Citizens Advice Response to BEIS Consultation on the Feed-in Tariffs Scheme
Citizens Advice welcomes the opportunity to respond to the government’s consultation on the Feed-in Tariffs scheme.
The government is currently proposing to close down the Feed-in Tariffs scheme (FiT) and has expressed the view that “small-scale low-carbon electricity generation… should compete independent of direct subsidy and on its own merits on a level playing field with other electricity generation technologies through competitive, market-based solutions.”
We broadly agree with the government’s view, noting that the price of low-carbon microgeneration – especially solar PV – has come down rapidly and seems likely to continue falling apace. We believe that small-scale low carbon generation can survive without new subsidy but argue that some government support is needed to smooth that transition.
We are therefore proposing that – after closing the FiT generation tariff – the government should extend a subsidy-free version of the FiT export tariff set at a discount to the wholesale electricity price. This would provide a last resort market for electricity exported by small-scale low carbon generators after March 2019 and should serve to smooth the transition to market-based solutions, giving these more time to develop and allowing more of the enabling infrastructure to support those solutions (such as smart meters and half-hourly settlement) to be put in place.
We are also proposing that in the future, once SMETS1 meters are no longer being installed in consumer properties and when existing issues around ensuring that export data from smart meters can be reliably and securely accessed by the FiT licensee, FiT generators should be required to accept a smart meter from their energy supplier to be eligible for this revised, subsidy-free export tariff. This would end deemed export for new FiT participants and help prepare them to access some of the new markets that are anticipated to emerge for the electricity they generate. In the interim, we suggest that deemed export should continue on a provisional basis until the outstanding issues with smart meter export data are resolved, but we encourage the government to urgently address these issues, which currently present a serious barrier to its vision of cost-reflective export. We recommend that the government publish a roadmap laying out how and when outstanding export data issues will be resolved, with a clear accountability framework for its delivery.
Finally, we agree with the government’s proposal to include metered exports in the levelisation calculations, noting that metered export payments can potentially impose significant costs on some FiT licensees at present.