Dear DECC,
I've just seen your consultation part B, and frankly I think you've all lost the plot. Have you even read the definitions of stand-alone contained within the FIT legislation and clearly outlined in Ofgem's guidance, or have you just asked an intern to draft up this policy in their lunch break?
This needs a serious rething / dropping before you create a completely unworkable paradox within the scheme legislation.
9 -
- No it won't make an ounce of difference because you've completely misunderstood how the scheme works. There are zero standalone systems registered under any of the 0-250kWp bands, as they have their own band that applies for all standalone systems, so your proposals make absolutely no sense at all. See point 10 for details.
- Also the reasons for lack of installs in these categories aren't down to degression, they're down to difficulty in obtaining DNO approval, companies not wishing to commit that level of finance to solar installs in one go, these systems requiring planning permission, the complexity of the RooFIT system, and a lack of capacity within the industry.
- We have a backlog of 20 quotes outstanding for 30-250kWp systems, we've had a 400% increase in inquiries in the last 6 months vs last year in the large roof mounted category, but it takes a long time to increase our capacity to enable us to handle that increased level of inquiries, and process them through to actual installations.
- Please don't do this, fiddling with the scheme and making it more complex for next to no net benefit is the last thing we need, and barely anyone in the industry even knows what you're planning to do. We need a long period of stability, then we'll deliver the capacity increase you're looking for.
10.
This is the definition of stand-alone from the latest Ofgem guidance to suppliers, as taken from the FIT legislation.
Stand-alone (autonomous):Stand-alone solar photovoltaic (not wired to provide electricity to a building)
There should be no stand-alone systems installed in the 50-150 or 150-250kWp categories because all standalone systems have to be registered under their own tariff level, currently 6.38p / kWh
Consequently we believe that the majority of ground mounted solar PV installations will be considered as stand-alone.
It'd be true to say that virtually all stand-alone systems are ground mounted, but completely wrong to state it the other way round.
All ground mounted solar PV instalations in the 0-250kWp band will be connected to provide electricity to buildings because the Stand-alone rate rarely makes economic sense, and would pretty much only be applied by accident. This is why the standalone figures aren't increasing at all, not because standalone systems are being accredited via the standard 0-250kWp categories.
Connecting a standalone system as being on one of the 0-250kWp FIT bands would be fraudulent and the suppliers would know because they've have had to install a new MPAN for them to connect to the grid.
There is the potential that some stand-alone solar PV may wire through a building and thereby count towards the capacity thresholds of the new other than stand-alone degression band.
No there isn't, as any installation that is wired to a building's electrical supply automatically isn't a stand-alone installation, look at the definition of stand-alone, how can it be otherwise?
If you mean ground mounted systems then say ground mounted, you can not use the phrase stand-alone to refer to anything other than actual stand-alone systems as described in that actual act itself and all available guidance since 2009. Do you not even run this stuff passed a lawyer before you put the consultations out?
11
No. See points 9 and 10. You're introducing a nonsense split that is entirely counter to how the scheme actually operates, there are no stand-alone systems in any of the other categories.
12 It shouldn't be implemented at all.
I am entirely your target market for this, the only thing we do is install roof mounted systems, we have never installed a ground mount system.
