Responses to consultation

[Ted]

I've sent in my responses to the FITs consultation paper today.

Rather than just copy them all verbatim here I've put below a precis that covers what I see as the main questions that need addressing. (My responses ran to 9 pages.)

You are welcome to use these as a starting point for your own ideas but it is probably best if you don't just copy and paste these. If a specific scenario applies to you then I suggest you use it to explain the reasons for your answer - e.g. if you are an existing PV owner and intend to expand your system in the future then Q63 is especially relevant to your situation.

The format I used was to start with a paragraph describing who I am, what system I have and why I am responding. Then I copied each question posed in the consultation paper and followed it with my thoughts, starting each with a "Yes" or "No" where applicable to immediately indicate whether I was pro or anti the idea proposed, then following it up with the detailed reasons.

Responses need to be emailed to rfi@decc.gsi.gov.uk before the deadline on 15th October.

The main thoughts I wanted to get across were in relation to:
 - existing system owners (Q45, Q64)
 - MCS accreditation (Q48, Q63)
 - off-grid systems (Q41, Q49)
 - incremental installs (Q63)
 - tariffs and degression rates (Q35, Q36, Q37, Q51, Q52)
 - and the definition of an 'installation' (Q61)

OK - take a deep breath...

Q35. Do you agree that FITs should be structured in order to recognise all generation, rather than just exports?

Payment for ROCs is based on total generation, irrespective of how much you use yourself. FITs should follow the same principle.


Q36. Do you agree that the best way of delivering security for the investor is to set a long-term guaranteed price for exports?

Export pricing should be a competitive arena amongst electricity suppliers. The rate would best be set as a % of the import price charged rather than a defined figure which will always need to be updated.  Setting a 'guaranteed' figure has the possibility that this will be taken as the only figure that suppliers will offer.

Q37. Do you agree that FITs generators should also benefit from on-site use of their generation?

Yes, this is tied to Q35. If payment is for total generation then this must apply also.


Q41. Do you agree that generators off the electricity grid should be eligible for FITs? If so, what safeguards should be put in place for these generators to ensure the electricity is being used?

Off-site generators are eligible for ROCs so should also be eligible under FITs.


Q44. Do you agree that the FITs should not require on-site generators to comply with any energy efficiency standards as a condition for eligibility?

The standards have been required only for those claiming LCBP capital grants that are paid irrespective of how much energy is generated by a system.  In the absence of the capital grant and where FITs are paid for actual generation it is difficult to see that this should remain a requirement.


Q45. Are there any issues regarding eligibility that we have not foreseen here? If so, how should we address them?

Issues for existing system owners having difficulty getting registered for ROCs due to admin problems at OFGEM. This could impact the automatic transfer that these systems should have on to FITs.


Q48. Do you agree with the proposed model for registration and accreditation of plant claiming FITs discussed in the Accreditation, Registration and Connection section?

IS MCS accreditation really required?  What real benefits will it bring to customers?  At present only wind turbines up to 50kW are covered by MCS so where will customers get larger accreditied turbines from?  All inverters (PV and wind) that are listed as MCS accredited are just carried-over from earlier Clear Skies registrations - these will lapse in December.  Requiring that only MCS accredited systems are installed will reduce choice for customers.  This requirement would deny any DIY installed systems from being eligible for FITs when at present they are allowed to register for ROCs - this seems perverse.  How can you handle a system that is initially installed DIY and then extended as MCS - the system would be partially eligible and partially ineligible for FITs.


Q49. Do you agree with the principle that all generation should be metered to qualify for FITs? Do you foresee any issues with that approach?

This raises an issue for off-grid systems. All OFGEM approved total generation meters are 230V AC. This would need to be addressed in order to allow off-grid systems to be metered correctly.


Q51. Do you agree with the tariff levels, lifetimes and degression rates we have set out for the chosen technologies? If not, what evidence do you have for choosing alternatives?

Degression rate of 7% for PV is high given the recent history of PV prices.  Tariffs can be better set as fractions of import rates rather than as absolute figures.


Q52. Do you agree with our proposed guaranteed minimum price for the exported electricity? If not, what price would you propose and what is your proposal based on?

The proposed rate of 5p is well below the sort of rates currently being offered, especially for daytime PV.  A figure based on a fraction of the import rate would be a fairer method rather than basing this on an absolute figure. This would go some way to compensate exporters who lived in the higher import tariff areas.


Q53. Does the proposed review structure provide the right balance between providing certainty and adapting FITs to the changing circumstances in which it operates?

FITs rates should be reviewed annually. Any longer time period could lead to distortions between market prices and the FITs rates.  As a review point draws near it will probably lead to some market distortions in any case as potential owners try to beat the deadline to get a new system installed at the lowest cost but to still benefit from the higher prevailing tariff.  Making the review period longer than one year will just lead to larger market distortion effects.


Q61. What do you think is the best way of defining an installation for the purposes of FITs?

One technology with one total generation meter. Anyone with a wind turbine and PV, for example, would be required to install a meter on each system so that the relevant readings could be taken, as different rates would apply to each.


Q63. How could we deal with installations at a single site installed in different years?

The system will need to cope with this as it certainly happens. The total generation figures need to be apportioned across the different rates that would apply.

Q64. Do you agree with the proposed approach for the treatment of existing generating stations?

A tariff of just 9p (the equivalent of the existing double ROC) is very low compared to the 36.5p being offered for new PV systems. This leaves existing system owners at a major financial disadvantage and could lead to systems being removed and then later reinstalled in order to qualify for the higher rate.


Q65. Do you agree with the proposed approach for the treatment of generating stations that completed installation during the interim period?

Is it right that someone should get the LCBP grant and the full FIT rate just because of the time they installed a system?

[StBarnabas]

Ted
thanks. A useful starting point. I must make sure to get my own response in before the deadline.
Sean

[CeeBee]

I've sent in my responses to the FITs consultation paper today...

Ted and others:

Having 'expressed an interest' by email to DECC some time ago, I've been notified of the workshop for 'generators etc.' to be held on 18th Sep 2009 in London. Not sure whether I'll go - maybe - I need to tell them. If anyone else is interested, or wants to attend, here's the text from the 300k .ppt they've sent (it's only one slide - goodness knows how it manages to be 300k).


Designing the Feed-in Tariffs

Workshop on the Government’s proposals for Feed-in Tariffs to provide financial assistance to generators of small scale low carbon electricity - part of the Clean Energy Cashbacks.

Are you a potential generator, installer or consultant advising on small-scale low-carbon electricity generating equipment? 

This event is aimed at providing an opportunity for all interested parties to understand proposals set out in the Renewable Financial Electricity Consultation on the Feed-in Tariffs (FITs), with an opportunity to ask questions on the proposals and to inform the design of the scheme.

When:       Friday 18 September 2009
Where:      BIS Conference Centre, 1 Victoria Street,                London SW1H 0ET
Time:      09:30 – 16:30
To register:   Please email Joely Begum:                   joely.begum@decc.gsi.gov.uk
      or Stelios Stylianou:                      stelios.stylianou@decc.gsi.gov.uk. 

NB: Spaces are limited and will be allocated on a first come first served basis.

The first email they sent managed to give away the list of recipients. Obviously not all recognisable, but gave the impression of being mainly from sizeable companies, rather than individual PV generators like me.

[Ivan]

Excellent response, Ted.

I think I'll make mine more emotional, at the risk of it being ignored. I'm assuming that the BRE have some hand in the proposals, and they're keen to use it to boost the laughable MCS in which they have a strong vested interest. Assuming I'm right, perhaps this needs to be brought to DECC's attention in case they're too thick not to realise.

[wookey]

When's the deadline?

[kristen]

Wookey: Assuming I've got the right date that you are after Ted's post contains this bit : "Responses need to be emailed to rfi@decc.gsi.gov.uk before the deadline on 15th October."

[StBarnabas]

I agree with Wookey and Ivan. My experience of MCS installers does not give me confidence they provide value for money. The thought of FITs being linked to them quite frankly horrifies me. Many of my thoughts on this have appeared on other threads, and I applaud Ted on his clear thinking, but I get quite angry when I think about the current system (and more-so on the way FITS may well end up), but need somehow to  make my points as clearly as Ted - possibly passion will have its place?
Sean
  

[noah]

Many thanks Ted for your application. I have already sent an "emotional" response pointing out, only slightly tongue-in-cheek, that waterwheels are probably the most expensive way to make renewable energy but they are the only known technology which everyone agrees is pleasant to look at.
I had a chat with a guy from mcs a few weeks ago and put to him the problem that I and other diy`ers would have with our one off hydro schemes.The surprising thing was that this aspect had seemingly not occurred to them as being a problem. He promised to make sure that the committee was aware of the fact that there are a lot of people out there who would love to cobble together their own systems and that the gathering and spread of knowledge that this would entail can only be good for society as a whole.
Mind you I`m sure they (MCS) are aware of this- they probably don`t give a monkey`s.

[Ted]

I don't think there is anything wrong at all with an 'emotional' response. But make sure it as an answer to one of the questions otherwise it is quite likely to be ignored.

The way these consultations work is that all the responses received are summarised (x% agree, y% disagree, z% don't care) for each of the questions so the more people that reply with a 'No, because ....." style of reply should get noticed.

The question to allow you to unload your dislike of MCS is Q48. Do you agree with the proposed model for registration and accreditation of plant claiming FITs discussed in the Accreditation, Registration and Connection section?

"No, I think MCS is a load of ...... because ....."

Noah, technologies being missed out (e.g. waterwheels as opposed to hydro turbines) would be a valid response to:
Q42. Do you agree with the selection of technologies for which we will be providing tariffs from April 2010?

[noah]

Ted
I didn`t think that q42 was relevant: there is no hint that waterwheels are to be left out, they are just a sub-species of turbine. (actually, considering their historical pedigree, an uber-species)
If this were not the case then something could be made of Q43:
(Should technologies for which we do not propose to offer a specific tariff from April 2010 be handled by:....)
but I`m sure the response would be (quite reasonably) "a waterwheel is a sort of hydro turbine, please accept 17p"

Not sure yet whether to like or dislike MCS: see what they do about hydro.

Point 3.64 is illuminating:
"3.64   MCS, which is industry-led, is capable of providing independent assurance and legitimacy to small-scale onsite energy installations. As such, it is the basis for eligibility for grants under the Low Carbon Buildings Programme and CERT"
I doubt the "industry" will be rooting for the independent do-it-yourselfer.
Therefore the question that follows :
"Q48. Do you agree with the proposed model for registration and accreditation of plant claiming FITs discussed in the Accreditation, Registration and Connection section"
maybe the one that needs to be addressed.
I welcome your feedback before continuing.

[Ted]

You're right - I hadn't looked closely at the list of MCS approved "hydro turbines" - there are a couple of waterwheels included.

http://www.microgenerationcertification.org/Home+and+Business+Owners/Microgeneration+Products/Small+Scale+Hydro+Turbines

So I guess they are included technologies. But, as you say, any DIY efforts will be outside the scope of what MCS approve.

[noah]

I recently spoke to an MCS poobah about the accreditation of small hydro and eligibility for fits. His attitude was that "if its not designed,built and installed by one of the approved companies then it wont be accredited" ie kiss goodbye to any fits. His view was that if you cant get an approved installer to ok your setup then it`s by default a load of cowboy tosh.
The problem being that those who are recommending the rules to the MCS are in the business of supplying new hydro systems.
All you people that have bought navitron and other turbines and had a good time installing them yourselves be warned: in order to get any fit`s you may have to have the installation (digging the leat, laying the pipe) checked by an outside expert who is quite likely to say "what cowboy installed this then? Tell you what guv, I`ll put in a nice new set of pipes and sign it off, all yours for six grand"
(apologies to hydro installers: most that I`ve met seem quite middle class)

So there are still 5 days until the deadline. I think all of you with systems which are in any part home-made better write to DECC and give them your opinion.

Here is my letter to them:

Dear RFI team,
With regard to question 48 of the consultation document.
 I am concerned that there may be many hydro schemes which may fall foul of the MCS accreditation scheme and therefore be disqualified from claiming FIT`s.
 There are many small hydro sites which have  existing systems, either waterwheel or turbine driven. Due to the great longevity of these machines the manufacturer/installer may be long gone.
 Many potential sites can only become actual if their owners are prepared to put in a large amount of unpaid work. Indeed one of the advantages of the small hydro scheme is that although the work/cost is relatively high, much of the work is low tech and highly suitable for the enthusiastic amateur.
 If however all work relating to the installation has to be, at the least, supervised by an outside "specialist" then many otherwise attractive hydro projects will never see the light of day.
 My understanding is that the MCS will be recommending a tough accreditation protocol which will pretty much stop the award of FIT`s to any project which has not been designed, built and installed by approved companies.
 This could cut the ground beneath those with existing systems which rely partly or wholly on historic machinery even though they may have been generating quite happily and reliably for some time.
 The MCS is chiefly advised on the small hydro front by businesses whose core concern is the selling and installing of their own products.
 We are all familiar with the stories of electricians/plumbers/gasfitters who, when called to make an inspection for insurance or grant purposes, will (from prudence or avarice or both) refuse to pass any existing installation and offer to re-install their own chosen system instead.
 There is obviously a concern about safety. However regulations already exist to cover most eventualities (eg any site which is G83 or G59 compatible has already shown its electrical safety)
 I therefore ask that some consideration may be given to the granting of automatic accreditation to already existing sites where historic or "non-standard" machinery is in use with the proviso that the operator/owner will give assurances as to the general safety of the installation.   "

[Ted]

But existing systems which are registered for ROCs will get automatically transferred to FITs at the 9p (double ROC) rate irrespective of whether they meet MCS guidelines or not.

It is only new systems that will need to be MCS accredited and eligible for the higher rates - 17p for <10kW hydro.  Also any systems over 50kW are currently outside the scope of MCS.

[CeeBee]

I recently spoke to an MCS poobah about the accreditation of small hydro and eligibility for fits...

I guess the problem is more widespread than just small hydro. The point that I hope many people have made in their responses to consultation (some hope - I wonder how many 'responses' from individuals not employed by mega-companies they have received at all), is that all that needs to be certified here is that "It's a renewable energy system of type X, and its output is being measured by certified meter Y"*. If the system indeed turns out to be a load of amateur tosh, then it won't generate much, so not much FIT payment. If it _does_ generate lots of energy, then does it matter about the nature of the system? It damn well shouldn't, because the point of this is to encourage people to generate renewable energy, not to line the pockets of MCS etc.

* Added complication that the present proposals intend different FIT rates for different 'capacity' systems. How exactly is this 'capacity' to be certified, without stupid situations arising. E.g. "I say it's a 9.9999999999 kWp hydro system - how was I to know that it would generate 10.000000001 kW briefly due to an extra raindrop?". I commented to them that banding shouuld be such that you get so much for your first so many kWh, then maybe a lesser amount for the next lot, etc. Not a less amount for all of them once you're over the threshold.

[guydewdney]

<devils advocate>

OK - so I have a 5kw water wheel. I also have a 3kw lister diesel, running on red / old engine oil etc. Who is to say I (wouldn't? can't?) connect the output of the lister to the input of my GTI with the wheel off - making loads of 'leccy. How would they know that the system hasn't been cheated?

Indeed - I could fit a 1 : 1.1 transformer to the grid, and 'backfeed' the grid from my GTI - and assuming the FIT is higher than the import rate, then I make money....

But I'm not that way inclined (or am i.... - wheres the devil smiley? )