As the legislation underpinning the RO and FIT schemes (such as the Renewables Obligation Order 2015 and The Feed-in Tariffs Order 2012 (as amended)) does not refer to or define storage or storage facilities, the co-location of storage with accredited renewable generation is neither expressly permitted nor prohibited. Therefore, the extent to which the accreditation of RO generating stations or FIT installations remains valid under the existing legislative framework depends on the specific circumstances of the generator’s facility.
Ofgem’s paper attempts to give some guidance on this matter and there are five key principles that operators of RO generating stations or owners of FIT installations should consider when thinking about co-locating storage with generation accredited under these schemes:
- Accredited RO generating stations or FIT installations are required to give notice to Ofgem of any co-located storage in the same way as they are required to notify Ofgem of any changes to the generating station or installation, or the way in which support under the RO or FIT scheme is to be claimed;
- The accreditation requirements under the RO and FIT schemes are not altered by the presence of a storage facility co-located with an accredited generating station or installation. In order to remain accredited, generating stations or installations must still maintain compliance with all scheme eligibility requirements;
- Generators can only receive support for eligible renewable electricity generated by an accredited RO generating station or FIT installation. This excludes any electricity produced or discharged by a storage facility;
- In most cases, the Total Installed Capacity of the RO generating station or FIT installation, against which benefits under the RO and FIT schemes are measured, will not be altered by the installation of a co-location storage facility. This is because storage is not directly referenced as an eligible generating technology under the RO or FIT schemes and, in most cases, is not essential to the operation of the generating station or installation. The storage facility would, therefore, not be considered part of the RO generating station or the FIT installation and so the Total Installed Capacity (TIC) of the generating station or installation would not be affected; and
- The type of storage technology installed will not affect Ofgem’s assessment of the availability of RO or FIT scheme support for any eligible electricity generated.
In summary, Ofgem advises that where the requirements of the RO and FIT schemes continue to be met, storage can be deployed and the accreditation of RO generating stations or FIT installations can remain valid under the existing legislative framework. However, depending on the specific circumstances of the develop and its facility, choosing to co-locate storage with an accredited RO generating station or FIT installation may have impact on the ability to claim the full amount of support that the generator would receive under the RO and FIT schemes.
If you have any questions on how Ofgem’s guidance may affect you or your business, please do not hesitate to get in touch.
For further insight on Behind the Meter battery storage, please find our series of articles on our Expert Insights page.