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Author Topic: Wanted views on F.I.T's.......  (Read 8616 times)
Simon
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« Reply #15 on: October 14, 2009, 07:49:51 PM »

To my mind this MCS clause is unjust and anti-comeptitive. I wonder if there is some way to launch a legal challenge?   The StBC PV system would makre a good test case..

Well you could try or just save your money. There is no way that the FITs system will start without some sort of accreditation. MCS exists therefore it is, to paraphrase Descart.

The following is from the Consultation Doc...

Small generators
3.63 For microgenerators and others where systems exist we intend to make
maximum use of third-party certification to minimise the administrative and
compliance burden. The Microgeneration Certification Scheme (MCS) is an
independent certification scheme accredited by the United Kingdom Accreditation
Service (UKAS), which assesses installer companies and products against robust
standards. It enables the provision of accurate forecasts of energy outputs to
generators as well as a level of consumer protection which meets the Office of
Fair Trading requirements. In addition, MCS gives assurances about the likely
quality, durability and performance of installations.
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.
3.65 Given the establishment of the MCS as the only formalised industry standard in
the UK based on European and international standards, and that it has been used
as the basis of existing Government support programmes, it would be beneficial
to continue to use it for installations up to the capacity limit to which it applies
(currently 50kW). Therefore, we propose that the MCS or an equivalent scheme29
has a role to play in the accreditation and registration of installations where that
scheme applies.

and ...

Consumer protection
3.76 If FITs are to lead to greater participation in electricity generation by households,
communities and other non-expert generators, the systems, as well as being
simple, need to deliver confidence to generators that their rights in the market will
be protected and they will not be subject to exploitation.
3.77 We propose that the interests of generators especially households will be
protected by a range of arrangements. These include systems that are specific to
FITs and energy markets, as well as general competition and consumer
legislation.
3.78 In the case of installation, we propose using the MCS to provide consumers with
assurance about the quality of the product they are buying that it will generate a
certain amount under certain conditions and be operational for a certain length of
time.

and ....

Auditing, assurance and enforcement
3.124 The organisations involved in the delivery and administration of FITs (the licensed
electricity suppliers, Ofgem, Elexon and, through the MCS, Gemserv) have
existing governance, audit and assurance procedures in place, some of which will
be suitable for use on FITs.
3.125 Therefore, as a general principle, where existing procedures exist, such as those
used for the RO, we will look to use these audit and assurance procedures.
We will work with the relevant organisations to ensure that the powers and
procedures in place provide the assurance we need to help achieve the following:
Only eligible and accredited installations claim FITs;
FITs installations only receive the tariff for which they are eligible;
Information provided by generators is accurate and there are suitable checks in
place to prevent fraud; and
Information provided by suppliers as part of the levelisation process is accurate
and timely.
3.126 The procedures in place to achieve these objectives are to include automated
checks, and ad hoc and scheduled audits and assessments.

Sorry about the formatting but it is copied from a PDF doc.

Simon
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Paulh_Boats
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« Reply #16 on: October 14, 2009, 08:46:39 PM »

What a load of b******  and red tape.
All we need is to measure an export meter and pay for Kwh exported to the National Grid.
As for legitimate installs, inspector comes round once a year and checks for 1) flat things on the roof with wires 2) a pretty damn obvious DC to AC grid-tie inverter, there are only about 3 manufacturers.

I guarantee you I could fiddle a squeaky clean approved install with a diesel jenny and send the export meter spinning, only regular inspections will stop that....

Or - 4 car battery chargers in series. 48V into inverter...endless "solar power" back through export meter. 12p a unit in...36p a unit out.

-Paul
« Last Edit: October 14, 2009, 08:54:42 PM by Paulh_Boats » Logged

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StBarnabas
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« Reply #17 on: October 14, 2009, 09:18:53 PM »

Paul
a few threads going on FIT's tonignt but I take grave exception  to most of the "government speak" as quoted by Simon. It seems to miss the mark by a long shot very badly argued and not credible. - Can't help but think this is going to be a disaster - hopefully I will be proved wrong..
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Ted
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« Reply #18 on: October 14, 2009, 09:34:51 PM »

For anyone thinking of trying to subvert the 'system' I'm sure that physical inspections will be prioritised for any PV installations that are generating much more than 850 kWh/kWp per annum. I expect that benchmarks will also be set for wind turbines against wind speed profiles for different parts of the UK and anyone reporting higher than average figures will be inspected.
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« Reply #19 on: October 14, 2009, 09:44:23 PM »

For anyone thinking of trying to subvert the 'system' I'm sure that physical inspections will be prioritised for any PV installations that are generating much more than 850 kWh/kWp per annum. I expect that benchmarks will also be set for wind turbines against wind speed profiles for different parts of the UK and anyone reporting higher than average figures will be inspected.

I totally agree Ted. I think we need house "MOTs" to check the solar panels, measure insulation levels, check wiring etc. and advise required work. At least when a property is sold, more often for renewables of course and older properties.

Interestingly there is no up-front red tape for a consumer of the well established car industry. Just sensible MOTs starting when things might go wrong.

-Paul

« Last Edit: October 15, 2009, 10:45:01 AM by Paulh_Boats » Logged

30 tube thermal,
2.3kW PV see:
http://www.solarmanpv.com/portal/Terminal/TerminalMain.aspx?come=Public&pid=17067

LED lighting in every room
NO tumble dryer, +370 kWh per year
martin
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« Reply #20 on: October 14, 2009, 09:50:04 PM »

Where angels fear to tread.............
FITs are not going to be designed to work as anyone with any commonsense would expect that they should, nor will they be fair, nor will they encourage general uptake of renewables - they will not be designed to........ Like everything that this bent government has ever done, it is designed to benefit their "buddies in the trade" - any "consultations" will be a sop to appear to be "listening", when in fact they've already made up their minds, and pocketed the envelopes - the last thing on earth they want is for them to actually do what they say on the tin, that would stuff the deals they've already done with the nuclear and other allied concerns.... So in the meantime, a few more "insiders" will make a swift financial killing, a few people will pay over the odds for renewable systems, and they'll get on with real business - building nuclear reactors..... whistlie
If you want to know the level of understanding of the government, I heard a member yesterday talking on the radio about how "microgeneration turbines on people's roofs would be well rewarded".......... despite the fact we all know the blo*dy things don't work, and Swindlesave has just gone down the pan.......... wackoteapot
Me? - I'll be found embracing my battery bank crooning "mine........... all mine.........." Wink
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« Reply #21 on: October 14, 2009, 10:14:23 PM »

I totally agree Ed. I think we need house "MOTs" to check the solar panels, measure insulation levels, check wiring etc. and advise required work. At least when a property is sold, more often for renewables of course and older properties.

Interestingly there is no up-front red tape for a consumer of the well established car industry. Just sensible MOTs starting when things might go wrong.

-Paul



Oooh ...... we could have things like Energy Performance Certificates and sustainability information ...... of course we would need a team of specially trained and certified inspectors ........ who would have to be a member of an accredited scheme ...... that could charge a hefty fee ........ then we could legislate so that everyone has to take part ...... lets see what could we call it ........ Oooh I know ...... how about a Home Information Pack ..... or HIP for short!!  Wink

 tumble

You only need to look at what a pigs ear Hips are to see what the reality of such a scheme would be, simply another layer of expense and never actually achieves its potential aims.

I'm also thoroughly fed up with every person in the country being assumed (by government/legislation) to be ignorant, incompetent and an outright criminal unless you can prove yourself otherwise.

If you treat everyone like fraudulent criminals then I suspect the level of fraud increases. If you trust people I suspect trust increases.

I would personally find regular check-ups offensive and insulting.
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Roy
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« Reply #22 on: October 14, 2009, 11:30:41 PM »

_Today_ is the last day you get to tell the govt about the problem with relying on MCS, as opposed to whinging here which will have exactly zero effect. I just sent mine in.

Just answer these three if you haven't got time for the whole lot. (and ignore the whole section on ROCs unless you really have got time to burn - i.e start at Q35)
Q48 Do you agree with the proposed model for registration and accreditation of plant claiming
          FITs discussed in the  Accreditation, Registration and Connection section?
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?
Q59.   Do you agree with the proposed approach to auditing, assurance and
           enforcement? If not, what alternative approach do you propose and why?


Here's my (relevant) answers: (most of the others are just 'yes, that's fine' - these are the contentious bits)
----------------------------
Q46. Do you agree with our approach not to offer up-front capitalisation to
schemes as part of the FITs? If not, what alternative approach do you propose
and why?

Yes, I think this is a reasonable choice - but it does have implications:
If up-front grants are not offered then it becomes very important to accept non-MCS (DIY) installations for FITs. Currently the capital grants can cover much of the installation cost. Without them, and with an attractive FIT, DIY becomes an very cost-effective installation method (at least for domestic PV), and should not be discouraged.

I think either up-front capital grants and a lower FIT rate or no capital grants and a higher FIT rate can work.

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

Absolutely not. This is the biggest flaw in the otherwise excellent proposal.

Given that generating stations are measured by output using approved meters there is nothing in the FIT scheme which requires any particular generating technology beyond the existing G83/1 requirements for grid connection. The MCS accredited list does nothing here except keep prices up and competition down. (There is plenty of PV equipment available which works very well but it not on the MCS accredited list for no good reason except that no-one has paid BRE to get it there. That is not a good reason for making systems built using such kit ineligible. The output is measured, so if the installed system is poor then it will produce low outputs, and receive correspondingly low payments.)

PV installations are fundamentally very simple - put a load of panels on the roof and connect them via an inverter to the grid, respecting G83/1 and part L. This is a straightforward task for the competent DIYer and doing so saves typically 3000 on a domestic install, even despite the VAT disadvantages (installers get 5%, DIYers don't) . Declaring that such a generating station somehow isn't valid and doesn't contribute to carbon emmissions reduction and renewable energy targets (which is what denying FITs amounts to) makes no sense at all. All micro-generation stations are valid and worthwhile - whoever put them there.

I cannot stress this enough - do not exclude non-MCS systems - it is illogical and will greatly reduce the number of systems installed: the difference between 8500 for 2kWp DIY and 13000 MCS-installer installed (a real, and typical, domestic example) is a major disincentive.

This would also create a problem with an installation that was initially DIY, but then extended by an MCS installer. That would make it 'half-eligible' under the consultation proposal, which seems nonsensical.

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?

Yes. For the reasons given (cheap, easy, incentivises uptime efficiency and maintenance). It also important in the context of DIY/non-MCS installtions - because ultimately only the output (and legal compliance) matters.

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?

No

Most are OK, except the 'Existing microgenerators' rate. The PV degression rate of 7% seems high - I don't believe it is dropping that fast. For retro-fit the tariff is about the minimum acceptable. It is sufficient to generate action in those who have funds available, but probably not for those that would need to borrow the capital. A slightly higher tariff would probaby be needed for that.

For Existing PV installations, the 9p tariff is exceedly stingy. People who were early adopters feel strongly that getting less that a third of people starting now is unfair. Last year for example SSE was offering 28p/kWh exported for PV. For a low-daytime-usage (i.e efficient) domestic property that represents a benefit of about 450/yr for a 2kWp install. The 9p FIT and 5p export tariff downgrades that income to under 300. Such people really shouldn't made worse off under the new scheme. Perhaps competition in export tariffs would help a little here, but fundamentally existing installations eserve a better deal otherwise people will be decommisioning and re-installing in order to get the new tariffs. The argument that they received a capital grant and thus deserve a lower tariff has some validity, but then people installing now (late 2009) also get this benefit under the transitional arrangements. And not _that_ low, anyway. That tariff may be acceptable for non-PV installations - I don't know.

Q59. Do you agree with the proposed approach to auditing, assurance and
enforcement? If not, what alternative approach do you propose and why?

Yes, broadly, apart from the MCS requirement for installations to be eligible, which would declare many smaller generating stations to be ineligible for no good reason. Removing this requirement may affect the best way of providing audit and fraud prevention to some minor degree, but the benefits are large and any changes needed small. 

Q62. Once an installation is defined, do you think further checks are required
to verify this? If so, what would these checks be?

A schematic and photo will be sufficient. Occaisional physical checks should be performed by way of fraud prevention.
-----------------------
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« Reply #23 on: October 14, 2009, 11:43:09 PM »

On the subject of MCS installations I'm being made aware of some situations where a company registers itself as an accredited MCS installer but they have none of their own employees working on installations. They instead just refer their customers to separate installers who are on their 'approved' list (which may mean they have been on a company-run installation course). The customer negotiates a price with and pays that third-party installer directly.

Somehow this method appears to pass through the current LCBP grant system unhindered - which I find a little surprising.

Anyone else heard of this approach?  If this is accepted as kosher then it may open up a course for Navitron to do the same?
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« Reply #24 on: October 14, 2009, 11:51:52 PM »

I work for many large sales out lets that are none mcs but i am so they sell a system with me down as the installer and supply of goods etc so they can claim the grant
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Been installing pv, solar hot water, chp air/ground heat pumps and wind for some time now.
Simon
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« Reply #25 on: October 15, 2009, 07:51:04 AM »

....

I guarantee you I could fiddle a squeaky clean approved install with a diesel jenny and send the export meter spinning, only regular inspections will stop that....

Or - 4 car battery chargers in series. 48V into inverter...endless "solar power" back through export meter. 12p a unit in...36p a unit out.

-Paul


What a great idea! Here in the Land of the Midnight Sun (i.e West Wales) we seem to be able to produce solar energy 24 hrs per day.... and all at 36.5p +5p from my (prospective) PV panels. I reckon I will be able to move to South of France in about 12 months.

Seriously, we are going to have to live with MCS approval whether we like it or not. The consultation document doesn't really give much reason for thinking otherwise. My local MCS accredited installer wants 1300 for the "Design, installation and commssioning inc documentation and liaison with electricity company". AS far as I can see he would be charging a reasonable amount for the panels, inverters etc so his main profit is going to be the installation charge so he is not going to get very rich.

Of course I could do it for nothing but then I wouldn't get the FITs so we are back where we started. Incidentally, I have calculated that I will get a financial return of nearly 7.9% based on a commercial install and my current electricity unit charge of 10.8p. With the cost of electricity increasing over the years the return will look even better.

And please no flaming on the subject of payback periods and financial returns. While a small number of us enthusiasts may well try to save the world single-handed, the vast majority will look at it as an alternative investment. The consultation document says that the FITs are based on a return of between 5 and 8% so that the public WILL see it as a reasonable investment.

Simon

ps I am retired and about 65 years old so why on earth am I looking at a 25 year investment - must be crazy!
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Ivan
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« Reply #26 on: November 08, 2009, 06:57:52 AM »

Ted,

We met the MCS admininstrators three or four weeks ago - I put the same [and other interesting] proposals to them - still waiting for an answer....(have chased them several times)
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Alan
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« Reply #27 on: November 08, 2009, 10:10:32 AM »



Quote I guarantee you I could fiddle a squeaky clean approved install with a diesel jenny and send the export meter spinning

Why pollute the planet with the exhaust of the diesel generator when any toridal transformer and two feet of wire would do a much better job.

Regards

Alan
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