G83/1, G83/2, G59/2 and other solar PV regulations

31st March deadline for FIT applications for systems with MCS certificates issued before 15th Jan 2016

a recent new build solar pv installationLeeds Solar have just become aware that on 10th March DECC slipped in a Statutory Instrument that takes effect today (31st March 2016) that results in  the following urgent issue.
 

All existing renewable energy installations with an MCS certificate issued before 15th January 2016 must submit their Feed-In Tariff application by 31st March 2016 or they will never be able to claim any Feed-In Tariff or Export payments.


This issue is not mentioned in any Ofgem guidance as there have been no updates since the legislation was drafted, but it has recently been added to the Energy Saving Trust Fed In Tariff guidance page, copied below

  • A requirement for customers to have applied by 31 March 2016 at the latest if their installation has a Microgeneration Certification Scheme (MCS) certificate issue date and commissioning date of 14 January 2016 or earlier. This applies to all MCS technologies under the scheme. 

We have produced a revised version of appropriate sections of the legislation including the new amendments at the bottom of this blog article, as well as a quick guide to the issue for those potentially affected.

Who does this affect?

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Solar PV export payments ruled out for extensions to existing installations

Ofgem confirms the solar industry's fears by ruling that extentions to existing Solar PV systems are not only not eligible for FIT payments, but also aren't eligible for export payments.

It was clear from DECC's consultation response that anyone wishing to add extra solar PV capacity to a site with existing Feed-In Tariff (FIT) registered solar PV systems would no longer be eligible to receive Feed-In Tariff payments for the extensions. However it wasn't at all clear whether these systems would still be eligible for export payments, with several FIT suppliers we contacted last week saying that they assumed that such installations would still be eligible for export payments.
 
On page 25 of the Feed-In Tariff guidance for renewable installations v10, released today however, Ofgem clearly state that this is not the case ;-
 


    3.77. Any extension to an accredited FIT installation that is commissioned on or after 15 January 2016 is not eligible to receive FIT     support. This applies to both generation and export payments. 

At Leeds Solar we already had 3 previous customers lined up who were wanting to fit battery storage to their existing system and add additional panels at the same time despite this being ineligible for FIT payments. This was just about economy with the export rate being paid, it remains to be seen whether it will be viable without even export payments being made.

This seems to us to be a particularly unfair and innecessary change to the system, as the export payments at 4.85p/kWh really aren't a subsidy. We struggle to see what justification there is for this change.
We hope that some of the more enlightened Feed-In Tariff suppliers will find a mechanism for these installations to receive payments from them via power purchase agreements without the need for costly half hourly export metering being fitted. In the meantime though this perverse decision risks preventing a market developing for entirely unsubsidised additional solar PV capacity being added by enthusiastic owners of existing solar PV systems. We'd love to hear the Minister explain why DECC want's this to happen.

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Major changes to G83 rules for properties needing advance permission to connect

A new draft version of the G83/2 regulations has been released for consultation including major changes to the rules about when advance permission is needed for connecting a solar PV system to the grid.

The key changes are:-

Definition of 'Close Geographic Region'

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