gla draft solar action plan - solar-trade.org.uk · the sap, to signpost the planned public...

Solar Trade Association Greencoat House, Francis Street, London, SW1P 1DH t: +44(0)203 637 2945 e: [email protected] w: www.solar-trade.org.uk

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GLA Draft Solar Action Plan

Response on behalf of the Solar Trade Association

About us

Since 1978, the Solar Trade Association (STA) has worked to promote the benefits of solar energy and to make its adoption easy and profitable for domestic and commercial users. A not-for-profit association, we are funded entirely by our membership, which includes installers, manufacturers, distributors, large scale developers, investors and law firms.

Our mission is to empower the UK solar transformation. We are paving the way for solar to deliver the maximum possible share of UK energy by 2030 by enabling a bigger and better solar industry. We represent solar heat, solar power and storage, and have a proven track record of winning breakthroughs in these sectors.

The STA warmly welcomes action by the Greater London Authority to boost solar power, which is the prime technology for enabling neighbourhood and regional action on clean power. We encourage prompt regional action given the current lack of supportive policy from central Government. Our analysis shows that local strategic initiatives can boost solar deployment considerably. We are keen to work with city leaders to maximise local opportunities to boost solar power using existing power, and to improve the national framework for solar.

Respondent details Respondent Name: Aleksandra Klassen (policy analyst)

Email Address: [email protected]

Contact Address: Greencoat House, Francis Street, London, SW1P 1DH

Contact Telephone: 0203 637 2945

Organisation Name: Solar Trade Association

Would you like this response to remain confidential? No

Introduction

Solar power is close to requiring no subsidy, and several applications can already be funded subsidy-free by local authorities given their unique financial advantages. The rapid & unfortunately premature removal of meaningful national support for most rooftop and ground-mounted solar power, and slow progress on national building standards, means the industry is under stress and greatly values positive


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policies by both local and regional Government. With economics on a knife-edge, the GLA has an important strategic role to play to boost market volumes, and make use of innovative investment models, so that the economic case can stack up. Given its strategic role, we are keen to work closely with the GLA to identify all opportunities for scaling up key solar markets; domestic, commercial, social housing and community invested/owned.

All of these key solar markets will need to be stimulated in order to make London a greener, healthier city. Currently, the capital is exposed to severe air pollution daily – over 95% of the population is breathing in one of the most hazardous toxic particles in levels that exceed global guidelines by 50% or more1. As petrol and diesel cars are gradually displaced by more EVs to curb emissions, we need to ensure that the systems in place (e.g. charging infrastructure) are supplied by a cleaner, more solar-based grid.

A Solar Plan Fit for the Future

What the transition to decentralised, low carbon energy has proved thus far is that we need to better future proof our planning. In the UK, technology has surpassed regulation, delivering new business models that will continue to evolve at a quicker pace. The smart power future will provide a much more diverse set of players, not just the standard energy generator, supplier, trader or consumer. Energy services will be upended and the brightest opportunities will lie in the boundaries between these outdated divisions.

A recent strategic report2 urges the UK to plan from the future, which should reflect “multiple consumer archetypes, masses of data, sophisticated data analytics and the potential – for example, through storage and smart devices – to divorce patters on energy service consumption from electricity purchase.”

These forward-looking, holistic narratives have unfortunately been excluded from this draft SAP. The GLA should therefore take a more innovative approach in designing a plan for London to become a smart energy city, which solar will be at the heart of. Solar facilitates the adoption of smart grid technologies and when combined with storage and electric vehicles, will be a key enabler to achieve the Mayor’s objective of making London a zero-carbon city by 2050.

Fundamental to planning from the future is consumers generating and owning their own clean energy. A lot has changed since early 2016, when a NYC resident generated and sold their own solar power to a neighbour in what was the first ever blockchain energy transaction3. Given the inherently similar structural complexities that NYC has— concentrated populations, different building types and property ownership configurations—innovative micro-grid projects are one option the city is pursuing in order to reach the scale necessary to meet their own 1GW solar target by 2030.

1 https://data.london.gov.uk/dataset/pm2-5-map-and-exposure-data

2 https://es.catapult.org.uk/wp-content/uploads/2017/10/Challenging-Ideas_single.pdf

3 https://www.newscientist.com/article/2079334-blockchain-based-microgrid-gives-power-to-consumers-in-new-

york/


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Summary of Recommendations;

The Mayor should officially adopt the 1GW 2030 solar target for London in the final Solar Action Plan (SAP) and London Environment Strategy (LES)

More future proof planning around solar + storage + EVs and wider smart power agenda

Maximise the potential to incorporate solar in new build using powers under the forthcoming London Plan

Work strategically to build volumes in key markets; domestic and public sector rooftop, subject to stringent quality control criteria

Enable solar companies (including those in London) to bid directly into RE:FIT

RE:NEW should work with social housing landlords to bring forward previously scrapped and new projects

Further investigate innovative finance measures that could be better be tailored to needs of strategic housing projects

Consider using grants or other interventions to stimulate now privatised Green Deal

Accelerate and expand solar deployment across the GLA family estate

Develop communications strategy and utilise TfL advertising estate to promote the SAP

Enable Londoners to invest in community-scale projects brought forwards by the GLA

Mayor to commission report on residential storage opportunities in London

Include storage in the LES recommendation for developers to look into generating and storing renewable energy onsite

Include actions to promote greater dialogue between developers and community energy groups

Work with DNOs to identify where in London additional solar capacity would benefit grid most

Work with networks of larger commercial landlords across London to help them refurbish their properties

Establish a dedicated legal entity to offering ISAs that works in partnership with crowd-funding platforms

Lobby Government to invest underspent FIT money into public sector and community-led solar projects

Organise 2018 Cities Solar Summit that brings together metro mayors to look at potential for solar, storage and smarter energy city solutions

Our response addresses each of the SAP’s five objectives, however in addition we also believe the GLA could also make a real difference through creative leadership and communications. We would also like to challenge the GLA to officially adopt the 1GW by 2030 solar target, which we believe should be achievable.

Communicating the London solar opportunity

There is a myriad of ways in which the GLA can capitalise on its leadership status and its charismatic Mayor to encourage investment in solar by diverse potential stakeholders across the city. For example, by publishing a very attractive and compelling Solar Action Plan (SAP) document that showcases the range of solar products available today; by placing ads on the tube, overground and buses to promote the SAP, to signpost the planned public website, and to highlight the Mayor’s energy programmes. The planned GLA website, from a trusted Government source, will be helpful to educate Londoners about the implications of going solar and potential investment opportunities. It is important to advertise this resource.


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Solar is the UK’s most popular energy technology (85% according to the latest BEIS Public Attitudes Tracker) and recent market research 4shows that 44% of homes want to go solar by 2020. Londoners therefore may need only trustable advice and modest support to act. The GLA shouldn’t miss this opportunity to ‘nudge’. According to its own analysis, the GLA does not have a good track record in raising awareness of its projects and events.5 This should further spur the GLA to develop a compelling solar communications strategy and members with marketing expertise would be very happy to help. As a first step we would like to see the GLA effectively utilising space on the world’s most valuable advertising estate6 to promote solar to millions of commuting Londoners every day. And the hard part has already been done: the Mayor approved a budget of up to £1m this year “on services and tools required to deliver effective marketing and engagement campaigns for the GLA, based on willingness to raise awareness about the GLA’s work and to improve understanding and participation in key projects and events”.7

1. Maximising solar energy technologies on GLA group buildings and land

The STA welcomes the Mayor’s aim to increase solar PV on GLA owned and managed buildings and to roll out a mapping tool to assess the full potential for solar generation on GLA estates. By leading on rapid delivery of solar projects, the GLA will be able to provide case studies and tools to encourage other public sector bodies to follow suit. However, we believe that waiting for the delivery of GLA projects on challenging sites should not be a pre-requisite to encouraging public sector land owners to install solar, as suggested in the draft. The GLA should certainly incentivise innovation and pass on lessons learnt from using new technologies, but not at the expense of momentum. Vacant land for example, can deliver some of the greatest value for money in terms of scaling solar deployment and so should be prioritised without delay. Restructuring the RE:FIT programme could facilitate more solar on GLA land too. The recent TfL tender, for instance, resulted in undue confusion and the ultimate prioritisation of large construction firms over dedicated solar developers. STA members provided PV installation pricing, which was deemed non-compliant by the marking team at TFL, because they had not provided pricing for other efficiency measures such as insulation works. In such a sub-contracting scenario, multiple firms’ costs and margins are passed through, which ultimately leads to a more expensive framework for authorities and housing associations to do business with. Similar to quality considerations in reverse auctions (more on this below) safeguards can be lost under sub-contracts. Given the needed strategic solar focus, there

4https://www.solarpowerportal.co.uk/news/four_in_ten_homeowners_want_solar_and_storage_by_2020_says_e.on

5 https://www.london.gov.uk/decisions/md2099-gla-marketing-budget-201718

6 https://www.london.gov.uk/press-releases/mayoral/mayor-in-crackdown-on-body-image-advertisements

7 https://www.london.gov.uk/decisions/md2099-gla-marketing-budget-201718

https://www.london.gov.uk/decisions/md2099-gla-marketing-budget-201718

https://www.london.gov.uk/decisions/md2099-gla-marketing-budget-201718


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should be a discreet process that enables solar companies (including those in London) to bid directly. This will lead to a better result for Londoners too, both for competitive pricing and for quality control.

2. Encourage solar energy installations through the planning system The STA recognises that the Mayor has major strategic planning powers and we urge him to make full use of these to boost rooftop solar across London. We therefore welcome the Mayor’s commitment that he will continue to expect solar to be considered by boroughs and developers to help achieve carbon targets in his review of the London plan and we urge him to further improve standards at the next review, potentially including optimising solar generation potential at the development/building design stage. The cost of installing solar in new developments is lower than retrofitting onto existing buildings as access to the roof space is already available, so costs like scaffolding do not need to be factored in. It is easy and elegant to install panels that are roof or façade integrated enhancing the visual appeal of the building and London already boasts landmark solar developments, like Blackfriar’s Solar Bridge.

Higher energy standards through regulations or planning are effective at increasing tenders for solar PV in new developments. For example, in Scotland, where standards are moderately higher than England and Wales and similar to existing GLA energy standards for strategic developments, we anecdotally believe that 50-70% of all tenders for new build housing are now requiring solar. This is a tremendous improvement that has boosted the solar developing market and sector confidence. The STA will be happy to update the GLA as further information comes forward.

Since the Housing Standards Review and closure of the Government’s Zero Carbon Homes programme in 2016, there has been confusion over the powers local authorities retain to stipulate higher energy standards for new build both for residential homes and offices. The reality is that local government retains tremendous powers, confirmed recently by a Minister in the Lords8. Powers to stipulate a proportion of energy used on developments from renewables under the Planning and Energy Act were left untouched. Furthermore, legislation under the Deregulation Bill that would have removed powers on efficiency standards has not been enacted.

Local authorities are therefore free to set higher standards for new build homes and offices, through either a stipulated proportion of energy saving from renewables, or higher buildings efficiency or carbon performance standards generally. Given this clarification, we strongly recommend that the new London Plan makes full use of these powers and, furthermore that the Mayor encourages all London Boroughs to do the same.

The Mayor has a very good record on planning requirements for major developments, where most planning applications referred to the Mayor do require some solar incorporated in the development – it would be good to see this potential optimised in each development. While the GLA regulations capture most of new housing developments, there is still potential to boost solar in smaller sites,

8 “The noble Baroness asked specifically whether local authorities are able to set higher standards than the national

ones, and I can confirm that they are able to do just that.” https://hansard.parliament.uk/lords/2017-02-06/debates/76AF5263-A938-4851-929D-8CAE765C56B8/NeighbourhoodPlanningBill


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which require planning permission from London Boroughs. Indeed it will be helpful for developers if the GLA could urge all Boroughs to match his new build standards.

Part of the mapping work, which is proposed in the SAP, could be to make it clear what current energy standards are being used by each planning authority in the London Boroughs as this will have a material impact for anyone considering installing solar into a new development.

As for putting pressure on developers’ to reduce their carbon footprints, we welcome the inclusion of a monitored “energy hierarchy” in the draft London Environment Strategy. GLA’s plan to investigate demand side energy savings and potentially implement an energy efficiency target for developers themselves is a sound, comprehensive approach to further tackling emissions. We are particularly pleased to see the suggestion for developers to look into generating and storing renewable energy onsite, and would suggest that storage is included.

The GLA should also ensure that new developments are fit for purpose for new smarter energy systems rather than developers participating in box-ticking exercises. In some cases developers have been known to add 600w PV systems to new homes, eliminating any financial or carbon-reduction benefits. The STA would like to see greater scrutiny of residential developments in terms of the size of PV installs. A presumption could even be built-in for building roofs to be entirely solar, putting the onus on developers to explain why they could not comply if that was the case, as opposed to the reverse situation we are effectively in at the moment.

Lastly, The SAP makes no reference to how the Mayor will engage with London’s distribution network operators (DNOs) on supporting the deployment of solar. The GLA should work with the DNOs to identify where in London additional solar capacity would be beneficial and also where it may prove to be a challenge to the network. This type of information would be valuable to any new development integrating decentralised generation into their building.

3. Help Londoners retrofit solar on their homes and workplaces

Existing Domestic buildings RE:NEW Since its inception in 2009, RE:NEW has directly helped improve over 130,000 of London’s homes and through wider market delivery more than 600,000 homes have been retrofitted. However, following the Government’s cut in FIT rates, the majority of solar projects being developed by RE:NEW were abandoned9. RE:NEW should commit to working with social housing landlords again to bring forward those scrapped and new projects. We understand the difficulty of adjusting to lower subsidies, however, we would point out there is only 18 months left of the FIT to run and returns remain acceptable. It would be wise therefore for London to make as much use of this as possible, having failed to appropriate its fair share of FIT funding in the past.

9 MQ 2016/0480 22 February 2016

http://questions.london.gov.uk/QuestionSearch/searchclient/questions/question_286238


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We would like to see more projects such as Ealing Council’s £1m solar PV project on sheltered housing blocks being developed in London. Ealing Council’s main impetus was to achieve a minimum EPC target of C for their tenanted properties, but they have found it very challenging to retrofit PV: “the cost of splitting up an installation into four or more different flats – just to provide electricity – is not cost effective.”10 The GLA should look further into innovative finance measures that could be better tailored for strategic housing projects.

Furthermore, the GLA should not overlook the potential of solar thermal for RE:NEW, which remains effectively supported under the RHI and which is particularly suited to tackling fuel poverty, given its exceptional reliability and negligible running costs. Solar thermal is also particularly well suited to dense, urban areas, given it requires little roof space and works well at all orientations bar north.

We also agree with the Environment Strategy that the carbon offset funds developed across the majority of London Boroughs need to be extended to all; pooled, and used strategically to tackle fuel poverty through building upgrades. The over 300,000 homes in London struggling with fuel poverty11 can benefit from these funds, which can be potentially be used to support the inclusion of solar PV in the RE:NEW scheme again. As a rough guide, every 1kW(p) of solar PV installed will reduce energy bills by around £60 per annum.

At the same time, deeper retrofits should be better incentivised, so we look forward to the outcomes of the Energy Leap project and hope the London pilot will be successful (as it has been elsewhere12). We hope that a wider roll out of whole house zero energy retrofits will follow.

The Green Deal

The GLA could also consider engaging in, or supplementing, other schemes, such as the “re-born” Green Deal Finance Mechanism now privatised and owned by Greenstone Finance. The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 stipulated that as of April 2018 any private rented property rated EPC F or G will have to upgrade to a minimum of E, provided that the landlord has access to finance which means there is no upfront cost for the improvements. In London roughly a quarter of all homes – 830,000 homes have the lowest energy efficiency ratings13. Currently the main route for delivery is Greenstone Finance, which will be providing these upgrades through its limited amount of contractors. Greenstone Finance is planning to charge interest rates above the highly criticised 8%14 that was charged under the Green Deal, so we are sceptical that much investment will take place using this mechanism. This is of particular concern for London which has the highest proportion of Private Rented Properties in the country.

We would like to see the GLA consider using its grant funds to intervene by taking on some of the risk to bring down interest charges to levels that would stimulate landlords in particular to invest in energy

10 https://www.london.gov.uk/sites/default/files/gla_renew_casestudy_ealing_council.pdf

11 https://www.london.gov.uk/sites/default/files/draft_fuel_poverty_action_plan.pdf

12 http://energiesprong.eu/

13 http://www.ukace.org/wp-content/uploads/2016/07/Energy-Efficiency-in-London.pdf

14https://www.solarpowerportal.co.uk/blogs/in_conversation_kilian_pender_founder_of_greenstone_finance_and_c

eo_of_the


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efficiency and solar solutions that would upgrade their properties to EPC E or better15. The original inspiration for the Green Deal was how the German retrofitting programmes were financed from KfW, the German state infrastructure bank. It is feasible that some GLA retrofitting funds could be used to offer low interest finance for upgrading PRPs with solar. This is exactly the type of innovative green financing that the GLA is also actively looking at.

Reverse auction As the Feed-in-Tariff rates fall, the trick to getting solar economics to work today is to get sufficient volumes of deployment. We welcome the fact that the reverse auction proposal is trying to do just that. We would like to see more instances of the GLA acting to build market volume, not solely focusing on a reverse solar auction.

It is important that such an auction is well designed and does not result in a “race to the bottom” on price alone. The STA is working very hard with its members to ensure consistent, high quality installation so contractors do not cut corners by trying to reach their rock bottom price. Risks of a price dominated reverse auction include companies “buying” the work solely to boost turnover and a higher risk that a contractor will go bust during the contract period as any minor increase in prices from suppliers (e.g., because of exchange rates) or in labour costs (because of Brexit) will have a disproportionate impact on any profits.

If cost is the principal consideration, it is possible that subpar products will be chosen over products that offer a lower operating cost and lower cost of energy over the system lifetime. A poorly designed tendering process risks putting the reputation of the industry at stake and potentially leading to a poor service for the consumer.

Certification presents further questions, as currently there is no system in place to ensure installers register with MCS, RECC or any other certification or consumer protection body after FITs end in 2019. Warranties are another area of concern. Warranties have to be based on a 20-year life cycle including generation, maintenance and replacement. This was not the case for the Solar Together Norfolk Scheme, which had warranties of 10 years only.16 In defence of the scheme, all the installations had warranty-backed insurance policies; thereby covering them in the case the installer ceased trading.

Subject to securing this level of quality assurance, we would support this approach, which will help to improve economics, build market volumes and to directly engage Londoners with the GLA’s Solar Action Plan. The STA would be very happy to work closely with the GLA to ensure that the framework reflects all these concerns in order to give Londoners the best service and product available.

Battery storage opportunities

15https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/651304/Green_Deal_Framework

_-_Call_for_Evidence_-_final.pdf 16

https://solartogether.ichoosr.com/Product/customizableinfo.rails?actionId=414&infoTextId=275


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According to a new study, residential renewable power generation and storage will become profitable for London households by 2030, earlier than in New York City, which has set itself a 100MWh energy storage target in the next couple of years.17 So it is really important that GLA support local pilot projects, which integrate storage technologies with solar PV at an early stage. In addition, the Mayor should commission a report on residential storage opportunities in London to signal the GLA’s interest in battery storage.

Non-domestic Buildings – Building Volume

RE:FIT was an excellent idea but given the issues with the programme mentioned already, we are glad that it will be enhanced to deliver greater amounts of energy savings to public-sector organisations. Particularly exciting are the proposals to aggregate solar projects and to work more closely with academic institutions.

Given the many benefits of larger installations and taking into account London’s lack of space for solar farms, we believe the GLA is not doing enough to incentivise solar uptake on sizable roofs. RE:FIT should deliver more successful schemes such as the +6,000 panel + battery storage installation in Hounslow last year.18 Retrofitting schools and public buildings by offering councils an effective tender scheme, like the one Portsmouth City Council is running would be another way to improve this and to help build volume. Following the FIT cuts in 2016, Portsmouth started offering power purchasing agreements (PPAs) to schools, community centres and external authority buildings. The PPAs reduce the electricity expenses of the sites by delivering clean generated power, and on average the clients usually save over £1,000 per year, dependent on the size and baseload of the building.19 In order to drive capital cost efficiencies whilst remaining compliant with public procurement processes; the authority has established a £10m framework for the design, supply and install of PV. The framework comprises of 12 contractors arranged in 2 tiers; in order that mini-competitions can be run quickly and efficiently, and so that competition is stiff to encourage lower prices. Individual sites are typically wrapped up into larger contracts to deliver further project and contract management efficiencies; though contracts are kept small enough to allow smaller, local businesses to compete for the work. The success of PCC's approach has been noted by other councils, and as a result they are offering their services to other authorities; both as an agent to deliver the works where an authority has funding secured, or as a no-capital PPA offering.

West Sussex is making use of Portsmouth's highly efficient solar tendering programme to rollout a phased programme of solar installations across 50 schools after securing £3m of capital funding. The schools will purchase the solar power from the council-owned solar through a PPA, at lower price than

17 Bevan, Luke and Donovan, Charles, Firm Power Parity: A Framework for Understanding the Disruptive Threat of

Solar + Storage (September 4, 2017). Available at SSRN: https://ssrn.com/abstract=3031992

18 https://www.theguardian.com/environment/2016/may/19/london-borough-installs-6000-solar-panels-on-market

19https://www.solarpowerportal.co.uk/news/portsmouth_city_council_to_spend_millions_on_rooftop_solar_roll_out

https://ssrn.com/abstract=3031992


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retail, which avoids the need for upfront investment. Meanwhile, through a combination of power sales and FIT revenue, the council will recover its capital expenditure in 12 years. This is an excellent example of a council easing the barriers (e.g. FIT cuts and business rates increases) that have been imposed upon the industry by central government. We would like to see the GLA offer the same service to London Boroughs. In the draft SAP, the GLA has acknowledged the detrimental consequence of the hike in business rates; which have risen by eight times for certain sites, but has failed to offer any solutions. According to the STA’s analysis of VOA listings, at least 80% of schools in the UK fall outside of the £12,000 general business rate exemption threshold and are thus liable for business rates, depending on the ownership model. We would therefore urge the GLA to become more engaged in helping schools and businesses install rooftop solar for self-consumption without being penalised. We are also concerned how business rate treatment will impact the nascent storage market in the UK and are currently seeking clarification. We are keen to work with the GLA to level the playing field for solar power and storage with gas CHP, which is excepted from business rates.

Commercial Retrofit

The Mayor's draft Environment Strategy highlights the huge contribution of workplaces to London's emissions (42%), with commercial sector buildings responsible for a third of London's CO2. It is vital that the Mayor engages effectively with the commercial sector to encourage the take up of both solar PV and solar thermal. We warmly welcome the Mayor's planned Commercial Boiler scrapage scheme to help replace boilers with both more efficient boilers, combined with renewable technologies. Solar thermal has an important role to play here and we hope to see this reflected in the SAP. Solar thermal has an extremely high solar energy conversion rate, so takes up relatively modest roof space making it ideal for dense, urban areas. The new 100 Minories Hotel over the river from the GLA has had solar thermal installed (at an angle that makes it invisible from Tower Bridge) to provide sufficient hot water to meet half the needs of 268 bedrooms. The STA is the lead partner on the EU-wide LabelPackA+ project, which recalibrates existing heating technology labelling for technologies up to 70kW to show the need for renewables to reach the highest A+++ levels of performance. The new labelling has been mandatory since 2015 and it includes a 'package label' showing the energy performance of heating systems combining several technologies. Solar thermal is particularly suited to combination with other technologies. We note the other possible ways in which the Mayor could engage with the commercial sector, all of which we welcome. Expanding RE:FIT to the commercial sector would be very welcome and we support a discreet solar retrofit programme here with tendering direct to solar companies. Please see our detailed comments above on the RE:FIT scheme. We would like to understand better how the Mayor will work with networks of larger commercial landlords across London to help them refurbish their properties. There will be good opportunities here and we would be very pleased to offer any support.


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We agree that at a minimum the GLA should provide guidance to the commercial sector. Given the number of possible contacts and interventions that the GLA will be making across the commercial sector, we hope that every opportunity will be taken to encourage the uptake of solar energy. Several STA tools should be helpful to support this guidance. For example, the STA's Commercial Confidence Checklist is designed to give commercial investors confidence in their ability to commission and project manage solar projects20. It is also possible to get around the high business rate charges for onsite self-supply with solar PV and we have made this information available.

4. Help Londoners make informed decisions about investing in solar

Following in the footsteps of cities such as Tokyo and New York that have created interactive maps to assess solar potential on buildings in their localities is a great idea. And expanding the platform to include relevant information will be important for consolidating its value and continuing to drive traffic. The STA would be open to collaborating with the GLA to provide information from our members on best practices of installing PV and solar thermal.

We are keen to boost local clean energy data and to accelerate London’s status as a smart city but would advise the GLA to consult the broad range of existing research in order to evaluate all available options prior to finalising the map and tool for Londoners.

Additionally, the GLA should create more appealing investment opportunities for Londoners, many of whom may want to invest in solar but are not in a property that enables them to do so or who may not have sufficient savings to invest alone. Some pointers could be taken from the very successful Chapel Farm Solar Park, which was installed on a former landfill site owned by Swindon Borough Council.

Public Power Solutions devised the unique blend of public sector and community investment for the 5MW scheme. The solar park was financed with a £3m investment from Swindon Borough Council and the remaining £2.4m came from investors within the local community and across the UK via the first renewable energy bond eligible to be held tax-free in an Innovative Finance ISA, structured by Abundance Investment.

This innovative product allowed local residents to receive a healthy 6% tax-free return on their investment for 20 years, as well as the opportunity to fund a renewable energy project that will not only provide green energy but will enable Swindon Borough Council to use part of its profit from the scheme to fund other much needed local projects. The ISA offer was so popular that it closed three weeks early.

We would like to see the GLA take forward similar community-scale projects that give Londoners, including those with little resources, the opportunity to invest in community-scale schemes. Community energy schemes are an effective way to increase London’s share of solar installation in the UK (currently 2%). Larger sites could be identified within the GLA family estate for community investment and ownership, and indeed Forum for the Future has started a scheme to enable

20 http://www.solar-trade.org.uk/wp-content/uploads/2015/07/STA-confidence-checklist-FINAL.pdf


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commercial companies to ‘donate’ their rooftops for community investment. The GLA should support this.

The launch of the London Community Energy Fund is a very good first step, but we believe that actions to promote greater dialogue between developers and community energy groups should be included in the SAP. The GLA could also underscore and reinforce its leadership by undertaking initiatives directly via the TfL. Bristol City Council’s scheme, which provided opportunities for community energy groups to install solar PV on corporate stock following a competitive tender process would be a project worth replicating.

Local authorities are in the unique position of being able to roll out subsidy-free projects at scale. West Sussex Country Council is completing building a subsidy-free 7.4MW solar farm with 4MW of battery storage on a closed landfill site in Westhampnett this year. The system has been designed to current National Grid requirements for Enhanced Frequency Response - a service that the authority will offer through its current Laser group energy supplier. Like its first solar farm, Tangmere, some of the energy generated at Westhampnett will be ‘sleeved’ back to the council through a Power Purchase Agreement to offset energy costs and reduce the authority’s exposure to energy market price volatility. The council estimates the scheme will pay back in 15 years and generate £7.9m net income. With its own ‘White Label’ local energy tariff in early 2018, the authority also has plans to supply its residents with energy generated in the county.

By combining economies of scale of larger schemes, with the special borrowing requirements of the public sector, together with the tax breaks of solar ISAs, it should be economic to do this today. We suggest the GLA establishes a dedicated legal entity to do this and that it works in partnership with crowd-funding platforms.

5. Call on government to set a national policy framework that unlocks London’s solar energy potential

STA welcomes the Mayor’s decision to pressure Government to provide a clear plan for FITs, but additional steps can be taken to ensure a better outcome for solar. There will likely be a considerable underspend in the FIT budget due to the massive collapse in solar deployment following the FIT cuts. The Mayor should lobby Government for this money to be spent on supporting public sector and community-led projects to get the biggest ‘bang-for-your-buck’.

We agree with the Mayor’s proposal to accelerate supportive policies for battery storage, as current regulation is holding back their deployment. Generally, we are very keen to work with the Mayor of London and other city leaders to press collectively for a more enabling policy and tax framework for local, distributed power. The STA would also like to work with the GLA on a 2018 Cities Solar Summit– bringing together metro mayors to look at potential for solar, storage and smarter energy city solutions.

Other areas we encourage the GLA to consider include:

Cities to join forces to lobby for energy policies

Keeping pressure on government via more collaboration with other local authorities


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Replicate successful, viable council-run projects

Spread best practices in Boroughs

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