Friends of the Earth (FoE) and Solar Century, the main protagonists behind the recent legal challenges over Government’s handlings of the solar feed-in tariff, have spearheaded recommendations that ministers adopt an ‘Under-Deployment Trigger’ that would see FiT rates rise if installations fell short of expectations.

The proposed under-deployment trigger would work in exactly the same manner that DECC’s over-deployment trigger would – meaning that if less than 25 percent of the central deployment scenario is delivered than the feed-in tariff should be raised to stimulate demand and drive installed capacity. FoE argues that the proposals in their current guise are “one-sided” and only capable of dampening demand.

The group contends that the FiT has been immensely successful, delivering over 200,000 installations and creating an additional 27,000 jobs in solar PV alone. FoE believes that each installation undertaken is estimated to create some 14 days’ paid work and that, every 25 installations provide an equivalent of one year’s paid employment. However, the group are concerned that installed capacity in year one under the new revisions will not support the level of jobs that the industry currently holds. Greg Barker’s much-touted 22GW ‘ambition’ for solar will be hard to realise if job losses ravage the industry in the short-term. As a result, the group have expressed concerns over the absence of the explicit mention of the 22GW ambition in the consultation.

Another proposal put forward in the group’s response to the consultation was for Government to collect data on cost of PV as part of the FiT register. The proposal is a direct response to the controversial Parsons Brickenhoff report that was put together in just four days, from 11 sources in the summer of 2011. The response suggests that each participant in the FiT scheme should be required to submit the cost of the installation upon application. If this were to happen DECC would hold up-to-date costs data on all PV installations across the country, allowing the department to make informed decisions about setting tariff levels.

The response also provides a renewed call for Government to revise the Renewable Energy Roadmap to include solar PV. As solar is now below the marginal cost of renewable energy at some scale, the rationale that certain types of solar should only qualify for 4.5p, because solar has no role in meeting the renewable energy target, is “outdated and therefore should be revised.”

The group note that, because the consultation proposes that tariff degressions are to take place with just two weeks’ notice, many solar projects with a longer time-span than two months before FiT registration will not know which FiT rate they will be eligible for. This uncertainty will make key investment decisions near impossible and jeopardise the future of longer-scale solar projects. FoE has called on the department to adopt the same process available for non-solar projects and allow PV projects to be eligible for the FiT rate at an earlier stage of the project’s development.

FoE maintains that the two fundamental principles that drive the feed-in tariff are: simplicity and certainty. If the suggested improvements submitted to DECC are adopted, the group believes that the scheme can continue to support the UK solar industry, open up the energy market and help combat climate change successfully.

The charity’s response to DECC’s phase 2a consultation is supported by, the Renewable Energy Association, the Solar Trade Association, The Federation of Small Businesses, the Country Land and Business Association, the TUC, The Public and Commercial Services Union and the Lib Dem LGA group among others.