|58 Pages of Pure Reading Pleasure|
You can read them here:
As a result, some remaining points of clarification for solar thermal on the scheme have now been made public:
- Solar for space heating / indoor swimming pools are not eligible, in fact solar DHW is not eligible if it is combined with space heating or swimming pool heating.
- Air heating (transpired) solar panels are not eligible.
- Hybrid PV-T panels are not eligible.
- The regulations refer to version 1.0 of the MCS deeming calculation (MCS024) and not the most recent version 1.1, this means that the MCS standard is immediately out of synch with the RHI and it omits the Incidence Angle Modifier from the deeming method, putting evacuated tube collectors at a disadvantage.
I suspect that the solar industry might be most aggrieved by the fact that a solar system that heats an indoor swimming pool is ineligible. Setting aside the politics of envy, swimming pools are an ideal application for solar heating, the low temperature of the pool meaning that panels operate at higher efficiency than when preparing domestic hot water alone.
Under the rules published yesterday, if a solar system is installed to prioritise domestic hot water with a divert to a pool once the hot water is satisfied, then the renewable heat for the domestic hot water is also ineligible. This creates a perverse incentive to install the solar system as two separate systems, one for the pool and one for the hot water.
A simple way to deal with a complex system such as this would be to allow the owner to opt to meter heat rather than deeming it.
The scheme is not set in stone and there will be opportunities to amend it over time. However, if the Department of Energy and Climate Change (DECC) is going to expend resources to do so, then the industry is going to have to build a strong case to support the argument that any prospective change is worth the cost and trouble.
Should any of these omissions from the scheme concern us? What do you think?