Energy efficiency rules spark confusion for new solar arrays

Additional energy efficiency regulations for new solar installations that came into effect this month are causing some confusion among the industry. Paul Spackman sheds some light on what’s happening.

Recent changes to the Feed-in Tariff (FiT) scheme mean that, from 1 April 2012, new solar PV installations up to and including 250kW must demonstrate the energy efficiency of certain buildings to which solar arrays are attached.

The Department of Energy and Climate Change says that where possible, an Energy Performance Certificate of grade D or better will be required to qualify for the full FiT payment rate, otherwise a reduced rate of just 9p/kWh will be paid for the lifetime of the FiT. An EPC will be needed at the time of application for FiTs.

But while application of the new rule may be fairly straightforward for domestic properties installing solar, it has sparked a great deal of confusion for those installing systems on agricultural buildings such as grain stores, livestock and poultry sheds and workshops or offices.

Many farm buildings are exempt from the EPC requirement, but others could be required to produce one, particularly where the solar installation is wired into or connected to other buildings that could be assessed for an EPC.

Ofgem, which administers the FiT scheme, recently published some guidance to clarify the situation, as summarised below.

What systems are affected?

• New PV installations with an eligibility date on or after 1 April 2012, which are attached to a “relevant building” or wired to provide electricity to one or more such buildings

• Does not apply to solar arrays installed and registered for FiTs before 1 April 2012, but does include extensions to existing arrays

• Excludes stand-alone PV installations.

What is a “relevant building”?

It is defined in legislation as “a roofed construction having walls, for which energy is used to condition the indoor climate” (for example, heating and cooling systems). It may refer to the whole building, or parts of it that have been designed or altered to be used separately.

The definition is aimed at buildings where heating or cooling is used to condition the climate for human occupancy, such as homes, offices and other workspaces.

Buildings that don’t use energy to condition the climate within them, such as barns with open sides, grainstores or unheated milking parlours, are therefore not classed as a “relevant building” and an EPC will not be needed to claim the full FiT rate. In many such cases, it may not be possible to get an EPC anyway, although the NFU’s Jonathan Scurlock says it is down to the FiT claimant to prove an EPC cannot be obtained and a document signed by an accredited EPC assessor confirming and explaining this may be required.

Where the complications begin

There are certain agricultural buildings where energy is used to heat or cool the building interior, such as in a poultry unit, or coldstore/packhouse. However, in such cases, it is argued that the energy is being used for a production process and not for human occupancy, so an EPC should not be required.

However, DECC is yet to confirm whether such buildings need to provide an EPC, although the NFU is lobbying with the solar industry to get clarification as soon as possible.

Additional confusion potentially arises where other buildings are wired to the same metered circuit as a solar array attached to a building that does not need an EPC. If any of these other buildings share the same Meter Point Administration Number as the solar array and are able to obtain an EPC, such as a farmhouse or farm office, then at least one of them will need to meet the required energy efficiency grade D for the full FiT rate to be received.

Where the solar array is attached or wired to more than one relevant building, only one of these needs to meet the energy efficiency requirement.

This could make it slightly easier to ensure the nominated building meets the required grade D. However, in many farm situations it is not always that straightforward, says Nick Pascoe, managing director of Orta Solar.

It may also be possible to electrically disconnect the relevant buildings (that require an EPC) from those that don’t and connect the solar array to the latter, he adds. This will require new metering, distribution boards or electricity supply, but will avoid the need for an EPC to claim FiTs. However, it also means that you could miss out on an electricity savings that would have been used in those buildings.

“The obvious solution is to select carefully the most economically upgradeable ‘relevant building’ among the selection of buildings on a farm to ensure that it meets an EPC D requirement.

“But the reality is that many commercial farms have several three- or single-phase supplies. These are often on different tariffs, metering, supply points and maybe even different suppliers, supplying a mixture of the farming operation ‘non-buildings’ and the occupied ‘relevant buildings’ on the farm. It can take some time to work out exactly what is connected where.”

Getting an EPC

EPCs can only be produced by energy assessors who are a member of a government-approved accredited scheme for that type of building, and who have the appropriate qualifications or experience.

A number of companies offer independent commercial EPC assessments, which should cost around £150-300, says Mr Pascoe. The recommended energy efficiency upgrades to the buildings (such as insulation, double glazing, low energy lighting, gas fired condensing boiler) will have an upfront cost, but should be designed to payback in terms of energy saved, he says.

Despite the additional regulatory burden of the EPC requirement, in most cases upgrading energy efficiency should make business sense, Dr Scurlock adds.

• A searchable database of accredited non-domestic and domestic energy assessors is available on behalf of the government on the Landmark Information Group website.

• You can also search to see whether an EPC exists for a property.

• Detailed guidelines from Ofgem, Feed-in Tariffs: Guidance for renewable installations (Version 3) 44/12 are available to download

What does an EPC contain?

Energy Performance Certificates provide energy efficiency ratings for all types of buildings, based on factors such as:

• Age and layout of the property

• Activities going on within the different spaces

• Materials used in construction

• How it is heated, cooled and ventilated

• How lighting is provided

Ratings are standardised and presented in a similar way to those found on white goods – such as fridges and washing machines – grade ‘A’ is the most efficient rating and ‘G’ the least efficient.

Other information included on an EPC includes:

• The EPC number and date of issue

• Details of the energy assessor responsible, including their name, accreditation number, employer’s name (or any trading name if self-employed) and accreditation scheme

• Information on how to complain or check whether an EPC is genuine

An online register of EPCs is held on the Landmark Information Group website

EPCs for business properties are valid for up to 10 years but cannot be amended. If you want an EPC to show improvements you have made in a building’s energy efficiency, you will have to commission a new one.

For more information, go to the Business Link website and click on Environment & efficiency > Cut energy costs > Energy Performance Certificates – business properties