The new energy efficiency requirement for the feed-in tariff (FiTs) for solar PV kicks in on 1 April 2012. This means that the full FITs rate is only available for buildings which have an Energy Performance Certificate of band D or above. This is currently a bit less than half the UK housing stock.
The good news is that the installation of solar panels is in itself an energy efficiency measure and will bring some properties that are currently band E to band D. However, don't assume that is the case. The EPC algorithms are complicated, and the only way to be sure is to run the data through the software. Installations that don't meet the criteria, will get a significantly lower level of generation tariff: 9p per kW instead of 21p per kW for systems of 4kW or less.
The bad news is that there are a lot of questions about what buildings are exempt, and detailed guidance from Ofgem is still not available. Here are some pointers to what's in and what's out.
The common question is what about a barn in a farmyard? This is quite simple: the key bit is in DECC's FiT FAQs. It says: "Under the requirement, PV installations will only be eligible for standard FIT tariffs if they can provide a valid Energy Performance Certificate (EPC) at the time of application for FITs, showing a rating of level D or above for the property to which the solar panels are attached or wired to provide electricity."
So if the solar PV system was providing electricity for use in the farmhouse, then the farmhouse would need to have an EPC band D. Potentially, if the farmyard has a separate electricity bill, and a separate MPAN number from the farmhouse, and was not wired to the house, it may not need an EPC.
Generators will need to satisfy their FiT licensee (energy supplier) and Ofgem that it is not possible to obtain an EPC for a particular building, and that it is not wired to a building that could. Decisions on eligibility are ultimately a matter for Ofgem and the FiT supplier, not DECC.
Another condition that will contribute to a building's eligibility is whether it is capable of being heated or cooled. The issue of how they will deal with large, unheated warehouses or factories that have a small heated office space in one corner is not yet clear.
The STA is thinking of putting a series of case studies on its website as they occur to enable people to see how individual decisions are reached. Early exemptions will be considered on a case by case basis.
However, there will definitely be some buildings for which it is impossible to reach EPC band D. An example of this is old churches. When confronted with this unfairness at the Solar Power UK Roadshow in Newmarket, Alasdair Grainger, of the DECC feed-in tariff review team pointed out that FiTs have never been fair. "I live in a flat, so I can't install solar panels," he said.