News 26 July 2011. [Note: we seem to be asking for a lot, but the fact is that some really big, really stupid corrosions are happening, due to the combined nuclear and heat pump lobby virtually hijacking the RHI.]

Response from Solar Twin Ltd to the RHI guidance consultation.

We have three requests to make.

1/ Stop the imminent £10M-£100M RHI overclaiming fraud. Regarding all mains electrically powered technologies, actual energy benefit (ie net energy rather than gross heat, which is currently the metric) needs to be subsidised, for all technologies. If, in a year, if a heat pump gives, say 10,000 kWh of heat but consumes 3000 kWh of electricity in the process, the subsidy should be based on 7,000 units of net energy, because this is the benefit, not 10,000 units.

This “net energy benefit” principle, needs to apply to all mains electrically powered renewables, otherwise perhaps 10-20% of all money will be paid under RHI for claimed benefits which are not actually real.

It is vitally important that the RHI subsidises real energy benefits only. Doing so would deliver better value for taxpayers and would reward systems with zero carbon operation more fairly. The metering implication would only be to add an electricity meter to the system. Electricity meters are simple, reliable and low cost, compared to heat meters.

[Note: we are, in effect, seeking to prevent a massive fraud from taking place. We estimate it would be worth tens of millions of pounds in the short term, in the context of the current £860M RHI budget and hundreds of millions of pounds of fraud in the longer term.]

Subsidising what is, in effect, a non-existent energy benefit, would not only waste tens of millions of pounds of public funds. It also risks fatally undermining the credibility of the RHI and of its architects.

2/ Don’t meter small business’ solar heating into oblivion. Regarding solar thermal, Metering of small solar thermal installations is overkill. There is a major issue of burdensome heat metering requirements for small business which plan solar thermal installations under RHI.

For example, in our 1-2 panel solar heating installations (1.6-3.2 KwP), there is a huge costs-benefits problem caused by metering:

the proposed metering cost increases the total capital cost by 15-20% This is awful in terms of financial costs-benefits.
the carbon savings are negated by around 5% by the use of electricity. This hits the sustainability benefit.
the metering reading window of 3 days means at bank holiday weekends you to have to attend and unlock the premises to read a meter for under £100 of subsidy. Driving around virtually pointlessly using up holiday time to do so is not the way to run an efficient, sustainable business!

If Government intends to prevent SMS’s from installing small solar thermal installations it should just say so, and do so via so much red tape. Solar thermal falls to smaller (domestic-size scales for many small businesses and it is unreasonable to impose such burdensome, indeed deterrent, metering requirements, unless tariffs were to be increased by around 20% for systems under, say 10kWp. This exemption would also reduce large amounts of relatively low energy value workload for OFGEM.

A solution would be to allow non-domestic installations of solar thermal only who are buying 1-4 solar thermal panels (perhaps say below 5 or 10 kWp) non-domestic solar thermal (and solar thermal only) consumers really do need to be allowed to opt, if they want, for deeming under SAP. [Note: SAP is a simple performance simulation.]

3/ End blatant market rigging in favour of heat pumps. Regarding solar thermal with all other technologies, there is a return on investment market bias against solar thermal. The massive prioritisation of heat pumps (with around 30% electricity parasitics) over with a target 12% RoI while solar thermal (with typically 0-12% energy parasitics) has a mere 5% RoI is wholly unjustifiable in terms of both competition and carbon impact. Please could the returns on investment be levelled?

[The RHI consultation docs are at the bottom of this page: here.]

Fed up with seeing your money / the taxpayer’s money being mugged for non-existent purposes? Please…

1/ Email the consultation by 5 August 2011 at RHIguidanceconsultation@ofgem.gov.uk

2/ Alert your MP. Get their contacts. Send a link to this page. You can email them now from this site.

3/ Write to the press and blog.