The Future For Small-Scale Low-Carbon Generation

The Department for Business, Energy & Industrial Strategy published a document in July regarding the future of small-scale low-carbon generation, to which the Technical Committee have responded to the questions relevant to AMPS.

This follows the launch of the Clean Growth Strategy which set out 50 major policies and plans to help us in the words of Claire Perry, Minister of State (Business, Energy and Industrial Strategy) (Energy and Clean Growth) “cut the cost of energy, drive economic growth, create high value jobs right across the UK, and improve our quality of life.”

The aim of the call for evidence is to identify the role small-scale low-carbon generation can play in maximising the advantages for the UK in the global shift to clean growth by understanding:

  • The challenges and opportunities from smallscale low-carbon generation in contributing to government’s objectives for clean, secure, affordable and flexible power; and
  • The role for government and the private sector in overcoming these challenges and realising these opportunities.*


A call for evidence, The Department for Business, Energy & Industrial Strategy, July 2018. Full document can be found on the AMPS Website:

Please find our response to the call for evidence as below: Note: Only relevant questions have been answered.

Have we accurately captured all the opportunities and benefits that small-scale lowcarbon generation can provide to the UK energy system over the short, medium and longerterm? Are there any that we have missed? Please provide evidence.

No comment.

How can government help consumers benefit from small-scale low-carbon generation such as local communities, local authorities, and those in fuel poverty?

One of the challenges for these stakeholders is the complexity (perceived or otherwise) of this technology. In an era when people struggle to simply change supplier, the concept of small scale ‘behind the meter’ generation, storage and time of use tariffs is likely to be a step too far. The advantages of, and complexities of the future smart networks needs to be abstracted from the end user by commercial wrappers and smart systems that will simply present the customer with a ‘pence per kWh’ bill. Government should work with the industry to push for a simple offering that delivers 80% of the benefits with little or no input from the consumer. There may be a handful of ‘tech aware’ customers who can become involved in the final 20%, but these should not be the first target.

The introduction of enabling technology and systems such as the roll out of smart meters, and half-hourly settlement, will provide commercial incentives on energy suppliers to develop and offer tariffs. Will smart tariffs provide a viable route to market for small-scale low-carbon generation? If so over what time frame, and what are the possible barriers to these smart tariffs?

The issue with half hourly metering and the associated smart tariffs is the lack of a long term price signal that this gives to small investors. Some form of CfD type assurance or floor price (and perhaps a ceiling price to avoid cost overruns) would encourage the investment.

Given the slow roll out of smart meters and the chance that the 2020 deadline will be missed anyway, it is unlikely that tariffs could be developed and demonstrated before 2025 and are unlikely to get widespread acceptance.

Do you agree with the challenges we have identified? Are there any challenges small-scale low-carbon generation presents that you think we have missed? Please provide evidence.

One of the biggest challenges facing the distributed generation industry currently is the inability to connect to the DNO networks. This is taking a long time to resolve and whilst some changes such as the introduction of queues and a revamping of National Grid’s Statement of Works process has improved the visibility of the issues the underlying lack of investment is still there. The rapid rise of intermittent renewables caught all parties by surprise, but the response has been slow, possibly due to the regulatory timescales. DNO need to be allowed to invest ahead of demand to allow for the future scenarios being present in this document otherwise we may have the same problem again in 10 years – assuming the current problems don’t strangle deployment in the short term.

How would you propose the small-scale lowcarbon sector, suppliers, off-takers, network/system operators, and/or government can overcome the challenges presented?

No comment.

What are possible ways to track and monitor behind the meter installations (we would appreciate specific suggestions in relation to how information can be sourced (e.g. direct from businesses and households) and the method for sourcing it (e.g. an annual survey))?

From April 2019 all generation above 800 W will need to apply to the DNOs for connection approval. This will provide a lot of visibility of new ‘behind the meter’ equipment installed. Properly configured and capable smart meters