Below is a list of policy documents and consultations that CEE is considering making responses to (listed in date order of responses required). Draft responses will be added to this page for member comments. If you would like to input into any of our responses, please email us.
- Call for Evidence: The Future for Small-Scale Low-Carbon Generation
This call for evidence seeks to identify the challenges and opportunities from small-scale low carbon electricity generation in contributing to the government’s objectives for clean, affordable, secure and flexible power. It also seeks information on the role for government and private sector in overcoming these challenges and realising these opportunities.
Key opportunities identified:
- Meeting demand – reducing and managing peak demand on the system.
- Markets for flexibility – flexibility services may provide a source of revenue. (N.B. CEE is working with UK Power Networks to look at this opportunity in more detail).
- Co-locating generation and demand – generation co-located with demand to receive a fair reflection of the value they are providing to the system through reduced network usage, ultimately benefitting consumers through reduced network costs.
- Storage - helping households and businesses manage their energy consumption and bills, and providing potential revenue opportunities by selling power back to the grid at peak times or consuming power when demand is too low.
- Demand side response – aggregators seek to unlock value for customers by aggregating their electricity flexibility into a range of markets and revenue streams enabling small-scale low-carbon generators to more easily access markets.
- Smart metering and half-hourly settlement – greater autonomy over their electricity usage and take advantage of consuming or exporting at times of the day and night that either save or make them money.
- Energy efficiency targets – reducing costs by lowering the amount of electricity that needs to be paid for from the grid.
- Fuel poverty and community energy – community energy to play a part in supporting those in fuel poverty, although it is acknowledged that activity to date has generally been funded through FiT scheme revenue.
- Behind the meter and inequitable network cost recovery – may have unintended impacts, such as the recovery of residual network charges could increasingly fall on those who cannot install or access smart solutions, especially vulnerable consumers or those with inflexible demand. (N.B. Ofgem is undertaking a Targeted Charging Review to look at how to ensure all users pay their fair share of network costs and CEE is talking to Ofgem about community energy’s role).
- Tracking deployment and network management – alternative methods to be identified, as currently tracked through FITs scheme register.
- System inefficiencies – where distribution networks are close to capacity, queues to connect further generation can develop and may lead to expensive network reinforcement.
- System balancing – an increased penetration of intermittent generation may make balancing the system more challenging and costly.
Identified options for levelling the playing field include:
- Control for Low Carbon Levies – new levies may be considered where they have a net reduction effect on bills and are consistent with the government’s energy strategy.
- State Aid – options will depend upon Brexit negotiations.
- Innovative market-led solutions – an option put forward is to leave future deployment to be driven by energy market forces. BEIS is looking for evidence for developing models that will allow projects to deploy without support. Eg. changes to building regulations and efficiency banding provide a means to increase unsupported solar photovoltaic deployment; what is the impact of the emerging corporate PPA market and ancillary services.
- Access to markets:
- The development of local energy markets may offer a route for distributed energy resources to access revenue streams from which they have traditionally been excluded. Potential models range from alternative supply arrangements for specific geographical areas, peer-to-peer platforms for trading energy, and local markets for flexibility.
- Providing or improving access to alternative markets such as the Capacity Market, Balancing and Settlement market, and markets to value energy efficiency/demand reduction.
- Planning and regulatory requirements – potential additional requirements for small-scale low-carbon generation to promote energy efficiency at a domestic and commercial level. E.g. health and safety standards may need to be revised to protect consumers and ensure the delivery of quality; planning regulations may need to be brought in line with the requirements to install small-scale low-carbon generation within developments and close to electricity demand; possible interventions to contribute to upgrading fuel poor homes; impact of changes to Standard Assessment Procedure (SAP).
- Network charging - Ofgem is developing, through the Targeted Charging Review, and work on network access and forward-looking charges, new network charging methodologies which will aim to be more cost reflective for the smarter system which is coming. (N.B this will be covered in more datails in a future CEE briefing).
- Decarbonising heat infrastructure – no preferred option yet, there is a need to be testing different approaches to heat decarbonisation and supporting more take-up of low-carbon heating, where it is cost-effective to do so.
- Guaranteed route to market – this option would need to take advantage of developments in the electricity market and support the delivery of the Smart Systems Plan in such a way as to enable the development of a competitive market that is mutually beneficial to both small-scale low-carbon generation and flexible solutions such as storage. Accessing the PPA market would be difficult for smaller schemes.
Two case studies are included in the document, both community energy projects: SCENe in the Trent Basin and Plymouth Energy Community.
Full call for evidence available here.
Deadline - 11.45pm on 30th August 2018
- Feed-In Tariffs Scheme
This consultation sets out a proposal to close the export tariff alongside the generation tariff on 31 March 2019, which would mean full closure of the FITs scheme to new applications after 31 March 2019.
Key proposals are:
• No new applications for accreditation would be accepted after 31 March 2019. Exceptions to this would be:
o ROO-FIT scale (> 50 kw) installations that apply for pre-accreditation on or before 31 March 2019 would (subject to meeting all other eligibility criteria) benefit from current validity periods to convert to full accreditation (ranging from 6 months for solar PV; 12 months for anaerobic digestion and wind; to 2 years for hydro).
o ROO-FIT scale community installations that apply for pre-accreditation on or before 31 March 2019 would get the standard additional 6 month period on top of the relevant validity period per technology set out above, in which to convert to full accreditation (subject to meeting all other eligibility criteria).
o Microgeneration Certification Scheme (MCS) scale (≤ 50 kW) installations which commission and have an MCS certificate issued on or before 31 March 2019 would have until 31 January 2020 to apply to their FIT licensee for accreditation.
o MCS scale community installations that apply for pre-registration on or before 31 March 2019 would get the standard 12 month validity period in which to commission and apply to their FITs licensee for accreditation.
o MCS scale school installations that apply for pre-registration on or before 31 March 2019 would get the standard 12 month validity period in which to apply to their FIT licensee for accreditation.
• There would be no special provision for those projects in oversubscribed deployment caps at the close of the scheme i.e. projects queuing beyond the tariff period in 2019. Such installations would not be eligible for either generation or export tariff payments under the scheme.
o Currently, three deployment bands (100-1,500 kW and over 1,500 kW onshore wind, and standalone solar) have a queue of applications beyond the end of the tariff period in 2019.
o Most of the other deployment bands have available capacity rolled over from previous quarters, with further capacity to be added in the remaining quarters up to and including the tariff period in 2019.
o Government does not consider there is justification for reallocating capacity between technologies and/or deployment bands.
• The export tariff would also be removed, with no new applications for accreditation being accepted after 31 March 2019.
• BEIS is not consulting at this point on whether replacement of or adding additional capacity to existing projects should receive FiTs at the project’s existing rates. To inform a decision on whether to consult, BEIS asks for evidence on likely replacement rates and any efficiency gains, in order to better understand the budgetary impact of any such proposal.
Full consultation available here.
Deadline: 11.45pm on 13th September 2018
- Ofgem's 'Getting more out of our electricity networks through reforming access and forward-looking charging arrangements' Consultation
Ofgem has put the case forward that the current approaches for allocating and using capacity - and charging for the associated network usage - are no longer fit for purpose.
Ofgem is seeking views on their plans to overhaul the charging arrangements of the UK energy system to allocate more costs to distributed generation to reflect the ongoing transformation of the sector, including the key issues with the current arrangements, the options that should be prioritised in addressing these issues, and how different options should be taken forward.
Full consultation available here.
Deadline: 18th September 2018
- Future Worlds Consultation
As part of the Open Networks Project, the Energy Networks Association, has launched the Future Worlds Consultation. The consultation seeks industry views on five models, known as the Future Worlds, which present a wide range of options for the future structure of our electricity networks. In the models, which were developed through a series of stakeholder workshops, traditional forms of infrastructure will work alongside new consumer technologies such as electric vehicles, smart meters, battery storage and solar panels.
The consultation is a major step toward a smarter, more flexible and decentralised energy system. This is your opportunity to help to shape the future of the electricity networks. Read more about the Future Worlds Consultation and submit your feedback to: firstname.lastname@example.org.
We encourage community energy groups and interested stakeholders to register to join one of the events or webinars organised by the Energy Network Association, to hear more and discuss the consultation:
-Webinar (21st August)
-Edinburgh stakeholder event (29th August)
-London stakeholder event (3rd September)
-Webinar (13th September)
Deadline: 6pm on 25th September 2018