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Author Topic: FITS & Energy Storage  (Read 6958 times)
burble61
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« on: January 20, 2020, 10:03:35 PM »

Started on the long haul to install energy storage back in June-19. Well the Energy Store is now installed and working nicely, but the rules & regs relating to FITS payments - well, still a work in progress!

I'm now deep in the stages of a formal complaint, and i'll share any significant progress, but a summary of "experience to date";

1/ Our original PV installation was pre-FITS. With "Energy Retailer XXXX" we had a tariff based on export with a "traditional" meter providing import & export reads, with accompanying MPANS (the meter registration number for all energy billing meters). Subsequently transferred to the FITS scheme.

2/ when planning the Energy Store, found the OFGEM guidance on Energy Stores/FITS - https://www.ofgem.gov.uk/system/files/docs/2018/12/storage_guidance_final_v2.pdf. As others have highlighted, important to design the system so meter reading (particularly for Generation) are not compromised.

3/ Went to XXXX as our FITS provider for guidance (this in June..).... "Computer says you can't have export payment any more". Hmm you have read the OFGEM guidance that says it can be paid on a deemed basis haven't you? "Err can you send us the guidance, oh and can you ask OFGEM" ok...

4/ Went to OFGEM, posing the question as a policy and guidance issue, not regarding an individual installation. "Can't discuss this, speak to your FITS licensee". Sigh....

5/ Official Complaint to XXX. "Nope, computer still says no" Ok, so what regulation, legislation or Industry Code prevents this? "Can't say. Regulatory Unit says No". Has your Regulatory Unit asked OFGEM for clarification. "No. And they Won't"....

6/ OK Escalation of complaint....(which is where we are now, still waiting for response).


So a few things I picked up on the way.....

- there doesn't seem to be a policy in place for shifting FITS deemed export payments to metered when a Smart Meter is fitted. But there are definately discussions ongoing regarding that.
- the OFGEM view against metered export payments where an Energy Store has been fitted seems to be on the basis that energy could have been imported, stored then re-exported, and thus not from 100% renewable sources. I can see that point of view.
- as with aspects of Smart Metering, the issues with OFGEMs approach were signalled way in advance by industry groups - google for the Solar Trades Association response for the consultation as just one example.
- i suspect the real reason that Retailer XXXX doesn't want to move folk from export to deemed is that given the FITS scheme is over (for new entrants) they really don't want to spend money on any process or IT changes on it.
- the issue of course, is that as Smart Meter deployment increases, and IF deemed->metered export migrations happen, then Energy Storage becomes more mainstream, then the numbers involved will increase.

Not keen on exporting for free (the principle rather than the amount), but working on some ideas i will post in the appropriate place for thoughts and guidance!

Regards

B61
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RIT
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« Reply #1 on: January 20, 2020, 10:44:46 PM »

When you write "Subsequently transferred to the FITS scheme." what exactly do you mean as I read that as you are now covered by the FITS scheme rules rather than any pre FITS and so very dated rules.

If you are fully covered by the FITS scheme rules can you not just have a registered check meter installed? It will also be worth you calling around the different companies that administer FITS payments as some will be better than others. Octopus Energy maybe a good company to call as they are still building their business (and software solutions) so maybe more flexible.




- there doesn't seem to be a policy in place for shifting FITS deemed export payments to metered when a Smart Meter is fitted. But there are definitely discussions ongoing regarding that.

Yep there is talk, but there is a problem - all FITs contracts detail how readings must be provided and from what solution/devices - so they can't just rewrite the contract their side and shift people to a new solution. The result is that none of the smart meter rollout has any focus on handling the export reading as FITS has always been described as having its own meter requirements.

- the OFGEM view against metered export payments where an Energy Store has been fitted seems to be on the basis that energy could have been imported, stored then re-exported, and thus not from 100% renewable sources. I can see that point of view.

This was a panic response many years ago when the German FITS T&Cs did not correctly handle the issue - many diesel generators ended up being used to feed power back into their grid as the payments were high and the amount of possible export was higher than in the UK for most installations. The UK solution was the introduction of the dedicated check meter and contract terms. The operators of the FITS payments also have a duty to estimate the amount of payment a contract should be receiving and then look into any mismatch.
 
« Last Edit: January 20, 2020, 10:47:57 PM by RIT » Logged

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nowty
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« Reply #2 on: January 20, 2020, 11:12:06 PM »

As you seem to be forcefully opted out of export (on FITS), can you not simply join the Smart Export Guarantee (SEG) scheme with a supplier (like octopus). You can certainly do this by volunteering to opt out of exports on FITS. This way there is no issue on whether the leccy is imported and exported via a battery system.
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pantsmachine
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« Reply #3 on: January 21, 2020, 09:59:41 AM »

As Nowty said re Octopus export would be simplest. Although you should be able to prove that your storage medium is not inline and qualifies for FIT export? I had to, to qualify for FIT, took a few go's to get the point across but got there in the end, are your proof drawings correct? Cheers.
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burble61
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« Reply #4 on: January 21, 2020, 10:26:26 AM »

Re the SEG.....very good idea!  Actually with Octopus, and on their "Go" tariff for overnight charging popup when solar isn't sufficient. Did enquire about moving to SEG, but their tariff design doesn't allow you to be on Go & SEG...they were concerned that folk with storage might arbitrage between low rates and re-export. But their Agile tariff - which can be below Go at certain times - its allowed!

Had a few conversations around the FITs with Octopus - i think its fair to say they are still coming up to speed with it but they are very willing to progress & develop, far better than "XXXX".  

Still considering it really, and still pressing ahead with "XXXX" to get the policy made explicit before i decide - i'll certainly look at what other SEG providers offer, so great suggestion, thank you both.

RIT - i'll dig out the FITS contract from the archive. From what XXXX told me, it might be the issue you raise was the one they were coming up against. Whether its true or not i don't know but I heard there was a similar problem in Spain, where its was cost effective for solar farms to run generators to power daylight-equivalent lighting at night to get the feed-in tariff. (And yes, we went RO-FITS)

Interesting point re a check meter, i hadn't considered that.  the only time we will be exporting now will be about 14/16 weeks in summer. I might just divert that into water heating, it wouldn't be too complex to manage.

Pantsmachine - yes i've given XXXX the installers diagram - their response was around the fact we are metered export (not allowed for storage installations). I provided Octopus with the Ofgem guidance, lets just say thats a work in progress too!

Regards & thanks again.

B61
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nowty
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« Reply #5 on: January 21, 2020, 02:54:22 PM »

Did enquire about moving to SEG, but their tariff design doesn't allow you to be on Go & SEG...they were concerned that folk with storage might arbitrage between low rates and re-export. But their Agile tariff - which can be below Go at certain times - its allowed!

Yes if it was allowed I would change to SEG with Octopus myself. I note the agile rates have been much better this winter so it might still be better for me. But for the moment I am on a "Go Faster" trial where I get 5 hours for 5.5p / kWh instead of the normal 4 hours for 5p / kWh.
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12kW+ of PV installed and 65+ MWh's generated.
Useable home battery storage of 45+ kWh's.
Hot water storage of 15+ kWh's.
Heat storage of 15+ kWh's.
EV BMW i3 (another 30+ kWh's of storage).
6kW Ground source heatpump.
310,000+ litres of water harvested from underground river.
burble61
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« Reply #6 on: January 28, 2020, 08:28:11 PM »

A sort of related topic - (mods feel free to shift if other forum more appropriate) .....

Was looking at the data on the Octopus site as my (electricity) Smart meter is now playing nicely (well, in the main, occasionally has delayed data, but it does catch up after a day or so) - noticed I was getting a peak of consumption in the 00:00 to 00:30 period - odd, as the Powerwall has had sufficient charge and it doesn't start charging again until 00:30.

Checked the time displayed on the meter (not the IHD) - and its running c.5 minutes slow (as measured against mobile phone running network time, speaking clock & radio-controlled clock). Given both mobile & the Sm network here run O2 that seemed odd (of course the meter might get its sync from "DCC time" rather than the network).

I'll check it against a BBC radio broadcast too (but even the delay on DAB is significantly less than this).

Anyone else experiencing the same?

I will, I promise get around to posting some experiences with the selection & installation of the Powerwall. Real Soon Now....
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nowty
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« Reply #7 on: January 28, 2020, 10:35:24 PM »

burble61,

Yes, my meter is running exactly 3.5 mins slow, I queried this with Octopus and they said the only way to correct the time is having the meter changed !

It also gets slightly worse as my SMETS2 smart meter was originally set up as an E7 meter and when it changed to the "Go" tariff I found from my first bill that they used the R1 and R2 rate registers for the split between the normal and cheap rate and not the half hour readings. The problem here is on my meter the rate only changes about 6 mins after 00:30 is shown on the meter so even after I delayed everything by 4 mins to take into account the incorrect clock I was still billed at the high rate for the first 5 mins or so every day.

So I have 1) real time, 2) meter time and 3) Rate time and they are all different ! facepalm, at least you knew where you where with the old standard E7 meters.

Now I am on their "Go Faster" trial (5 hours for 5.5p/kWh) I think my account has been changed to be billed on the half hour readings like the "Agile" tariff, so that should improve things apart from the 3.5 min delay to the half hour readings.
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12kW+ of PV installed and 65+ MWh's generated.
Useable home battery storage of 45+ kWh's.
Hot water storage of 15+ kWh's.
Heat storage of 15+ kWh's.
EV BMW i3 (another 30+ kWh's of storage).
6kW Ground source heatpump.
310,000+ litres of water harvested from underground river.
andrewellis
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« Reply #8 on: January 29, 2020, 07:46:35 AM »


Checked the time displayed on the meter (not the IHD) - and its running c.5 minutes slow (as measured against mobile phone running network time, speaking clock & radio-controlled clock). Given both mobile & the Sm network here run O2 that seemed odd (of course the meter might get its sync from "DCC time" rather than the network).



My understanding is that they are all staggered slightly to avoid the sudden heavy power demand as all the washing machines,tumble dryers, car chargers etc turn on at the same time. It gives the grid a fighting chance to respond
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burble61
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« Reply #9 on: January 29, 2020, 11:10:12 AM »

Certainly the concept of "staggering" would make sense - creating a peak on the transistion to off peak wouldn't be too helpful! (similar issue occurred in Singapore where there was "TOU Road Charging" I understand).

Without energy consumers being notified of such a change, not sure how the UK Balancing System would operate though? So absolutely acknowledge the logic, a few thoughts spring to mind...

1/ oddly, my IHD shows the correct time whilst the Smart Meter doesn't.
2/ I had a quick poke about the documentation around the Balancing System documentation and there's no mention of this (I certainly don't recall anything like it in the Commercial & Industrial metering space - but i may not have been looking hard enough!)
3/ with the increasing prevalence of EVs, the increase in demand at the transition might be more obvious, but looking at electric insights.co.uk theres no a clear step up in the recent past
4/ and perhaps most relevant, the SMETS2 spec I used as reference stated "4.4.1 Clock The Clock forming part of GSME shall be capable of operating so as to be accurate to within 10 seconds of the UTC date and time under normal operating conditions."  That spec may have changed of course....

If it is deliberate, then i'd suggest it would sense for energy retailers to inform customers, if only to prevent the helpdesk calls !
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andrewellis
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« Reply #10 on: January 29, 2020, 11:17:52 AM »

I should have prefaced with the fact it is something I read somewhere randomly in the past relating to economy 10 and 7 meters.  The document below mentions the stagger.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/48149/2393-smart-metering-industrys-draft-tech.pdf
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RIT
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« Reply #11 on: January 29, 2020, 11:26:14 AM »

I think if there were any official rules regarding "staggering" Octopus would include them in their pricing marketing/modelling at the moment they seem to be opening themselves up to a lot of bad publicity in the future if they state prices start at a certain time, but in fact, that time is varied by the meter while the meter hides the fact by showing the correct time at the IHD.


Currently "staggering" is being talked about independently in documents such as the government's "Electric Vehicle Smart Charging" strategy document where the focus is on the EV charger having "staggering" and adjustable energy rates for charging or discharging (VtG) features.


https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/817107/electric-vehicle-smart-charging.pdf


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« Reply #12 on: January 29, 2020, 12:09:52 PM »

...
4/ and perhaps most relevant, the SMETS2 spec I used as reference stated "4.4.1 Clock The Clock forming part of GSME shall be capable of operating so as to be accurate to within 10 seconds of the UTC date and time under normal operating conditions."  That spec may have changed of course....

I may be getting too cynical in my old age but here I see a world of difference between:

"shall be capable of operating"  and "shall operate".

The latter is what I would have wanted to see written in the standards.
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andrewellis
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« Reply #13 on: January 29, 2020, 01:36:44 PM »

That reminds me of a story about the eh101 Merlin told to me. The spec called for it to be able to carry a Land Rover or whatever the in vehicle was. Any sane Person would know the intentions. However on delivery it was discovered that the vehicle couldn’t be driven up the ramp.  If you rebuilt the vehicle inside the helo then it would fit. Therefore there was no come back as nowhere was it requested to be able to drive one in.
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RIT
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« Reply #14 on: January 29, 2020, 02:37:57 PM »

That reminds me of a story about the eh101 Merlin told to me. The spec called for it to be able to carry a Land Rover or whatever the in vehicle was. Any sane Person would know the intentions. However on delivery it was discovered that the vehicle couldn’t be driven up the ramp.  If you rebuilt the vehicle inside the helo then it would fit. Therefore there was no come back as nowhere was it requested to be able to drive one in.

The solution was to buy the lan Rover from Ikea so that it was flat packed.  Smiley

    https://www.militaryimages.net/media/loading-land-rover-on-eh101-merlin.13507/
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