Can you commission before supply is available?

[ktech]

I have a customer for a 30kW system that needs the supply upgrading. The DNO are going to provide the supply in September. However the customer has asked if we can install before 1st July to get in before the next tariff change / potential panel price increases we keep hearing about re Chinese tax. We have looked into this before and spoken with Ofgem on what the term commission actually means but they never give a straight answer. For example do you think you could complete all dc testing and class the installation as commissioned and register for the FiT on the existing mpan then leave the system off until the upgraded supply is installed. Or even use a generator to commission and register?

 

[TedM]

OFGEM have clarified this: http://www.ofgem.gov.uk/Sustainability/Environment/fits/Documents1/FIT generator guidance.pdf

2.23. The term “commissioned” is defined in FIT legislation as meaning:

In relation to an Eligible Installation, that:
(a) such procedures and tests have been completed as constitute, at the time they are undertaken, the usual industry standards and practices for commissioning that type of installation such that it is capable of operating at its Declared Net Capacity (assuming that the relevant Eligible Low-Carbon Energy Source was available to it without interruption or limitation), and
(b) the installation is connected to Plant such that the whole of its maximum output could be used in a permitted way.

For this purpose:
(1) the maximum output of an installation is the amount of electricity that it would generate if operated at its Declared Net Capacity; and
(2) electricity is used in a permitted way if it is:
(i) consumed by the FIT Generator or (if different) the operator of the installation, or by persons to whom it is supplied by the FIT Generator, or
(ii) Exported.

2.24. During our assessment of an application for accreditation, we will request independent verification that the Eligible Installation in question has been commissioned. This information will be assessed against the definition in the FIT Order. Such verification could take the form of:
- notice from the Distribution or Transmission Network Operator that the installation was permitted to export to the grid, for example witnessed G59/2 test documentation
- confirmation from the installer as to the date on which the installation was commissioned, and/or
- An audit report from an independent party that attests to when the installation was commissioned and the configuration of the installation at the relevant date.

 

[BruceB]

Not sure which way, if any, Ted is suggesting the clarification falls in this circumstance.

With a bit of effort to limit exported current to the grid, then you should be able to commission the system as long as you have a lower capacity grid connection available now.

 

[Earthstore]

Could the customer not have the upgrade done by an independent, and not the DNO?
I could put you in touch with the right people if you PM me.

 

[TedM]

Sorry, I saw that as so straightforward so as to not need explanation.

I interpret 2.23 (a) and (b) to mean that the full DNC has to be operating for the system to be considered commissioned but 2.23 2(i) and 2(ii) make it clear that this does not need to be exported. I would say that 100% could be used on site (not difficult if you borrow a few 3kW heaters). But you would still need to satisfy all of the conditions in 2.24.

 

[Earthstore]

Could it be a problem if the DNO want to witness it?

 

[Gavin A]

so let me see if I've got this straight...

We install 5kWp systems limited to 16amps, register them as that 5kWp meaning they get a lower FIT rate, then delimit the inverter if the DNO gives permission for a greater output.

Ofgem have quite clearly stated to us that the inverter output is irrelevant when it comes to determining the TIC for FIT rates.

So what they appear to want to happen here is that they have their cake and eat it, as either the inverter is irrelevant for determining the FIT rate, or it's not irrelevant, it can't be both relevant and irrelevant at the same time depending on how it suits ofgem.

I mean, if it's the inverter output that counts, then just commission it as a 10kW system, limited to 10 kW at the inverter, then when you get DNO permission, register the additional 20kW as an extension to the system and claim for that on the 10-20kW fit rate, and your customer will be quids in. I'm not actually suggesting you do this, but this is the logic of what they're saying in that quote.

For reference, there is no part of the MCS commissioning sheet that asks for confirmation that the inverter output is set to the maximum output, or anything similar, so the system can be fully commissioned with the inverter output restricted IMO.

Ofgem FIT compliance team, making it up as they go along again...

 

[ktech]

Nothings simple is it! Probably the biggest problem I have is the customer currently has a single phase supply. The DNO upgrade is to supply new overhead 11kW cabling to a new 100kVA transformer. So we can't actually connect the three phase inverter to the single phase supply to commission that side of it. We could run it up off a generator on a grey day with some local load but seems daft to get a generator for half an hour!

 

[Gavin A]

ah, well in that case you're scoobied. Could install 1/3 to a single phase inverter and register that, then use single phase inverters for the other 2 phases when available... maybe. Not entirely sure how that'd comply with the balanced generation requirements.

 

[Earthstore]

Ketch, as I said, If he wants the install then get somebody else to do the upgrade, the DNO do not always have to do that side of things, just the connection to the grid.
But he will be pushing it for the first of July.

I think Gavin is right, you are "scoobied"

 

[Gavin A]

I think Gavin is right, you are "scoobied"

classic 80s/90s slang revival caused by swear filters...