The impact of Government changes to Solar PV

It appears from Greg Barker's post this morning that the DECC spokesperson were right - the document referenced in our last blog post was inaccurate in the sense that the deadline date was not 8th December but 12th December - 4 days out! Pretty much everything else is spot on.  You can read the full DECC report here.

These are the proposed new tariffs compared with the current ones to see the extent of the suggested reductions:

New tariffs for solar PV

If I'm some way through the process already what should I do?

If you're at a relatively early stage and you have yet to get a confirmed install date with an installer then it's likely to be too late.  Most installers we've spoken to do not have any free slots for new customers.

For those that are some way down the road with an installer then it's all about whether you can meet the 12th December deadline.  You should probably seek guarantees from your installer that they can get your system signed off with some days to spare before the deadline. What exactly do you need to do to meet this?

The DECC report says the following..

47.The effect of the proposal is that in order to be eligible for existing tariffs a PV installation with a total installed capacity of up to 250kW must be commissioned (see definition below) and have its request for accreditation received by a FIT Licensee (in the case of PV installations with a declared net capacity of 50kW or less) or Ofgem (in the case of PV installations with a declared net capacity of more than 50kW) before 12th December 2011. In the case of PV installations with a declared net capacity of 50kW or less, the request for accreditation must include a Microgeneration Certification Scheme (MCS) certificate.

Our reading of this (and we are seeking confirmation specifically on this from our Supporters) is that for domestic and small scale projects (under 50 kW) you will need to have your system up-and-running (ie. commissioned by your installer), completed all your documentation (with no gaps or mistakes), and have sent this off to your chosen FiT licensee to arrive with them on 11th December 2011.  To be certain you should check with your chosen FiT licensee.  You should consider using a FiT Licensee that you can trust to follow their procedures, has a strong reputation in this area and can act quickly - we would suggest Good Energy as one of the FiT Licensees that would be a good option.  You do not have to switch to them to provide your electricity - you can just use their FiT registration service.

Subsequent to this post we have included specific Good Energy guidance which they issued for those wishing to use their FiT registration service - see our follow-up comment below.

Installers will be keen to do your work over the next 5 weeks but you may want to back out given the risks of not getting in before the deadline.  If you decide to go ahead, given the likely rush and pressure on installers to get through installations quickly, you should be careful to make sure performance is not compromised.  

For those who have signed contracts and paid deposits (either for purchase of solar PV or a rent-a-roof scheme) you need to contact your installer or service provider and read the detail of your contract.  You may even need to seek legal advice if you want to back out.

Households that have been considering solar PV (given they have south-facing roof space) should seriously consider solar thermal as an alternative solution for offsetting their energy consumption - in this case water heating.  The panels will take up significantly less roof space and the overall cost of such a solution may well be 50% or less than that of a solar PV project.  Financial support for domestic scale solar thermal projects is likely to be introduced through the Renewable Heat Incentive (RHI) from October 2012.  It may not be as generous at first sight but ultimately FiTs and other incentives are a temporary catalyst.  We should all be more focused on how much these technologies can save us on our existing energy consumption.   Solar thermal solutions are inherently a more efficient way to generate energy from sunshine and should offer sustainable, long-term benefits in terms of offsetting your energy use.

What are the wider consequences of these changes?

If this goes ahead as is very likely, it will be a major blow to the attractiveness of domestic and commercial (up to 50 kW) scale solar PV projects.  Take-up from now is likely to be curtailed significantly.  The availability of 'free rent-a-roof' schemes is also likely to drop sharply - many of those offering such schemes are already in the process of shelving them.

Customers should keep an eye on the health of their installer - it's likely a significant number of them may not be around long-term.  Many customers of solar PV systems are starting to realise these are not "fit and forget" solutions - glitches are occuring and these have tended to be fixed by the installer for free.  So if your installer goes bust where does that leave you?  You should have warranties on your kit (panels, inverter etc.) with the manufacturer in case problems arise but chances are you may not be able to diagnose the specific problem.  It's likely that a smaller number of current installers will set up maintenance services to provide on-going specialist support to anyone with solar PV...but not for free!

The use of Energy Performance Certificates (EPCs) in the qualification process from 1st April 2012 is a new and significant introduction that focuses much greater emphasis on EPC ratings for buildings.  There is likely to be renewed investigation of these for residential and commercial properties.  Our experience is that larger commercial buildings and older historic properties could find it a costly process to achieve a Grade C or above EPC rating which could effectively rule them out of solar PV FiT receipt.

For the industry the impact will be significant for all those companies that have invested in MCS accreditation and have skilled up their workforce to deliver projects.  They should feel rightfully aggrieved with this sudden policy change.  A significant number of these companies will either have to focus more on the much smaller market for maintaining these systems or diversify away from this area.  If they fail to do so successfully they may go to the wall leaving their PV customers in an awkward position should they need further on-going support.  The idea that solar PV companies can diversify into solar thermal systems is worth exploring although the solution is inherently more complex and requires new skills.

What's caused this problem?

The crux of this issue appears to be size and lack of expandability of the budget set for the FiT scheme.  The current economic climate and budget deficit probably has a lot to do with this too.  While the funding is raised through increases on all our energy bills, it is actually treated as a tax by the Treasury and therefore has to be given an upper limit.  The Government are not prepared to increase this budget with the consequence of greater rises across the board to all our energy bills.  They are also not prepared to let solar PV hoover up the majority of the FiT budget - there are a range of other renewable technologies that actually are considered 'higher priority' by DECC.

Our view is that FiT has demonstrated it can lead to a significant increase in jobs in this area - jobs which are likely to be evenly distributed across the whole country.  So, as a means of creating and supporting jobs it has been very successful.  However, as a means of (green) energy production we can understand why many believe it doesn't offer great value.  Aggregated outputs from all domestic PV projects would generally fall a significant way short of the sort of output from a single gas fired power station.  There is also the argument that the UK is one of the windiest countries in Europe (and the world) but a long way from having a good solar resource.

Much is made in the DECC justification document of the explosion in solar PV installation rates that could blow the FiT budget.  Could this have been anticipated?  We believe the sort of installation rate increases over recent months should have been entirely predictable - they are in line with our predictions (and those of others) on the take-up of domestic PV.  So, the real cause may be one or more of the following:

  • The FiT budget has taken a 10% cut as a result of cross-government budget cuts so this will have had some impact.
  • DECC initially predicted very little take up (if any) of anything other than sub 4 kW schemes in the first few years according to their published figures - in reality there has been significant take up (in terms of generation capacity and therefore budget) of larger scale generation projects and also stand-alone projects that has put considerable pressure on the overall FiT budget.
  • DECC got their early sums wrong in terms of the budget that was actually needed to support the rapid growth of solar PV to meet targets.
  • Officials assumed initially that the upper budget figure was likely to be more 'flexible' - but that is now proving politically unpaletable in the current climate with rising consumer energy prices.
  • DECC are far from convinced that support for solar PV is the best way to achieve their energy production and carbon saving objectives.  As they say in their document, solar PV is NOT one of their 8 'priority renewable technologies'. The amount needed right now to incentivise customers to invest in solar PV is too great and it does not offer value for money.
  • The solar PV industry is not something that DECC are prepared to artificially support for the sake of maintaining jobs - they would prefer to put their money for (renewable?) energy projects into other things - like building nuclear energy plants.

My vote is that Government priorities have changed since Labour lost power and the objectives of this government in terms of spending in the current environment are quite different.  They believe Solar PV incentivisation is too big a price to pay for the benefits (in relatively small-scale green energy production, carbon savings, jobs and wealth creation). Politicians are extremely keen to see the Green Deal scheme become a major success at the domestic scale and much less enthusiastic about schemes that have been inherited from the previous Government, notably FiTs and RHI.  [From a 'green perspective' focusing on efficiency savings is entirely logical but whether the Green Deal will be as popular as FiT remains to be seen.]

In retrospect, what lessons could we learn?  

Were the tariffs too generous?  Unlike many people, our financial analysis suggests that the rate of return for solar PV was in NOT excessive in relation to risk.  The problem relates to it being hugely over-hyped.  We've talked to a lot of households who were interested in solar PV but put off by the length of payback period and the relatively 'average' returns based on the walking away after 15-20 years.  The value that solar PV might add to your house in the long-term is very unclear.  Those that have installed solar PV should be rewarded for taking a significant risk.  Unfortunately the hype around solar PV (often perpetuated by those in the industry) suggested the deal was "too good to be true". Many households will move house within the 25 year period and may well not see a financial return on the scale they were expecting - they may even be substantially out of pocket.  

Who have been the real winners from FiT supported solar PV to date?  In broad terms, they are likely to be:

  • Wealthier households with savings that have been able to afford to invest up-front in solar PV particularly if their property is unlikely to be sold on outside the family in the long-term.
  • Many owners of solar PV companies who have had a very profitable last 12 months making significant margins largely on the sale of the kit.  Also some owners of 'rent-a-roof' service companies who have made substantial profits due to the nature of the FiT scheme.  [We would tend to agree with the DECC report that the benefits to households that have opted for the rent-a-roof scheme are fairly marginal due to the limited ability to actually consume the energy that solar PV generates.]
  • Anyone who buys a property with solar PV already installed where it qualified for this higher tariff - provided the price the new owner paid does not include a significant "PV Premium".  These new owners should be very happy indeed with the windfall payments every quarter!

Should incentives for energy generation have been launched before incentives for energy conservation?  We believe they should not.  A scheme like Green Deal should have been brought in first to incentivise households to save energy before they try to generate it.  Successive Government's have been focused on energy generation ahead of energy efficiency (see ACE blog post).  Depending on the energy efficiency measures taken by a household, it should then qualify for generation tariffs.  The Government is therefore (belatedly) right to link generation with energy efficiency as they are seeking to do now.

Overall, we feel the Government has asked industry to 'ramp up', 'skill up' and 'certify up' to install solar PV. Unfortunately they have been well and trully dumped on.  The industry has generated '000s of new jobs which are now threatened.  The recent comments by the Prime Minister to pump prime the economy through large capital intensive projects ring rather hollow when some of this money could go into an industry that has already demonstrated it can generate jobs across the whole country.  So, rather than drastic changes and job losses, why not top up the FiT budget with this additional 'pot' and reduce solar PV tariffs more gradually in line with technology costs - that way you should have a sustainable, long-term solar PV industry that supports a large number of 'green jobs'.

Just to clarify, the suggested changes above are 'under review' at this stage, subject to a consultation period.  If you feel strongly you can respond to the consultation on the DECC website.  The fact that the date of close of consultation is after the 12th December deadline suggests you may be wasting your time!

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Meeting the deadline: Good Energy guidance to new PV customers

In order to clarify the situation on getting your new solar PV system registered by the deadline, this is the guidance that Good Energy put out below.  If you are not going to use Good Energy for your FiT registration (they do not need to be one of your energy suppliers) you should seek equivalent guidance from your FiT Licensee.  They may not have the same instructions.

The Feed in Tariff review – clarifying the deadlines

The government FIT review announced on Monday stated that FIT tariffs for ‘retrofit’ solar PV installations on existing buildings below 4kW will be 21.0p/kWh from 1st April 2012, but installations must be complete before 12th December in order to qualify for the current higher rate.

This means that applications for the FIT scheme received by Good Energy on or after 12th December 2011 will only retain the current rate until 31st March 2012, and then be moved to the lower rate from that point onwards.

For the avoidance of doubt Good Energy must receive the application on our FIT form (downloadable from goodenergy.co,uk) for an installation (including address and MCS certificate number) by midnight on 11th December 2011 in order for that installation to qualify for the FIT tariff at the current rate beyond 1st April 2012. Please note that one of the requirements for an ‘application’ is the MCS certificate number, which means the installation must be commissioned, and the MCS certificate created by the installer, prior to submitting the application to Good Energy.

Any installation whose application is received after midnight on 11th December 2011 will be subject to the lower rate of FIT from 1st April 2012 onwards.

The tariff for which the installation is eligible is based on the application date, not on the date that Good Energy registers the installation with Ofgem. As the deadline approaches we anticipate a surge in applications, and we will successfully register installations where the data has been provided, but it may take longer than is currently typical, so please bear with us as we process your registrations.