I would very much have liked to have attended the PRASEG meeting on the
evening of 24th February covering Feed in Tariffs, to be introduced by
DECC on 1st April, but it unfortunately clashes with our local Transition
Energy Group meeting we already have scheduled for that evening.
I wondered if it might be possible to put forward to you some of the issues that
are apparent to me with the new FITs scheme that DECC have announced.
1. The metering requirements for off-grid systems have not yet been defined.
It is currently not possible to install an off-grid system that is known to
be fully eligible for FITs due to this fact. Transitional arrangements, to
cover any interim period until the metering requirements have been officially
defined, have also not been clearly stated.
2. No MCS accreditation guidelines for hydro installers or manufacturers.
At present all PV, wind and hydro systems up to 50kW capacity need to be both
an MCS certified product and use an MCS certified installer in order to be FITs eligible.
But there are currently no MCS certified hydro systems available nor have the
MCS certification guidelines for hydro installers been published so it is
impossible for a potential hydro installer to know what conditions are to be
applied to them.
In consideration of the fact that a long time is needed for wind systems to
become approved (a minimum of 6 months field testing is required) the BWEA
have negotiated transitional arrangements to allow certain wind turbine
products to be considered certified to cover the interim period. No such
arrangements have been made for hydro.
The whole aspect of MCS product certification for hydro also ignores the
essentially bespoke nature of each individual hydro system that is required
in order to produce an optimum installation.
These failings with hydro represent a major problem for our particular area. We
have a multitude of old wool mills which are prime candidates for installing
hydro systems as well as many other river and stream-side properties. Some of
these old waterwheels could be refurbished - but if they were they would not
be eligible for FITs due to the 'second-hand' rule. Others could have new
replacement systems put in but there are no MCS certified products that could
3. DIY systems are no longer eligible.
Again this is a major problem for our area. West Wales has a reputation for
attracting 'self-sufficient' types who follow in the footsteps of the well
known author on the subject - John Seymour. Requiring MCS accreditation for
installers prevents any DIYer from accessing any of the FITs rates. This is
despite the fact that they were acceptable under ROCs and currently can
qualify for the 9p rate. Why has no category been assigned under FITs to,
at the very least, allow this to continue?
4. Second-hand and refurbished systems not eligible for FITs.
If any second-hand or refurbished components are used in a system then the
system is not eligible for FITs. This is a condition that DECC have introduced
that was not even covered in the consultation exercise - which strikes me as
It effectively wipes out probably 90% of the value of any second-hand system
in the UK, as no one would want to pay a higher price for a system that is
unable to recover its costs through FITs payments.
5. Treatment of 15th July 2009 (the publication date of the FITs consultation)
as a cut-off date between eligibility for full FITs rates and the double-ROC
9p rate. How can it be justified for someone who had their system installed on
14th July 2009 to lose 30p per kWh on their generation? I consider such a
retrospective action (from the the point of view of the implementation date of
the bill) to be contrary to natural justice.
6. There are many existing system owners who are so annoyed at the conditions
being imposed by DECC that they are quite prepared to dismantle their systems
and sell them off (probably outside the UK due to 4 above) rather than to
continue to accept these FITs rates. They are also prepared to do this while
generating the maximum amount of bad publicity possible for the government.
Thank you for your time and I would be greatly obliged if you could consider
the above noted topics when discussing Feed in Tariffs.