Monthly Archives: July 2011

Another small update to FiTs legislation

DECC have announced another set of small amendments to the FiTs legislation. These come into force from 1st August 2011.

Of special note is that the period that microhydro systems (not more than 50kW) can be eligible for FiTs via ROO-FIT, instead of MCS, has been extended until 31st March 2012.

It also tidies up some other minor wordings to allow for tariff codes (used by OFGEM) to reflect year on year changes in rates and a change to Article 13, which is now amended to effectively say:

13. On or before 1st March immediately before the beginning of each FIT year (except FIT year 1), the Authority must publish in accordance with clause 3.3 of Part 1 of Schedule A to Standard Licence Condition 33 the FIT payment rate table which is to apply for that FIT year (subject to the Secretary of State substituting a new FIT payment rate table in Schedule A to Standard Licence Condition 33).

I do sometimes wonder if anyone at DECC has got a GCSE in English.

DECC issue consultation on Feed in Tariff loophole change

DECC have announced a short consultation on the changes they intend to introduce to plug the ’12 month extension’ loophole (see previous post). The consultation is now open and closes on 31st August.

Details of these changes are on the DECC page.

There is a subsidiary change proposed to the FiTs legislation that will remove the ‘terminological inexactitude’ that was introduced in the original FiTs SI that I have pointed out before. This relates to the date used to determine the start of the 12 month period. This will be changed from either Confirmation Date or Commissioning Date to Eligibility Date. Something that it should probably have been from the beginning.

DECC to plug Feed in Tariff loophole

DECC are apparently rushing to plug a loophole in the Feed In Tariff regulations that would allow a solar developer to extend an existing system within 12 months of the original installation and still qualify for the original rates.

I’ve mentioned this loophole several times on various fora – right from back in March this year when the fast-track review was first announced.

Pity DECC don’t seem to read all my posts.

1: Electricians Forum 20th March 2011
2: Navitron Forum 31st March

Renewable Heat Premium Payments details announced

DECC have published a factsheet covering the terms of the Renewable Heat Premium Payment (RHPP) that serves as an interim measure to incentivise take up of renewable heat systems until the full Renewable Heat Incentive (RHI) comes in to force for domestic properties.

Of special note is confirmation of the earlier rumour that RHPP (and possibly therefore also applies to the full RHI) payments are only going to be made available to properties that are not connected to the gas grid. Solar thermal is an exception to this.

The scheme is limited to £12 million and is being administered by the Energy Saving Trust on a first-come first-served basis.

Payments will be:
– solar thermal £300
– biomass boiler £950
– air source heat pump £850
– ground source heat pump £1250

At these rates the £12 million budget will only fund around 15,000 properties:
4000 x £300
4000 x £950
4000 x £850
3000 x £1250

totals £12.15 million.

DECC press release now says that £15 million is available “to support up to 25,000 installations” but with a review once £10 million has been reached.

It also looks like early adopters get disadvantaged again as the RHPP will only apply to systems that are to be installed from today onwards. The full RHI was always supposed to be available to systems installed on or after 15th July 2009. I’m waiting for the EST to confirm this – calls to their Helpline 0800 512 012 are not being answered at present as they are probably inundated.

Effect of FiTs on take-up of PV

Here’s a simple graph showing how the introduction of Feed-in Tariffs, in April 2010, has massively accelerated the number of PV systems being installed across the UK. Month 13 on the graph is April 2010.

(Click image for larger size)
This is taken from data published by OFGEM.

An analysis of TIC (Total Installed Capacity) by tariff band of the 120MW of PV systems installed so far shows that more than 85% of systems are in the retrofit 0-4 kWp band. And a tiny 800 kWp of stand-alone PV has been registered with OFGEM; the systems that caused DECC to implement the fast-track review.

(Click image for larger size)

EXGEN are systems installed before 15/07/2009 and transferred to FiTs from ROCs.

PV installs and Building Regs

There appears to be much disquiet at the moment over exactly how PV installation works are covered by Building Regulations.

Many Local Authority Building Control (LABC) departments are advising concerned callers that a Building Notice application is required at a cost, in some instances, of over £350 – even where the installer will be both MCS accredited and a member of a Part P electrical competent person scheme – in order to cover the non-Part P elements of the work, which would normally be Part A, covering any structural work on strengthening the roof. And it seems that this situation has not been helped by some rather unguarded comments issuing from the NICEIC.

As far as I can see any Building Notice required under Part A would be for notifying that strengthening works are to be or have been carried out on a roof – as a result of a structural survey.

There is no need to notify LABC that a roof is simply being assessed as to its suitability to carry a higher load or that a higher load is being imposed – with no need to strengthen it.

And any building work that is associated with Part P work (which is what a PV install is as far as the Building Regs are concerned) is automatically covered by the Part P CPS self-certification. This is written into the Building Regs legislation and has been since day 1 of Part P. In fact the wording to cover associated building work under CPS self-certification was first introduced way back in 2002.

So, as far as the legislation is concerned, if an installer is competent to self-certify for the Part P electrical work then they are also considered competent for all the other work carried out at the same time and, as far as the LABC should be concerned, is covered by the same self-certification.

This all comes hot on the heels of the recent news that some Local Planning Authorities (LPAs) were advising homeowners that their planned PV installation required planning approval even though it would usually be covered by the revised Permitted Development legislation that has been introduced by central government over the past few years – specifically to remove this particular barrier to the wider roll-out of microgeneration.

I suppose that this sort of reaction by LABCs and LPAs is a result, in these days of financial restraint, of scrambling to get as much revenue in from their customers as possible. But this is not the right (or legal) way of doing it.

The relevant parts are included in paras 17 and 20 of Schedule 3 of the Building Regulations 2010.

Impact of DECC FiTs review – the graphs

Here are a couple of graphs that demonstrate visually the impact that the recent DECC ‘fast-track’ review of over 50kW PV rates will have.

First we look at the full range of possible systems covered by FiTs from 0 to 5MW. The blue region shows the annual income (in £,000 on the vertical axis) for each size of system – shown in kW along the horizontal axis – using the existing rates. The red region shows the predicted annual income once the new rates will come into effect.

The size of the reduction is pretty clear.  But let’s zoom in on that area in the bottom left hand corner and have a closer look at the effect on systems just up to 500kW.

Here we can now clearly see the effect of the new bands that have been introduced – at 50kW, 150kW and 250kW. You can see that the annual income from a 251kW system is very little more than for a system of only 50kW, and that the income from a 251kW system will actually be less than for a 150kW system.

The new rates are due to come into effect for new systems commissioned on or after 1st August 2011.

(Annual income figures based on production of 1000 kWh per kWp. About right for the south of England.)

Links to the full-size images if anyone wants to use them: