Following a number of queries and differing interpretations, I recently sent a query to the CRC Helpdesk requesting clarification on how to report electricity generated from solar PV.
I have reproduced both my questions and the Helpdesk’s answers below.
1) When reporting electricity generated from solar PV, should it be reported as core or residual supply?
The consolidated guidance document refers to electricity generation from renewables on pages 55-56. Para 4.6.2 says that the electricity that you use (whether it receives FIT or not) should be reported as core supply or residual supply where applicable. This suggests there is the possibility of self supplied renewable electricity being classed as either core or residual – so the question is how is this determined?
In the definition of non-core supplies (para 3.2.4, pages 36-37) electricity is classed as non-core where it is generated onsite and it is classed as self-supply and it is not measured through a meter. However, this wouldn’t apply in all instances, as many supplies are measured through a meter.
One interpretation is that this depends whether it is connected back to the grid via a core or non-core meter (i.e. the supply is received through a core or non-core meter).
-If it is core, then you must report the electricity generated each year in your annual report, and it should appear with other core electricity supplies, calculated at grid average.
-If it is residual, then you may choose to report the electricity generated or not, assuming you can meet the 90% rule when excluding it. If you include it, it should appear on your Residual Measurement List (RML) and on your annual report alongside any other residual supplies, again calculated at grid average.
Can you confirm whether this is correct?
CRC Helpdesk answer:
How you report self generated electricity is, as you state in your email, dependent on how it is measured i.e. via a core meter.
2) When the electricity generated does not have an export meter, how should you report the quantity of electricity self-supplied vs the quantity exported?
Guidance para 4.6.3 says you must report electricity you have generated and self supplied for which you have received a FIT payment. It notes that this excludes the electricity you export to third parties.
If the supply is connected to the grid but you do not have an export meter, it is usual for the purposes of calculating FIT payments to deem a 50/50 split. In this case it would seem logical and reasonable to report 50% of what is generated as self-supplied electricity. As you have documented evidence (in the form of the FIT payments) to demonstrate that you have used 50% and the remainder has been exported, you can reasonably exclude 50% as unconsumed supply.
Can you confirm whether this interpretation is correct?
CRC Helpdesk answer:
On your second point, providing you can suitably demonstrate the amount of supply you use then your approach would be acceptable.
I have to say that I find these responses somewhat less than detailed; however, I would be happy to rely on them, in my evidence pack, to justify the approaches that I have outlined. The questions were deliberately very specific, and the responses broadly support the approach taken; however, it is up to you whether you choose to rely on this when submitting your own reports.
If you would like me to forward the CRC Helpdesk’s email to you, to add to your evidence pack, please contact me.