Reply from OFGEM:
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Hi Ted
This is a pretty complicated situation with a large number of different potential scenarios. I don’t think I can provide you with a one-size-fits-all answer. Here are some of my initial thoughts/concerns.
I suppose my first comment would be about whether the electricity is generated in or converted to AC. As I understand it, a lot of PV installations on boats generate in DC and their appliances consume in DC. Any installation which does not generate in AC or where the electrical flows are not converted to AC cannot meet the metering requirements and would be ineligible; there are currently no DC meters approved to the necessary standards.
Secondly, I would question whether the boat could guarantee that it would always be located in Great Britain. Only installations located in GB can receive FITs payments.
Thirdly, I am not sure how we would define the site if the installation could be moved from one location to another. Schedule A of Standard Licence Condition 33 (
Electricity_supply_standard_licence_conditions_consolidated_and_coming_into_effe) defines an ‘eligible installation’ as:
“means,
on a Site [my emphasis], any plant owned by a FIT Generator capable of producing Small-scale Low-carbon Generation from the same type of Eligible Low-carbon Energy Source, the Total Installed Capacity of which does not exceed the Specified Maximum Capacity”
It also defines ‘site’ as:
“means the premises to which are attached one or more Accredited FIT Installations or Eligible Installations in close geographical proximity to each other, to be determined as required by the Authority by reference to:
(a) the relevant Meter Point Administration Number for electricity supply;
(b) street address;
(c) OS grid reference;
and any other factors which the Authority at its discretion views as relevant”.
I cannot see how a boat that could move from one location to another could meet the ‘site’ definition.
Clearly, the FIT scheme is still in its infancy and we are developing our understanding of how the scheme should operate. In developing any scheme, it is impossible to cover all possible scenarios. I doubt very much that the scenarios you describe were considered as part of the initial development of the scheme. I understand that DECC have today announced an early review of the FIT scheme. If you believe that there is a large potential for these types of installation that need support from FIT payments, you may wish to respond to the FIT consultation to raise your views:
First review of Feed-in Tariffs (FITs) - Department of Energy and Climate Change
I trust this aids your enquiry.
Yours sincerely