Changes to the ‘backwards-counting meter’ principle for PV under 10 kVa in 2020 and 2021: essential questions answered

From 2021, you will be able to apply for a PV installation premium to replace the ‘backwards-counting meter’ principle. But the complexity of the legislation raises many questions. PV-Vlaanderen provides a number of answers below.

 

Question 1: If I do an AREI inspection on the temporary site meter for the PV installation at a new-build property no later than 31/12/2020, will my customer receive a backwards-counting meter?

Answer: The FAQ states the following with regard to this:

The PV installation can be connected to the site distribution unit and inspected in this way. There is compensation on the site distribution unit meter at that time. When the PV installation is changed to its definitive connection, another inspection of the whole interior installation is required. The date of this inspection is decisive and no compensation is therefore possible if this inspection takes place in 2021. The final PV installation inspection date must always be observed for the whole installation behind the connection point, not just the provisional date for the AREI inspection of the PV installation.

The people at PV-Vlaanderen think this wording is unclear and open to interpretation, and have therefore asked for clarification on this issue, but have not yet received an official answer. They have however received confirmation that PV installations that are connected directly to a fuse in the site distribution unit will not be entitled to a backwards-counting meter. 

There seems to be no discussion for them if the definitive digital meter is present.

The compromise proposal to allow an inspection of a new building without the digital meter is as follows: 

-        The property is wind and watertight and the solar panels have been installed on the roof. (We advise you to take photos and email them to zonnepanelen@fluvius.be no later than 31/12/20 with your customer in CC, in case there are any discussions at the start of 2021).

-        The power distribution unit is in its definitive place with its definitive power cable (even if this cable is connected to the temporary site meter).

-        The definitive earthing is present. There is a differential present in the power distribution unit and, as well as the cable that goes to the PV installation, there is also a second electricity cable that goes to at least one electricity outlet (such as a light or plug socket). The better the interior house installation, the less possibility of any discussion there can be.

PV-Vlaanderen and subsequently GPC will keep you informed about whether this proposal is accepted, and have also asked VREG, Fluvius, VEA & the Department of Environment to include these clarifications in their FAQ.

 

Question 2: My inspector does not have time for an AREI inspection. What can I do? 

Answer: You can find an overview of all possible inspection bodies here: https://economie.fgov.be/sites/default/files/Files/Energy/Installations-electriques-liste-d-organismes-agrees-pour-le-controle-Elektrische-installaties-%20lijst-van-erkende-organismen-voor-het-uitvoeren-van-controles.pdf. It is not yet fully clear whether inspectors from Wallonia can be used. (There is currently no 31/12/2020 deadline in Wallonia). There must be at least a translation of the inspection certificate. We will keep you informed about this. 

 

Question 3: What is the impact of extensions to the backwards-counting meter and green energy certificates? 

Answer: There is no difference between an extension in 2020 and 2021. For an extension with AREI inspection, the 15-year period remains for both the initial installation and the extension, whereby the date of commissioning (AREI inspection) of the original installation counts as the start date for the 15-year period. This is also the case when the extension takes place in 2021.

Inverters that are connected to an installation that does not qualify for a green energy certificate may be extended. 

Inverters that generate electricity which does qualify for a green energy certificate may not be extended and an additional inverter must be installed, unless this installation does not exercise its right to green energy certificates. The inverter power for an existing PV installation may be reduced at any time, which may allow for greater extension while retaining the backwards-counting meter. 

If an extension takes place to more than 10 kVA, the customer loses the right to the backwards-counting meter. This right is retained if the existing installation already qualifies for green energy certificates. A network study must be carried out prior to the extension to more than 10kVA. 

 

Question 4: What happens in the event of a complete relocation of a PV installation? 

Answer: The complete relocation of a PV installation is regarded as a new installation or an extension at the new address. 

If there is not yet a PV installation present at the new address, the standard rules for installing a PV installation apply. 

-        If the installation was relocated no later than 31/12/2020, there is a right to backwards-counting meter for 15 years (unless there is a ruling from the Constitutional Court that fully or partially nullifies this regulation).

-        If there is not yet a PV installation present at the new address, and the relocation takes place on or after 01/01/2021, then the installation is covered under the new regime without a backwards-counting meter.

-        If there was already a PV installation present at the new connection point (from before 2021), the relocated installation will be treated as an extension to this original installation, even if this relocation takes place in 2021. The backwards-counting meter then applies for this installation for up to 15 years after the AREI inspection of the first installation, unless a subsequent ruling from the Constitutional Court nullifies this regulation.

-        If the inverter that is relocated is not on the latest C10/26 list, then it must be replaced with an inverter that is on this C10/26 list together with the relocation.

-        For a relocation of a PV installation to a new-build property or in the context of a major energy renovation after 01/01/2021, these panels can no longer be included for the EPB calculation. 

 

Question 5: There is already a PV installation in my property, or there was in the past. Can I install a new installation and apply for a premium in 2021?

Answer: Only one premium may be granted for a photovoltaic installation per building, on the condition that no other photovoltaic installation has yet been commissioned behind the connection point in question. 

There is one exception to this, i.e. in the case of a transfer of ownership where the installation was already decommissioned before the transfer of ownership. Qualification for the premium therefore only applies if the previous PV installation was installed by the previous owner, decommissioned, and unregistered with Fluvius prior to the transfer of ownership.

 

Question 6: Can I receive a premium for an extension to a PV installation? 

Answer: No premium can be claimed for an extension.

 

Question 7: What if I want to relocate an installation that was inspected in 2021? 

Answer: PV installations for which a premium has been granted may not be relocated to a different property for a period of at least 15 years after commissioning. If it is relocated, the premium will be recovered.

 

Question 8: What if I relocate a PV installation with backwards-counting meter to a connection point where a PV installation was installed for which the premium was granted?

Answer: The photovoltaic installation for which a premium has been granted may not be extended with an installation that benefits from the backwards-counting meter, unless the network user in question has irrevocably waived this right. 

GPC offers a full range of high-quality photovoltaic solar energy products (solar panels, inverters, mounting material and solar accessories) and battery systems for engineering firms and installation companies. Our goal? To make renewable energy solutions accessible to everyone. The final objective: a more sustainable society with fewer CO2 emissions.

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