Darebin City Council Submission to the Inquiry into Feed-in Tariff Arrangements and Barriers to Distributed Generation Darebin City Council (Darebin) welcomes the opportunity to provide a submission to the Inquiry into Feed-in Tariff Arrangements and Barriers to Distributed Generation. Darebin welcomes the review of feed-in tariffs in anticipation of an outcome that will continue to encourage the installation and production of small scale renewable energy and provide more certainty into the medium term for both consumers and the renewable energy industry. Darebin is currently in the process of investigating cogeneration at both the Northcote Aquatic and Recreation Centre and the Reservoir Leisure Centre and we are aware of both the considerable benefits of and the barriers to distributed generation in the Victorian context. In the context of the introduction of a National Carbon price, Darebin notes that while a price on carbon is an important device to encourage cost effective mitigation responses across the Australian economy; it will not be a solution in itself and must be well supported by a broad range of complementary measures that effectively address the many barriers to climate change action. Darebin City Council, on behalf of our community has long been an advocate for a gross feed-in tariff and continues to support a generous, fair and consistent feed-in tariff as a complementary measure to the carbon price. Darebin's Climate Change Action Darebin City Council has established a leadership position in terms of managing greenhouse gas emissions from Council Operations and in working with the Darebin community to facilitate community emissions reduction and respond to increasing energy costs. Darebin achieved its 2010 corporate greenhouse emission reduction target ahead of time by reducing emissions by 20%, based on 1995 levels, in 2008/2009 and has kept emissions below the 2010 target since then. Darebin's Climate Change Action Plan identifies the energy hierarchy as a guiding principle. The energy hierarchy identifies a priority order for taking action: energy conservation; energy efficiency; investment in renewables via GreenPower and small scale renewables; and offsetting only residual emissions. Darebin has recently updated its greenhouse inventory reporting methodology to the National Greenhouse and Energy Reporting System and is working towards Carbon Neutrality for Council operations by 2020. Darebin has also endorsed a Community Climate Change Action Plan that sets an ambitious carbon neutral target for the Darebin Community by 2020. The three key strategic directions of the plan are: provision of targeted services and programs including a solar hot water rollout for residents and energy efficiency programs for low income residents and those from diverse cultural backgrounds; strengthening of community networks and mobilisation on climate change and advocacy. Darebin has participated in a number of programs and initiatives to increase the uptake of solar panels in the municipality including participation in two 'bulk roll-out' programs one led by Manningham City Council in 2009/2010 through which more than 220 Darebin, Banyule and Whittlesea residents installed a solar system and again in 2011 through the Northern Alliance for Greenhouse Action, led by the Moreland Energy Foundation in which more than 170 households installed a solar system across the region. These programs involve a City of Darebin Submission to Climate Change Act Review competitive tendering process delivered by Council to select a good value solar system option which is then promoted to the community. This reduces the barriers of knowledge/time involved in researching options and upfront costs for our community. The projects also involve some risk however in regards to quality assurance of workmanship, Council reputation and delivery of the program in a highly changeable policy and cost context. Darebin's climate change action, both in terms of demonstrating leadership in Council's own operations and in supporting the community to reduce greenhouse gas emissions has been recognised in a range of prominent environmental awards: Winner of the National Environs Australia Award for Achievement in Sustainability - Urban and Larger Councils category (August 2009) Finalist in the Premier's Sustainability Award in the Local Government category (March 2010) Winner of both the Local Government Energy Saving Champion Award and the Local Government Green Powered Champion Award at the EcoBuy Awards (May 2010) Winner of the United Nations Association of Australia's Meeting the Greenhouse Challenge Award (June 2010) Winner of the Department of Infrastructure, Transport, Regional Development and Local Government Award for Community Climate Change Action - which also featured Darebin's leadership in reducing emissions in Council's own operations (June 2010) Finalist in the National Banksia Awards for Leading in Sustainability Award Setting the Standard for Large Organisations (October 2010). Solar Feed-in Tariffs Darebin City Council makes the following points to the inquiry: At a solar seminar delivered by Darebin in 2008 more than 180 residents attended and indicated that the key barrier to installation was upfront cost and the key reason for installing a system was for environmental reasons The recent Premium feed-in tariff facilitated unprecedented demand for solar panel installations in Victoria. While small scale renewables are less cost effective (per MWh generated or per tonne of greenhouse emissions abated) than large scale renewable energy programs or energy conservation and efficiency; they have multiple other benefits. Solar panels capture the imagination of the Victorian public and appear to promote an engagement and awareness in energy literacy and energy efficiency that is unparalleled by educational programs alone. They also serve as a very real, tangible and local reminder of renewable energy generation. These additional benefits, particularly in regard to energy literacy and efficiency outcomes, are areas that warrant further research and investigation. We understand that the carbon price will still impact residents who elect to purchase 100% GreenPower (as the base tariff for GreenPower costs is determined by the cost of conventional energy). The introduction of a carbon price is therefore unlikely to favour the other key opportunity for households to voluntarily choose renewable energy. This is inappropriate and should also be reviewed. Darebin also notes that the urgency and magnitude of the threats presented by climate change requires action on all fronts - a price on carbon; energy conservation and efficiency; large scale renewable energy investment; and Page 2 City of Darebin Submission to Climate Change Act Review promotion, facilitation and adequate incentives for the increased uptake of small scale renewables. Feed-in tariffs contribute to 'green jobs' and more than 3,000 people are employed in the solar industry in Victoria. The recent changes at short notice to Australian and Victorian Government policy has had a substantial negative impact on the industry. Any ongoing feed-in tariff should continue to reduce the payback of investment in a solar system below 10 years. While the impacts on other electricity consumers, particularly low income households need to be considered, Darebin notes that subsidies to the solar industry remain disproportionately small to the subsidies and public infrastructure investment in fossil fuel energy sources, which are also ultimately borne by consumers. Darebin also strongly supports the use of appropriate tariffs, concessions and energy efficiency support to mitigate rising energy cost prices (from all sources) on low income households. Distributed Generation Darebin City Council makes the following points to the inquiry: Darebin notes that distributed energy generation has significant potential to make a positive contribution to Victoria's electricity supply in terms of: a reduction in greenhouse (and water use) intensity of the Victorian network; enhanced demand management opportunities both locally and more broadly; and reduction in the risks of depending so heavily on a small number of large generators for most of Victoria's energy needs. There is considerable community interest in local distributed generation opportunities and 'localised energy supply'. It is presently very challenging to plan for the costs and time involved in even relatively small and straightforward cogeneration installations (parallel, grid connected and no feed-in) due to the uncertainty around the network augmentation requirements that may be required for any given specific system. The system needs to be decided upon before augmentation requirements can be assessed, costed and approved by the distribution business resulting in uncertainty around project costs and timeframes. Distribution Businesses have a geographic monopoly in Victoria and each have their own approach to distributed energy investigations and approvals. Darebin has three distribution businesses within the municipality. There is no legislative or statutory requirements, nor incentives, for Victorian Distribution Businesses to process and facilitate distributed generation connections in a timely and efficient manner. While we are aware that there can often be technical barriers due to substation loadings and grid fluctuation profiles etc the delays, costs and differing requirements imposed on these connections by Distribution Businesses appear to be excessive and inconsistent. The complexity, uncertainty around costs and timing of the approval process is a strong disincentive for pursuing larger projects that could have significant community benefit including feed-in to the grid, supply of electricity or heat to neighbouring properties or enabling facilities to continue to operate in island mode to provide community services and potentially emergency response opportunities in black out situations. Page 3 City of Darebin Submission to Climate Change Act Review Conclusion Local government plays a key role in implementation of sustainability initiatives and advocacy and promotion of environmental programs, products and services for our residents. Darebin appreciates the opportunity to provide input into this review, would be happy to participate in further discussion and welcomes the opportunity to make further comment on the draft report later this year. For further information please contact: Libby Hynes, Manager Environment and Natural Resources, email: lhynes@darebin.vic.gov.au phone : 8470 8442 Page 4