50kW farm solar projects after April 1 (now with EPC D)

Since the announcement that there are yet more feed-in tariff cuts on the horizon, many solar companies are being approached by farmers who are keen to install 50kW of solar PV on 1/4acre of land or a barn roof before the rates are reduced on July 1.

For many, at the current feed-in tariff (FiT) rates, 50kW of solar PV on a farm still makes strong financial sense, as an outlay of ~£90k pays back ~£380k over 25 years.

However, the FiT cuts are not the only bump in the road. On April 1 a new requirement was put in place where a ‘building’ to which a solar PV system is attached must be independently assessed to meet Energy Performance Certificate grade D (EPCD) or above in order to claim FiTs.

But how does this work for farms with a mixture of grain barns, cowsheds and/or workshops and offices?

After studying the wording of the ‘Government Response to Consultation on Comprehensive Review Phase 1 – Tariffs for solar PV’ (without falling asleep!) and Ofgem’s ‘FiT Guidance for Installations v3’ (issued on March 30, enacted on April 1) Orta Solar proposes two routes forward to its farmer clients:

  1. Start the PV installation process with a commercial EPC assessment on one of your farm ‘buildings’ connected to the proposed PV system, and then consider the cost of upgrading it to meet an EPC grade D as part of the PV installation.
  • Advantage: the PV system would deliver savings on the electricity consumed in all ‘buildings’ connected to the installation, alongside the savings achieved through additional upgrading works,
  1. Electrically disconnect the ‘buildings’ from the ‘non-buildings’ (perhaps by installing new metering, distribution boards or electricity supply) and connect the solar PV system to the latter.
  • Advantage: lowest cost to install the solar PV
  • Disadvantage: would not save electricity used in the ‘buildings’ (maybe losing out on £2-3k savings annually)

But what are ‘buildings’ and ‘non-buildings’?

Paragraph 43 of the consultation states, “...it should be possible to obtain an EPC for any building that meets the definition of building set out in the Energy Performance of Buildings Directive (it is important to note that this includes buildings which are not currently required under that Directive to have an EPC when sold, let or built) 8”, the note 8 referring to, “8 Directive 2002/91/EC on the energy performance of buildings”.

This defines a ‘building’ as, “a roofed construction having walls, for which energy is used to condition the indoor climate; a building may refer to the building as a whole or parts thereof that have been designed or altered to be used separately”.

So that is clear: a barn with open sides is not classed as a ‘building’. Nor is a grain barn, or un-heated milking shed, both of which are often substantial consumers of electricity, as they do not use energy to condition the indoor climate.

This is good news, as it is now clear that an EPCD is not required on a structure that does not fall into the definition of a ‘building’.

However, what happens in the case of a chicken shed where energy is used to condition the climate, but it is used as part of the internal process rather than conditioning the indoor climate for human occupancy? Should this type of structure meet the EPCD requirements?

So far no answer has been provided by the Department of Energy and Climate Change (DECC) on this type of grey area, but Dr Jonathan Scurlock, the Chief Renewable Energy Adviser at the National Farmers’ Union (NFU) is lobbying hard for clarification in such instances.

Further confusion

Where this also gets muddled is the latter part of paragraph 43 of the consultation which states, “Additionally, in many cases we expect that solar PV installations which are attached to a building for which it is not possible to obtain an EPC, will nonetheless be wired to provide electricity to a building that is able to obtain an EPC. For example, this might include a solar PV installation attached to a barn that is also wired to provide electricity to a farmhouse. In this example, the requirement would still apply and could be met if an EPC were provided demonstrating that the farmhouse was rated at EPC level D or above.”

The reality is that almost every commercial farm that Orta Solar visits to install solar PV has several three-or single-phase supplies (different tariffs, metering, supply points and maybe even different suppliers) supplying a mixture of the farming operation ‘non-buildings’ and the occupied ‘buildings’ on the farm.

Here Ofgem’s guidance states, “Where an installation is attached to or wired to provide electricity to a number of buildings that are relevant buildings only one of those buildings needs to satisfy the energy efficiency requirement.” Hence the straightforward solution is to carefully select the most economically upgradeable ‘building’ amongst the selection of ‘buildings’ on a farm to ensure that it meets an EPC D requirement.

Independent commercial EPC assessments should cost in the region of £200 and the recommendations to upgrade the ‘buildings’ may have an upfront cost but should be designed to pay back in terms of energy saved.

What does this all mean?

Our conclusion at Orta Solar is that the choice between disconnecting electrically the buildings and non-buildings or securing and EPC D on one of your buildings comes down to an analysis of the individual farm situation, calculating the electrical savings benefits to be had by connecting the PV to all of your buildings (by upgrading one to EPC D) versus the potential costs of doing so.

Installing 50kW of solar PV on most farms post April 1 has certainly become a little more complex demanding a good quality solar partner who takes time to understand the clients farming operations and electricity usage to gain maximum benefit.