Frequently Asked Questions - closure of the Renewables Obligation (RO) to small-scale solar PV
Guidance
Publication date
Scheme name
RO
This page is for operators of solar photovoltaic (PV) generating stations in England, Wales and Scotland affected by the closure of the RO scheme to small-scale solar PV on 1 April 2016. It should be read alongside the ‘RO: Guidance on the closure of the scheme to small-scale solar PV’ and the ‘RO: Guidance for generators’.
1. What is changing?
The RO has closed to small-scale solar PV operators from 1 April 2016. However, operators of small-scale stations that meet certain criteria may be eligible for a grace period, meaning that they can apply for accreditation for 12 months after the closure date, ie from 1 April 2016 until 31 March 2017.
2. Can I submit my grace period evidence to Ofgem for assessment before I build my project?
No. The legislation is clear that the grace period assessment is to be carried out alongside the accreditation application. We cannot advise on grace period eligibility before accreditation.
3. Will I receive assurance on my grace period evidence if I apply for preliminary accreditation?
No. Preliminary accreditation will only assess general RO eligibility, and will not include any assessment of grace period evidence.
4. Does Ofgem need to have finished assessing my application by 31 March 2017 for my station to gain accreditation?
No. Your accreditation date is the later of the date you submitted your application and your commissioning date. The time it takes for us to review your application does not affect this. Please refer to chapter 4 of the guidance for information on submitting a complete application to us on or before 31 March 2017.
5. When is an application for planning permission considered ‘made’?
Considering the Development Management Procedure Orders, we would expect this to be the date that the original application (including all required items) for the generating station was submitted to the relevant planning authority. The relevant planning authority must confirm when the application for planning permission was made.
6. The requirement for a ‘valid’ planning application does not address inconsistencies in how local authorities approach planning applications. Can Ofgem remove this requirement?
No. The decision to include a requirement for a ‘valid’ planning application (as defined in the Town and Country Planning (Development Management) Order applicable to the station was a policy decision taken by DECC. Ofgem administers the RO on the basis of the RO legislation. The RO Closure Etc. (Amendment) Order 2016 requires that an applicant provide evidence that a valid planning application for the station was made on or before 22 July 2015 for it to be eligible under the significant investment grace period.
7. My planning authority asked me to resubmit my application/provide further information/further payment after 22 July 2015. Does this mean my planning application was not valid?
We don’t judge whether planning applications are valid, so you should direct all queries or concerns about the validity of your application to the planning authority. We will accept the judgment of the planning authority on whether an application you submitted on or before 22 July 2015 was valid, and will not intervene in disagreements over the decision made by the planning authority.
8. What if the distribution network operator (DNO) or local planning authority won’t provide the required evidence?
The legislation is clear about the information you need to gain from the DNO and we encourage you to speak to them about the required evidence. We cannot grant a grace period without this information.
Based on the requirements of the legislation, it is not clear to us how any party other than the planning authority can truly deem a planning application to be valid, and as such we recommend you speak to your local planning authority. It may be helpful to show them our guidance.
9. There have been variations to my grid connection offer since I accepted it, or changes to my planning permission since I submitted it. Is my station still eligible for a grace period?
We are aware that variations may be made to grid connection offers and planning permission applications. If the original offer or planning permission is for the same generating station that you are seeking accreditation for and the dates of these original documents are in line with the requirements of legislation, the station will still be eligible. Please refer to chapter 3 of the guidance for further details.
10. The planning permission for my site was issued to a different entity, and then novated. Will this affect my eligibility?
The RO Closure Order 2014 does not specify that the planning permission or grid connection offer must have been issued to the person applying for the grace period. Therefore, the party the planning permission or grid connection offer was issued to will not form part of our grace period assessment.
11. How can I ensure my application is assessed as quickly as possible?
So we can make decisions promptly, you must understand the legislation and guidance before submitting an application to us.
If applications for accreditation and the grace periods are right first time, we can assess them more quickly. If evidence is not clear, or is missing, and if applications appear to be speculative, it will take us longer to assess them, and delay our final decision. You also need to respond to our queries as soon as possible. Please refer to chapter 4 and Annex 1 of our guidance for further details on applying.
12. Can I submit my metering details after I have submitted my application for accreditation?
We recognise that operators may not yet have metering details available when submitting their application for full accreditation. You may still submit an application before you know these details, and up to two months before the anticipated date of commissioning the station. Please update your application with this information as soon as it becomes available.
13. What if my commissioning data/evidence cannot be provided until after 31 March 2017?
If your station does not commission until just before the grace period deadline (eg on 31 March 2017), we recognise that it may not be possible to submit commissioning evidence before that date. If your station is due to commission just before the end of the grace period, ensure you submit your application on or before 31 March 2017, and submit your commissioning evidence as soon as this becomes available.
14. What will happen if I try to apply on 31 March 2017, but the register is not working?
Generators looking to commission their stations by this deadline should submit accreditation applications well before 31 March 2017 (you are able to submit an application for full accreditation up to two months before the expected commissioning date) so they don’t risk problems accessing the system.
If you do apply on 31 March 2017 and encounter problems, please email renewable@ofgem.gov.uk and a paper application form will be emailed to you which you will need to return to us before 1 April 2017.
15. What happens if I apply after 31 March 2017?
You will not be eligible for RO support if you apply and/or commission after 31 March 2017.