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Response to Scottish Government consultation on the transition from the ROS to CfD


On Friday 1 November, Scottish Renewables and RenewableUK responded to the Scottish Government's consultation on the transition from the RO (Scotland) to the Contract for Difference. 

Our key points include:

  • concerns over the potential implication of the recent amendment to the Energy Bill - Clause 49 ‘Closure of support under the renewables obligation’ tabled by Baroness Verma. 
  • The Scottish Government’s commitment to renewables, and particularly the approach taken to fostering the development of nascent and innovative technologies, has assured Scotland’s place as an ideal location for inward investment and for indigenous growth in the fields of equipment, supply-chain and infrastructure. Scottish Renewables and RenewableUK support the Scottish Government’s rights of differentiation when setting support levels and tailoring the policy to Scottish specific circumstances. We would therefore prefer the amendment to reflect the current settlement, believing these powers should continue to remain with the Scottish Government until the Scottish Government closes the Renewables Obligation (Scotland) later this decade. 
  • In the event that Clause 49 is agreed to in the House of Lords, we welcome urgent clarity on how the Renewables Obligation (Scotland) will function during the transitioning years, and particularly, detail around the role and powers of the Scottish Government in governing the mechanism. This is particularly pertinent given the Scottish Government’s commitment to provide an 18 month grace period for those accrediting under the Innovative Offshore Wind band.

 In summary, our key points to the consultation questions are as follows:

  • An option to signal intent to enter the RO should be made available at the same point in time as application for a CfD by allowing generators to notify Ofgem of their plan to choose the RO scheme.
  • Such notification should be accompanied by documentation demonstrating that the project concerned can feasibly be delivered before the closure of the RO, including i.e. a grid connection agreement with a date before 31 March 2017 and contracts with suppliers that allow project completion by the RO closure date.
  • If a project has been notified to Ofgem and accepted by the regulator as deliverable by the closure date, then the project should be allowed a grace period of 12 months for a small project and 18 months for a large project, whatever the reason for delay; projects of 50MW and above should be regarded as large for these purposes. We believe that marine projects should be the exception to these rules, given that build-out is highly weather-dependent, and that therefore all marine projects should be allowed a grace period of 18 months if they have notified Ofgem appropriately.
  • There should be time limits on the ability of developers to notify Ofgem of their intention to enter the RO and secure these grace periods: we believe large projects should not be able to notify after 1 April 2015, and small projects after 1 April 2016.
  • ·Generators should not be penalised for withdrawing from a scheme whilst relevant legislation has not received royal assent and state aid approval
  • Where possible, DECC should seek to align the RO notifications, grace periods and notification of intents with CfD policy (or vice versa) to facilitate the transition from one scheme to the other.

For further information, please contact a member of the Scottish Renewables Policy Team. 

Posted on 01/11/2013

sr-ruk_response_to_transition_from_the_ros_to_c... (328.8 KB, pdf)