 2016“ for RES, excluding PV, introduced cuts up to 40% to incentives for small wind power plants and about 24% to incentives for mini hydropower plants. The decree also stopped the incentives for offshore wind in Italy. On the contrary, no cuts were introduced regarding the incentives for the incineration of wastes, which will benefit from higher tariffs than those provided for wind power. Even for biomass burned in old sugar mills, there are new facilities planned for a total capacity of 135 MW, corresponding to an expenditure in the amount of € 5 billion with prices guaranteed for 20 years. In this regard, stakeholders of the renewable energy sector do not claim for more incentives, but rather wish to eliminate them for plants that are not powered by renewable sources, such as incinerators and mega biomass plants. Moreover, they call for the introduction of simplifications for businesses and citizens’ self-generation of renewable energy. As of April 2019, the draft of the decree on the RES Support Schemes 2018-20 only involves wind, geothermal, solar and hydro. Therefore, the new support schemes will not apply to important RES such as biomass, biogas, offshore windpower, innovative geothermal, thermodynamic solar. According to the government they will be included in a second support scheme for more "costly" technologies.

Administrative regulation is extensive and fragmented between local, regional and national level. Shared regulatory competency at different levels of government causes confusion. A consequence is the uncertainty of duration and outcomes of approval processes.

The large-scale wind segment suffers especially from this barrier, since utility scale projects are subject to longer authorisation procedures, slowed down by modifications in regional regulations. The government has addressed this issue for smaller RES plants through the Renewable Energy Decree 2018, which implements the Legislative Decree 102/2014, and aims precisely at simplifying and standardising the rules for RES plants across regions. For instance, the installation of heat pumps will not require any permit from the local administrative authority in case the plant capacity is lower than 12 kW. Moreover, the Decree also standardises across regions the procedures for the Energetic Certification. The Decree has been approved by the Regions in the Unified Conference on 21 March. Once published on the Gazzetta Ufficiale, the Regions will have 120 days to adapt the local regulation.

Large scale installations are particularly affected by the multi-layered administrative provisions. One possibility to address this issue could be to implement a one stop shop similar to the “Modello Unico”, currently only applied for residential PV plants since 2015. Modello Unico is a simplified procedure through which the producer can request following documents in one step: • Grid connection • Administrative authorisation • Scambio sul posto’s convention. In order to use "Modello Unico" the PV plant should have specific characteristics required by Decree 19 May 2015, for example the architectonic integration with the building. This helps to reduce somehow time delays for the residential sector.

Clarity in terms of taxation is a problematic aspect. Specifically, the tax structure is quite complex (there are many types of taxes) and also many bureaucratic fulfilments (consumption declarations, license etc.) are necessary at this stage. In addition, local tax agencies may often provide different interpretations for the rules, thus leading to different treatments of operators.

A revision of the laws, providing clearer and unambiguous taxation rules, could be advisable.

The Italian Regulatory Authority for Electricity and Gas introduced an important change in the dispatching conditions for electricity produced by intermittent renewable energy sources such as wind, PV and run-of-river hydropower plants. Since 1 January 2013 producers are charged for the costs caused by the imbalance between their production forecasts and the energy really delivered to the grid. This provision has a rather important economic impact. According to wind and solar energy associations the current measures that regulate the imbalances are particularly penalizing for non-programmable renewable sources, which see charges ranging between 0.5 and 7 € / MWh applied to their unbalances.

The rule has also defined for each intermittent renewables technology a percentage of error of the forecast for which the imbalances are not penalised through so-called “tolerance bands”. For the years 2013-2014 the tolerance bands for variable renewables units were set at 20% of the volume sold into the market. Since 1 January 2015 the tolerance bands are the following:

• Wind farms>10 MW: 49% 

• PV units>10 MW: 31% 

• Hydro units>10 MW: 8% 

• Other units>10 MW: 1.5% The variable renewables units under 10 MW are aggregated and the imbalance settlement is calculated at a portfolio level applying a tolerance band of 8%. For new variable renewables units connected to the grid a period of no penalisation of the imbalances (at least 6 months) is foreseen, in order to guarantee a transitional period to fine tune forecasting activities. The imbalance settlement period is set to 1 hour, in order to support the compensation of the forecast errors and in accordance with the boundaries of the Day-Ahead and Intraday Market.

For existing plants in the Italian power system, stakeholders recommend that: 
 • The participation to the balancing market for the existing plants has to be voluntary and remunerated on a market basis with no retroactivity; 
 • The investments for technology adjustments have to be supported with specific financial 
measures.
 For all new plants, stakeholders recommend that: 
 • The participation to the balancing market is mandatory for the provision of the ancillary services provided for the security of the system, with the possible application of the clause “make-or-pay” (if you do not adjust the plant you are required to pay for the services not provided) 
 • The investments for technology adjustments do not have to be economically supporte.

Together with the Decree-Law 91/2014, the Government introduced another “Spalma-incentivi” for RES installations other than PV, under Decree 145/2013, and implemented it the following year in 2014 through DM 6 November 2014. Under DM 6 November 2014 the Government offered RES operators to choose between the following three different alternatives:

a) Reduction of the yearly incentive amount and spreading it on 24 years (instead of 20 years) ;

b) Redefinition of "double time": the entitlement period remains unchanged during 20 years and incentive amount will be reduced in a first period (still to be quantified/defined) and increased at a later time.

c) Reduction of the incentive of 6/7/8% (depending on size), for the remaining incentive period.

For RES installations, this possibility was offered on a voluntary basis, unless for PV, for which the three options (under DL 91/2014) were mandatory.

As part of a package called “Spalma-incentivi”, the measure “Spalma-incentivi obbligatorio for PV” (art. 26 of Decree Law 91/2014 converted into Law 116/2014) introduced from 1 January 2015 a reform of the incentives for photovoltaic installations greater than 200 kW.

The "Spalma-incentivi obbligatorio" asked PV operators to choose between three different alternatives:

a) Reduction of the yearly incentive amount and spreading it on 24 years (instead of 20 years) ;

b) Redefinition of "double time": the entitlement period remains unchanged during 20 years and incentive amount will be reduced in a first period (still to be quantified/defined) and increased at a later time.

c) Reduction of the incentive of 6/7/8% (depending on size), for the remaining incentive period.

By 30 November 2014 operators were required to communicate to the Italian Energy Services Operator (GSE) which of the options they preferred. The Spalma incentivi has intervened directly on resources for solar installations in operation, thus halting the market at the utility-scale and causing sudden job cuts in the sector. This legal retroactive change has provoked great uncertainty in the market.

Several damaged parties sued the Italian state at the administrative court of the Lazio Region (May 2015). The administrative court referred the question of constitutionality to Italy’s Constitutional Court. The Constitutional Court declared the Spalma incentivi as legitimate. Thus, the Administrative Court of the Lazio Region referred the question to the European Court of Justice, which will decide whithin the next years. Some foreign investors such as Greentech sued Italy as well at the international investment treaty arbitration tribunal and won the trial in December 2018 ("the Greentech Award"). The court obliged Italy to pay the total amount that the investors claimed for the reduction in incentive tariffs under Spalma Incentivi Decree, which amounted to € 11.9 million with a 2% interest rate. Additionally, Italy has to pay the Claimant's legal costs of € 478,000 and € 2.8 million.

AssoRinnovabili thinks that some kind of financial support should be provided to PV producers, in order to mitigate the negative outcomes of the measure “Spalma-incentivi obbligatorio”. With regard to this, a financial support mechanism should have been prepared by the Cassa Depositi e Prestiti S.p.A. together with the Ministry of Economy and Finance. The disposition to create such a mechanism was included in the DL 91/2014 and the deadline was the end of 2014, but it was never implemented in practice. Moreover, as the options to redefine the incentive plan for RES operators, other than PV, are voluntary, they can choose not to redefine their incentives and continue perceiving the correspondent incentives, that means FIT, Feed-in premium with registration or tender. This measure could be applied to PV installations as well.

The Italian PV market is composed mainly of small residential plants supported by the net metering scheme (Scambio sul posto) rather than Power Purchase Agreements (PPA). This is due to the fact that the current regulation only allows PPA with only one final user, thus excluding many market segments such as commercial centres, airports, industrial parks, office buildings and multi-family houses. The government is evaluating at the moment whether to include regulations on PPA in the upcoming Renewable Energy Decree ("decreto FER1"). One possibility which is beeing considered at the moment is whether to oblige the public administration to purchase power through PPS's.

It would be required the diffusion of Legislative Decree 115/08 in every single Italian municipality for its homogeneous application across the country.

A very important obstacle in installing renewable energy plants is the population's opposition which often occurs in Italy. Main concerns are the landscape, birdlife, noise and smells. Providing participation for citizens throughout the process of the installation of the plant is very costly and time consuming for companies. The choice not to involve citizens, however, often leads to even higher costs and delays which are particularly important in the light of incentives which are most of the time only granted if the plant enters into operation until a certain date.

There have been some initiatives to break that barrier such as the ISAAC-Program (Increasing Social Awareness and Acceptance of Biogas and Biomethane), funded by the European Horizon 2020. Several initiatives and activities that have involved citizens, local administrators, farmers and students have been carried out in the territories involved in the construction of biogas plants and biomethane, in particular Sardinia and Puglia.

It is necessary to foster awareness of the advantages of renewable energy plants while still informing about possible risks. Participatory processes should be fostered through out the realization of a new plant.

The cost of implementation is still very high, since the use of geothermal heat pumps requires very deep wells and heavy excavations. In general, these heavy excavations works are payed off during the construction of new buildings. Therefore, geothermal heat pumps are more recommended for new buildings, especially for large new condos that are intensive in thermal energy consumption.

The insufficient information on solutions related to renewables heat is a major obstacle, as the user doesn’t know about the opportunity to use heating and cooling from RES (so-called RES-H&C). In addition, information is scarce regarding the granting of permits, the request for incentives (white certificates are complex and conto termico requires non-consolidated procedures), and the funding request. In addition, RES-H&C technologies are not known enough, neither among citizens, nor among installers. There is still the need for increasing general awareness and information about the RES-H&C opportunities.

However, as the barrier was acknowledged by the competent authorities, measures were already taken to increase the awareness and information on RES-H&C solutions. As an example, a special permit was created for renewable plants used for district heating, which is well-known and spread by the different competent bodies. Also, GSE provides information on incentives and makes all relevant documents available on its website in a very clear and structured way. In addition, incentives are higher if the plant is in cogeneration. Therefore, it is possible to say that this barrier is on the way to being solved.

The level of qualification of installers is often insufficient. The problem is quite severe as the installers have a good level of knowledge on commercial practices while their scientific and technical competences are insufficient. This means that the user doesn’t talk directly to specialised operators, and so he is not well advised on the implementation of RES heating and cooling plants.

The barrier affects especially the RES plants in the South of Italy since there are less qualified installers in the South than in the North.

The Italian National Agency for New Technologies (ENEA) is working to improve the framework of qualifications. Moreover, it is preparing training programmes for the regions on the recommendation of the Ministry of Economic Development. ENEA has now introduced several training programmes for different actors, such as Regions, local organisations and private citizens. Some of these courses are available online and they vary according to the level of specialisation of the actors.

Furthermore, in July 2015 the government decided on an amendmend to the Decree, called "Mille-proroghe", which obliges companies operating in the sector of installation or maintenance of Renewable Energy Plants (Heat pumps, Solar Thermal, Biomass, Photovoltaic) to send their employees to a 80 hours training program.The initial deadline of 31 December 2016 whithin which the Regions were supposed to provide such courses, was now posponed to the end of 2019.

The renewable energy companies should train local installers and qualify them properly.

The development of biomass is reliant on modern logistics infrastructures. This involves the management of forests, Solid Recovered Fuel (SRF), green cities, the introduction of high standards for fuels through quality control as well as a functioning waste management. The barrier is severe, since bioenergy infrastructures are fundamental to allow the diffusion of biomass plants. In fact, biomass availability and competitive costs are fundamental to launch biomass plants in Italy.

Strong policy to overcome this barrier is required. The competent authorities should create bioenergy infrastructures where citizens can bring their biomass residues (for example prunings and grass) and buy biofuels (e.g. wood chips, pellet, briquettes, etc.).

Legislation regulating RES-H&C is often characterised by an inconsistency between measures of different nature. For example:

- The regulatory management of medium to large-sized biomass plants using ashes is an important barrier since ashes are still classified as a waste, and not as soil improvers,

- Ground water systems are subject to very different regulations at provincial level.

Furthermore, National Ministries, regional and local authorities have a negative role in certain cases such as in the implementation of legal provisions.

The government should classify ashes as a residue and not as a waste. In addition, it should establish homogeneous national rules and criteria to regulate ground water systems. The government should establish additional rules for additional aspects that work together with the different RES regulations.

The current legal framework for RES-H&C is a complex mix of measures arising from laws which are not related to renewables and does not therefore provide a holistic approach. Moreover, the unclear norms often lack common references so that different rules can be found in different regions.

The ideal would be that the national government would issue and approve a national policy framework with production based support scheme for RES-H, keeping the particularities for the regions as it is a federal country.

The main problem is a lack of a national regulation on geothermal energy so that regulation remains competence of the regions. This means that the quality and efficiency of geothermal energy varies tremendously between different regions. The absence of these rules, with the relative risk of disputes and refusal of incentives, deters many individuals from choosing the geothermal heat pumps and the ESCo from proposing them. The result is, for example, that schools and municipalities still have largely obsolete, wasteful and polluting air conditioning systems.

In this context, it is important to note that the government excluded geothermal energy from the Renewable Energy Decree 2018-2020 (Decreto FER1) even though incentives for geothermal energy had been garantied so far. Despite the rejection of the draft decree by the Unified Conference of the Regions in December 2018 the government insists on excluding geothermal energy from the decree. It seems that geothermal energy will be part of a second Renewable Energy Decree (Decreto FER2). However, this causes a lot of insecurity in the sector.

In addition, there is a lack of specific and proportionate laws for low enthalpy geothermal energy: Lombardy, Piedmont and Emilia Romagna have specific ad hoc - regulations; Lazio also issued them, but never implemented them.In all the other Regions each Municipality decides on his own. In many of them geothermal heat pumps must comply for instance with the stricter general environmental and soil and water protection legislation, even in case of closed loop technologies (with no ground water and soil contamination risks). The administrative procedures are hence not proportionate for these technologies: the consequence is a difficult and long authorisation process.

The ideal would be that the national government would issue and approve a national policy framework with production based support scheme for RES-H, keeping the particularities for the regions as it is a federal country.

Non-conventional technologies are often neglected by "conventional" operators for lack of know-how and training (see barrier ITHC11).

The national and regional government should implement more specific training workshops for operators to increase their know-how and technical expertise on RES-H technologies, in order to make them more attractive for operators

Groundwater heat pumps face complex procedures that also differ among regional and local governments, to obtain the building permit. The non-homogeneous administrative procedures are time-consuming and very inefficient for heat pump operators.

Some certification bodies have started their own certification schemes. For example, the Ministry of Economic Development, the Ministry of the Environment as well as the Ministry of Agriculture and Forestry took some measures mostly in environmental certification, which determinate a higher or smaller incentive in function of emissions reduction. With regard to biomass and solar thermal, there are just specific biomass certification processes, through technical norms (UNI). Although these certification schemes exist, they have been implemented quite recently and the interest is still somehow limited.

The Ministries of Economic Development and of the Environment together with the Agriculture and Forestry Ministry should increase awareness and diffusion towards the importance of systematic certification processes, especially concerning geothermal energy.

Lack of regulation for district heating creates uncertainty and additional costs. A new regulation is essential to increase the degree of competitiveness in the sector as well as to protect consumers. The legislative decree n.102/2014 partially addressed the problem by attributing to the Regulatory Authority for Energy, Grid and Environment (ARERA) legislative power in some areas. In particular, the ARERA is empowered to determine the tariffs for grid connection as well as the rules for the publication of the prices of the heating supply.