Comparative analysis
Comparison between regimes, technologies and operator categories.
Selective burden and proportionality
The Committee promotes a comparative assessment of how the 2022 energy crisis affected different economic sectors and whether the burden placed on photovoltaic producers was proportional, reasonable and consistent with equal treatment among productive categories.
The counterfactual: what solar replaces
Comparing regimes should not stop at the cost of incentives. It should also weigh what Italy would have spent, and emitted, without the plants that private investors built. Without solar generation, more daytime demand would fall on fossil-fuelled plants or imports, increasing Italy's exposure to gas markets; the alternative fossil generation would also bring CO2 and local pollutants that solar, with no combustion in operation, does not produce. And in the sunniest hours, low-marginal-cost solar output tends to hold down the wholesale price — a system-wide benefit, even though it does not always pass through in full or immediately to retail bills, which also include network charges, taxes and suppliers' own margins.
For a sample 999 kW plant, a fixed installation is estimated to avoid roughly 360–435 tonnes of CO2 a year and around 267,000 Sm3 of gas; a single-axis tracker raises that to about 410–495 tonnes of CO2 and 303,000 Sm3 of gas.
Not all renewables are treated the same
Article 15-bis does not apply uniformly across renewable technologies. It covers photovoltaic plants above 20 kW with fixed Conto Energia tariffs, and separately, non-incentivised solar, hydro, geothermal and wind plants above 20 kW that entered service before 2010. Wind and geothermal plants outside those specific conditions follow a different regime. The Committee considers this uneven scope, alongside the different exposure of small distributed producers versus large groups and funds, a key part of the proportionality question.