your choice akapabo, but you are going to come a serious cropper and probably end up bankrupt as a result at some point if you're not talking hypothetically.
why risk it, for what?
Hehe, I think you are misinterpreting my planned action but I'll play along. A question: Is there anything wrong with making multiple applications with different registered bodies. So for example if I process an MCS application of say 50kW receiving a 50 tariff then immediately process a 100kW application extension with Roofit to claim the 150 tariff then immediately thereafter process a 100kW application with Roofit to claim the <250 tariff?
No I don't think I was misinterpreting what you said, you were clearly talking about installing 300kWp of panels with the final 50kWp on MCS (quoted below), you're now talking about a different scenario, which is still outside of the rules, but a bit less so.
thank goodness i can install 300kW in three stages the first being 150kW with immediate extension a further 100kW and finally a cheeky MCS 50kW
do you think all solar sites will ever have their roofs audited?
An entire 300kWp system ending up being accredited at the 6.16p FIT rate rather than the mix of 11.71p, 9.96p, and 9.64p per kWh is a hell of a loss of revenue, no client is going to take that lying down on a ÂŁ250k investment, and no insurance company would cover you for that sort of attempted fraud (which clearly is what that would be).
Your PI insurance may possibly cover you against being sued for giving bad advice in the 2nd scenario you outline, but it's still pretty clear that you're not following the guidance, so they could well leave you high and dry to defend yourself / settle with the aggrieved client.
Here's the relevant sections of the Ofgem FIT suppliers guidance, they're clear that what you're suggesting in the 250kWp scenario should be treated as being a single 250kWp installation. It's not a loophole you'd be using, it'd just be fraud that you're hoping to get away with. Tbh I'm trying to work out if you're just on a wind up here, if so, well done, if not, then enjoy it while it lasts, but for the next 20 years you run the risk of one or more of these installs coming back to bite you with serious financial consequences if it does.
7.2. Multiple installations of the same technology type commissioned on the same date on the same site will usually be regarded as one installation. Such an installation will have one tariff rate based on the total installed capacity of all installations. The same generation meter can be used to record the amount of electricity generated from all installations.
7.3. Multiple installations of the same technology type commissioned at different times but on or before the application date on the same site will usually be regarded as one installation. Such an installation will have one tariff rate based on the total installed capacity of all installations. The same generation meter can be used to record the amount of electricity generated from all installations.
7.4. Generation and/or export meters which serve more than one accredited FIT installation are permitted, as long as only installations eligible to receive generation payments are connected to the meter.
7.5. All accredited FIT installations sharing the same meter should be registered with the same FIT Licensee. To ascertain whether there are any installations on one site sharing the same meter, FIT Licensees should search for other installations at the same address. If a match is found and they are not the FIT Licensee of the match, the FIT Licensee is required to contact the CFR Team.
lol, Ofgem hold no weight
They're only the organisation that processes the RooFIT applications, and issues the guidance that all FIT suppliers have to follow, and regulates them to ensure they do. They only have the power to withhold all FIT payments from your clients or determine that they should be paid at a lower rate inline with their guidance. At that point what do you think your client is going to do? Instruct their lawyers to take Ofgem to court for implementing their clearly stated rules, or instruct them to take you to court for giving false advice?
This really is a been there done that kinda thread, with several thousand wasted on legal costs to attempt to argue the point on FIT ratings being based on the inverter output not panel ratings, before realising that I'd need another ÂŁ10-15k to take it to judicial review. Your funeral if you choose to ignore the advice that's born of bitter costly experience.
I'll come back to my opening point - why risk it, for what advantage to you? There's more than enough work out there on commercial roofs playing by the rules, the returns are already incredibly good for most commercial roof mounted systems, what's the point in opening yourself up to that level of additional risk?