Consultation Question 1. Do you agree that, in the context of deployment and spend under the FIT scheme significantly exceeding expectations, it is appropriate to remove the ability to pre-accredit from the FIT scheme?
No, we do not believe the deployment has exceeded expectations. It is true growth in 2014 was more than double that of 2013, but because of the uneven reduction in FiT over time, the installation rate has been uneven. See fig 1 (source DECC)
Nor have expectations been exceeded if taken in a developed world context, where the UK is only 8th out of the top 10 countries for solar installations –
And in the case of Community schemes, certainly not. We were encouraged by DECC’s Community Energy Strategy of 2014 to set up a local community benefit society, to engage with the community and to negotiate with developers for potential shared ownership (or complete purchase) of grid-connected renewable energy schemes. This all takes time and we have now achieved considerable community backing for the purchase of all of or the majority of a 5MW scheme from a local developer/landowner.
Just as we are about to submit a planning application we learn of the proposed removal of the extended pre-accreditation arrangements for communities. This would make it almost impossible for us to raise the finance in time and to be sure of having a financially viable scheme that would generate community funds. A huge investment in time and in expectations will have been wasted, causing considerable annoyance and community disillusion with government policy.
Surely it is a fundamental truth that what investors need above all is stability of policy. Even more so when we have to raise money from the local community. The idea of shared ownership by communities was an excellent one in the spirit of the big society. It would be a disgrace if it were to be cancelled before it has been given a chance to get off the ground. Otherwise this looks like a complete reversal of government policy.
Consultation Question 2. Are the assumptions made above on the impact of removing pre-accreditation reasonable?
Please provide robust evidence to support your response.
We understand that the number of community schemes being registered in comparison with purely commercial schemes is very small, and therefore the assumption that it is important urgently to limit their deployment is not correct (and see charts above). Providing an extension of the time for which community schemes will be allowed to pre-accredit would enable those communities which have made considerable efforts to respond to the Community Energy Strategy to bring their projects to completion. Our calculations based on the proposed degression leaves our project non-viable as there would be nothing left for the community fund – the whole point of our existence and the community’s investment in us. See comment on premature withdrawal of support below.
Consultation Question 3. Are there additional measures which could achieve the objectives of encouraging deployment under the scheme while ensuring value for money under the LCF?
More predictability, and in particular an extension of the degression linked to achieved deployment. The Berlin-based think tank “Thermal 1” has estimated in December 2014 that UK solar PV could be subsidy-free within the next decade. We urge you not to undo the good that has been done so far towards achieving the targets set in the 3rd and 4th Carbon Budgets by a premature withdrawal of support. This support has been small in comparison to the support given and proposed for fossil fuels.
Consultation Question 4. Are there groups or sectors where it may be appropriate to reintroduce pre-accreditation in the future?
Community schemes – wholly owned or majority shared-ownership. This could be a good (but so far rare) example of the 2011 Localism Act working as intended.