Arguing about the technicalities of the consultation at this stage is re-arranging the deckchairs on the Titanic.
I'd disagree. DECC have convinced themselves, based on the PB research, that these tariff levels are sustainable and do achieve the minimum IRR returns that they view as being viable, and that's their justification for setting these levels.
It's an absolutely vital first step to clearly and definitively refute the assumptions used, and demonstrate that even if we were to accept their logic of a 4% IRR being acceptable, that these figures will not achieve that, and they really do risk killing the entire domestic solar PV market completely.
This will also be crucial for briefings to MPs on this.
Not that the rest of it isn't important, but I don't see that any of us here are in a position to do much of that stuff, whereas we are in a position to provide this sort of ammunition that STA etc can use to bolster their case. STA itself doesn't really have the resources or direct access to the information needed to do this level of detailed work to refute their consultant assumptions.
Unfortunately the STA blew a lot of credibility in 2012 by arguing that the fit reduction to 21p was unsustainable and would kill the industry entirely, when those of us with direct access to the costings etc were able to work out that actually this wasn't the case at all, that it'd be tough but we could make it work. STA were proved to have been wrong in their predictions then, and DECC will use this to discredit anything they say unless it's backed up by hard evidence that they can't refute.... boy who cried wolf stuff basically, not that they're crying wolf now, but that because they did it before without properly assessing the situation, their word is good for nothing now.
I think we should take note of Greg barkers comments on this as well, that the industry needs to propose credible alternative solutions to this backed up by hard evidence. Bluff and bluster got us nowhere last time, it'll achieve even less this time. This time they really have actually screwed up the data and assumptions, so we can actually nail them on these points to undermine their case, and set the ground for whatever alternative proposals the industry comes up with.
That's how I see it anyway.
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