According to Official Account @PVMen, more than two weeks have passed since the implementation of the Notice on Deepening the Marketization Reform of New Energy Grid Tariffs to Promote High-Quality Development of New Energy (NDRC Price [2025] No. 136) (hereinafter referred to as "Document No. 136"), marking 15 days of significant turbulence across the new energy sector, including wind power, photovoltaics (PV), and energy storage.
An official from an industry think tank revealed that in recent days, they have met with multiple executives from central and state-owned enterprises, all with the same pressing questions: How should future new energy power stations be evaluated? What should serve as the reference standard for investment decisions?
The inability to proceed with investment decisions has triggered a chain reaction. "Industrial support agreements and other costs previously negotiated with local governments are now on hold, pending project reassessments," said a business executive from the provincial branch of a central enterprise.
For most private enterprises and resource fee negotiations, the inability to determine a pricing model for new energy projects presents a significant challenge. A representative from a private enterprise stated, "For projects that have just obtained quotas or have already finalized EPC contracts but cannot be connected to the grid before June 1, the new policy will require renegotiation. Since the return on investment remains uncertain, these projects must be prepared for short-term illiquidity."
Since the release of Document No. 136, uncertainty has become the norm for professionals engaged in new energy development and investment.
Unclear Document, Uncertain Pricing
As a guiding policy for new energy market participation in electricity trading, Document No. 136 introduces new electricity market rules tailored to new energy development. However, for new energy developers and investors, the document spans multiple disciplines, introducing unfamiliar terms such as mechanism-based pricing, medium- and long-term transactions, spot markets, and bidding volume pricing.
"Every word is understandable individually, but when put together, it's hard to grasp how exactly this will impact new energy power stations," one industry insider remarked.
"After reading the document, many aspects remain unclear. For instance, the document states that ‘existing projects should be properly aligned with local policies ensuring a certain scale of guaranteed electricity volume.’ Does this mean the existing policies currently implemented by each province will remain unchanged, or will they be adjusted? How is mechanism-based pricing calculated? How will provinces determine their respective mechanism-based electricity prices? What will be the impact on new energy grid tariffs? Is there a reference range?" said a representative from an electric power design institute to PVmen.
"Since the release of Document No. 136, many project owners have turned to design institutes for guidance. Previously, we were responsible for project evaluations, but now we can’t provide any definitive recommendations—the unknowns are too many."
Besides project owners, many provincial energy authorities are also struggling to interpret the document. According to PVmen, in an effort to clarify the policy details, the pricing regulatory authorities held a policy briefing last week in Jinan, Shandong, to provide a detailed explanation of Document No. 136, helping provinces better understand its intent.
Furthermore, across different business domains—from distributed to centralized energy, from photovoltaics to energy storage, from corporate headquarters to provincial branches, and from investment enterprises to equipment manufacturers—stakeholders are actively seeking insights from government policymakers and electricity market experts to decode and analyze Document No. 136. Several regional subsidiaries of central energy enterprises have even organized dedicated seminars to assess the policy's impact and explore countermeasures.
Execution Challenges and Local Implementation
Beyond pricing uncertainties and difficulties in profitability assessment, another major concern surrounding Document No. 136 lies in its implementation.
Jointly formulated by the National Development and Reform Commission (NDRC) and the National Energy Administration (NEA), Document No. 136 is a high-level framework policy that outlines the broad direction of integrating new energy grid electricity into market transactions. It also provides a basic structure for electricity trading price settlements. However, the specifics of price settlement models and implementation details are delegated to individual provinces, which are required to release and implement their respective plans by the end of 2025.
Many questions remain unanswered until provincial-level policies are finalized.
Strategies for Navigating Document No. 136
While the industry continues to analyze the potential implications of the new policy, efforts are also underway to find ways to adapt to its uncertainties.
A representative from a central enterprise that their group's first step is to review the progress of existing projects, prioritizing those that can be connected to the grid before June 1 for solar projects and before December 30 for wind projects.
From the perspective of Document No. 136, existing projects are likely to continue following the relevant provincial policies already in place, meaning revenue fluctuations should not be significant. As a result, accelerating grid connection before the deadline remains an urgent task.
Secondly, in response to the electricity pricing policy adjustments, many investment firms are asking, “How can projects pass internal reviews?” "Investment enterprises will not stop investing because of the new policy, but the key question now is how to invest and how to make decisions. The challenge is finding an alternative investment return model to guide decision-making," an industry insider noted.
According to PVmen, some enterprises are considering mitigating electricity price risks by adjusting the initial investment costs across different provinces. "Since electricity prices will become variable, the higher the initial investment cost, the greater the risk of future revenue fluctuations. Therefore, controlling upfront investment costs is essential," explained an industry professional.
Given the current decline in equipment prices, the industry widely expects that controlling power station investment costs will first target resource fees. Reducing non-technical costs is expected to be one of the most significant impacts of Document No. 136.
Moreover, to address price fluctuations, investment enterprises are searching for a new benchmark for decision-making—such as levelized cost of electricity (LCOE). Unlike unpredictable electricity prices, LCOE can provide a more stable calculation framework.
Under the LCOE approach, power generation output becomes a crucial factor, making technological advancements in new energy equipment an area of growing interest.
Additionally, some new energy developers have begun investigating regional electricity supply-demand structures and nodal pricing data to guide site selection for new projects.
It is evident that 2025 will be another year filled with challenges. Document No. 136 acts as a final push, accelerating the integration of wind and solar power into the electricity market in a substantive way. The policy raises the technical threshold for new energy power station development and investment, ultimately ensuring that market signals direct new energy investment toward "valuable" locations.
Source：https://mp.weixin.qq.com/s/AbO2V3b3uSewlCVZiEHwlA