Renewable energy trade associations have collaborated in a letter to energy and climate change secretary Amber Rudd, condemning her department’s actions over feed-in tariff pre-accreditation consultation which closed this week.
The letter, sent before the consultation closed on Wednesday and seen by Solar Power Portal, criticises what the associations call an “inadequate consultation process”, a lack of evidence provided by the Department for Energy and Climate Change (DECC) and the perceived “inappropriate timing” of the consultation given the looming feed-in tariff review.
“We believe that the government has not followed the correct procedure with this consultation [and] we believe that the consultation is both new and contentious and should be given the appropriate 12 weeks or more,” the letter reads.
Soon after the consultation was announced Friends of the Earth (FoE) sought to question the legitimacy of its timeframe, stating its belief that the government had broken its own ‘Gunning Principles’ which stipulate the recommended guidelines for public consultations. DECC refuted the suggestions at the time and while FoE suggested legal action could be forthcoming, there has not been any suggestion this has been carried out.
The trade associations also sought to clarify why no impact assessment had been produced by the government unlike it had done with the Renewables Obligation consultation which was released on the same day. The letter argued that it was “impossible to answer” the consultation with no evidence to counter.
The argument surrounding the timing of the consultation stems from an understanding that the comprehensive FiT review consultation is to be published imminently, and the associations have questioned why both consultations could not be rolled into one.
“This would allow the industry to gauge the full impact and provide feedback on the overall picture, rather than piecemeal proposals at present.
“Pre-accreditation is an essential component of the current FIT system’s architecture and is key to investor confidence. Through the FIT review this year, it is possible that higher degression rates are likely to occur. By removing pre-accreditation prior to this review, a large proportion of long lead time projects will be left completely unviable.
“We would argue that the removal of pre-accreditation is unjustified, and can in no way result in benefits that would outweigh the impacts, which in any case government has not attempted to quantify,” the letter read.
Speaking to Solar Power Portal, STA business analyst David Pickup said the association hoped the letter would cause the secretary to carefully consider the potential impact of the proposals. “We don’t think the process for this consultation was right – it is a short consultation in the middle of summer, making it difficult for the industry to respond and no evidence has been provided for our analysts to examine and respond to,” he added.
REA solar policy analyst Lauren Cook said: “The degression mechanism has been designed to bring down tariffs in line with deployment and solar is already subject to possible quarterly degressions. The option of pre-accreditation has helped projects with longer lead times secure financing based on guaranteed rates. Removing the option of pre-accreditation will hurt the areas of the industry the government has expressed support for, such as commercial and industrial rooftops.”
The letter was signed by Matt Hindle, head of policy at ADBA; Simon Hamlyn, chief executive of British Hydropower Association; Emma Bridge, chief executive of Community Energy England; Nina Skorupska, chief executive of Renewable Energy Association; Maf Smith, deputy chief executive of RenewableUK; Niall Stuart, chief executive of Scottish Renewables; and Paul Barwell, chief executive of Solar Trade Association.