Korea's rural water agency puts its possible renewable-quota fine at 1.3 trillion won

The 1.3 trillion won is the corporation's own worst case. It assumes the agency is handed 1 gigawatt a year and meets none of it ^[14]. If the estimate also assumes the 150% penalty ceiling ^[13], it implies a base of about 867 billion won per gigawatt, or roughly 867 million won for each missing megawatt ^[1]. The officially announced unit price was not reported, so that per-megawatt figure is a back-calculation.

Set that gigawatt against what the agency owns. It holds 165 megawatts directly and developed 306 megawatts through 2025 ^[9][10]. A single year's assignment of 1 gigawatt would be about six times its directly held fleet and more than three times everything it developed through 2025 ^[2][3]. The worst-case fine is 6.5 times the roughly 200 billion won it falls short each year on agricultural water supply and aging irrigation facilities ^[4][15].

At 165 megawatts the corporation sits 65 megawatts above the decree's line ^[5]. Its own power business put it there. It expanded solar on reservoirs and freshwater lakes to cover that irrigation funding gap ^[15]. The corporation made the same objection as the agriculture ministry a day earlier, at a briefing held at its floating solar project in Saemangeum ^[5]. "Imposing an obligation based solely on the scale of renewable energy facilities held is an inappropriate standard that fails to consider the agency's founding purpose and duties," an agriculture ministry official said ^[4].

Under the capacity rule, a designated party must install, or secure through investment, the megawatts the government sets each year ^[12]. Designation would let the climate ministry decide how many megawatts the corporation has to finance annually ^[12].

The climate ministry can still leave the corporation out. "Not everyone exceeding the 100-megawatt threshold will be designated as a party subject to the obligation," a climate ministry official said ^[17], adding that details would be finalized through consultations ^[18]. A second path designates the agency with an assignment near the size of its current fleet, and the fine exposure shrinks with the shortfall ^[13]. The third assigns something close to the 1 gigawatt the corporation modeled. According to the agricultural sector, the climate ministry's hearing included a plan to consider designating the corporation ^[11].

I think the 1.3 trillion won is a ceiling built for the negotiation, and the real contest is the size of the annual assignment ^[14]. The counter-case is that an agency which has already put 306 megawatts on reservoirs and lakes is the kind of builder a capacity rule needs ^[10][15], and the climate ministry has reason to use it. The draft as reported does not say whether adding public agencies raises the national build or spreads the same target across more balance sheets. If the final decree assigns the corporation anything near 1 gigawatt a year, its estimate was a forecast and this view is wrong.