Good Energy add FIT conditions regarding storage devices

[sharpener]

Just had an email from Good Energy about their new Ts and Cs for FIT https://www.goodenergy.co.uk/wp-content ... y-2024.pdf, including Sections 4.2.2 and 7 about storage devices.

But they are not very well drafted. Section 4.2.2 says

"You would need to inform Us about include: (i) any modification to Your Eligible Installation which might affect its
eligibility or capacity calculation (including reductions or extensions, storage device,
Smart Meter installation) for the purposes of the FiT Scheme"

but if there was no change to the metering arrangement (Total Generation Meter is still directly connected in series with output of solar inverter) then the storage device cannot affect this so is not notifiable.

Section 7.1 says

"...If You have a storage device connected to or installed for Your renewable electricity
generating system You must notify Us at the start of this Agreement and provide Us with a
copy of the schematic diagram of the storage device which will need to show the
installation, the storage device and the metering arrangements. "

But the Agreement was started in 2011 before I had a storage device and the wording is not retrospective so seems to not to be applicable to subsequent addition of one.

Section 7.2 says
"...If You have an Export Meter, You will only be
entitled to receive FiT Payments for electricity exported to the local electricity network if
Your Export Meter is capable of isolating the amount of electricity exported by Your renewable electricity generating system."

Have started using Victron Dynamic ESS to see whether it will manage my system without nightly interventions according to next day's solar forecast https://www.victronenergy.com/live/drafts:dynamic_ess.

So how will export metering work in practice if I succeed in getting Octopus to fit a Smart Meter, and switch to their Outgoing tariff instead of getting deemed exports via Good Energy? How would they manage to "isolate" the exports from the FIT system, or will Octopus not care whether the exports come from the original FIT PV, my later DC-connected PV or the battery?

[robl]

I think that the issue in future will be deemed export, whilst using a battery (or diverter?). This is just a guess on my part.

You can swap from FIT (generation) + deemed(export) to FIT(generation) + measured(export); once this has happened, you cannot go back.

[nowty]

So how will export metering work in practice if I succeed in getting Octopus to fit a Smart Meter, and switch to their Outgoing tariff instead of getting deemed exports via Good Energy? How would they manage to "isolate" the exports from the FIT system, or will Octopus not care whether the exports come from the original FIT PV, my later DC-connected PV or the battery?

Octopus will accept some "brown" exported energy, its in their T&Cs and is also consistent with OFGEM guidance. Brown being grid energy recycled though batteries.

You just cannot have the energy going though your total generation meter without replacing it with a bi-directional one.

[sharpener]

So how will export metering work in practice if I succeed in getting Octopus to fit a Smart Meter, and switch to their Outgoing tariff instead of getting deemed exports via Good Energy? How would they manage to "isolate" the exports from the FIT system, or will Octopus not care whether the exports come from the original FIT PV, my later DC-connected PV or the battery?

Octopus will accept some "brown" exported energy, its in their T&Cs and is also consistent with OFGEM guidance. Brown being grid energy recycled though batteries.

So if OFGEM will allow brown exports are Good Energy being overprescriptive in saying you must have a smart meter that distinguishes the FIT from other exports? Don't see how it could be done as there is no way of unpicking the FIT, DC-connected and battery power flows since IIRC there is no MID-compliant way of measuring power on 48V DC circuits. And my MPPT and battery are both connected directly to the 48V studs on the inverter. (The battery pack incorporates a DC breaker, though getting the screw-down waterproof cover open in an emergency is another issue!)

You just cannot have the energy going though your total generation meter without replacing it with a bi-directional one.

Don't understand. The TGM is as originally fitted to the FIT inverter circuit, backflow is not possible (apart from the 3W needed to run the inverter in stand-by mode at night).

I think you mean a bidirectional meter on the grid connection? But AIUI all SMETS2 meters have this capability though the DNO needs to allocate a separate MPAN for the exports.

[nowty]

So how will export metering work in practice if I succeed in getting Octopus to fit a Smart Meter, and switch to their Outgoing tariff instead of getting deemed exports via Good Energy? How would they manage to "isolate" the exports from the FIT system, or will Octopus not care whether the exports come from the original FIT PV, my later DC-connected PV or the battery?

Octopus will accept some "brown" exported energy, its in their T&Cs and is also consistent with OFGEM guidance. Brown being grid energy recycled though batteries.

So if OFGEM will allow brown exports are Good Energy being overprescriptive in saying you must have a smart meter that distinguishes the FIT from other exports? Don't see how it could be done as there is no way of unpicking the FIT, DC-connected and battery power flows since IIRC there is no MID-compliant way of measuring power on 48V DC circuits. And my MPPT and battery are both connected directly to the 48V studs on the inverter. (The battery pack incorporates a DC breaker, though getting the screw-down waterproof cover open in an emergency is another issue!)

You just cannot have the energy going though your total generation meter without replacing it with a bi-directional one.

Don't understand. The TGM is as originally fitted to the FIT inverter circuit, backflow is not possible (apart from the 3W needed to run the inverter in stand-by mode at night).

I think you mean a bidirectional meter on the grid connection? But AIUI all SMETS2 meters have this capability though the DNO needs to allocate a separate MPAN for the exports.

On the first point OFGEM allow it but specifically say its up to the FIT provider whether they want to pay it or not.

On the second, I'm simply pointing out that some folk can retrofit a hybrid inverter with storage in place of their original FIT inverter, In that case its against the rules if the storage has grid charging capability unless you retrofit a bi-directional TGM with the agreement of the FIT provider. I.e. the bi-directional meter prevents anyone from clocking up the TGM.

[sharpener]

On the first point OFGEM allow it but specifically say its up to the FIT provider whether they want to pay it or not.

On the second, I'm simply pointing out that some folk can retrofit a hybrid inverter with storage in place of their original FIT inverter, In that case its against the rules if the storage has grid charging capability unless you retrofit a bi-directional TGM with the agreement of the FIT provider. I.e. the bi-directional meter anyone from clocking up the TGM.

1. OK, now I get it (I think). If you mean the (new) SEG provider - Octopus say - not the original FIT provider - Good Energy, who I would intend to stay with as changing that will involve sending Octopus a whole load more paperwork. (New 2022 PV system installer initially said no MCS cert could be provided as it was DC connected, soon changed his mind when I withheld £500.)

2. Yes I can see that introduces complications which presumably GE intend the new Ts and Cs to guard against. Fortunately my original PV install is completely unaffected by the battery system - though it has had four master inverters replaced like-for-like under warranty, don't plan on telling them about those either(!)