Senvion Australia submission: Victoria’s Renewable Energy Roadmap Introduction Senvion Australia has delivered approximately 10% of the Australian wind energy market with a total of 440 megawatts of wind capacity installed across 9 wind farms in Victoria and New South Wales. The majority of our work has been in Victoria, and we have delivered over 30% of the State’s 1,229 MW of operating wind farms. Senvion’s Melbourne-based Australian team is also responsible for the Senvion Group’s presence in the Asia Pacific region, including Japan and New Zealand. We are very encouraged by the Victorian Government’s strong commitment to renewable energy and welcome the opportunity to provide input into the development of its Renewable Energy Action Plan. Key points - Senvion Australia welcomes the Victorian Government’s commitment to increasing renewable energy in the State. - Moving to a lower carbon economy will require increased energy efficiency, the managed exit of existing coal-fired power stations as well as targeted policies to support the increased uptake of renewable energy. - Future targets for renewable energy should at least match global ambitions to tackle climate change. Targets should be developed in the context of a broader energy strategy for Victoria. - We look forward to the Government’s discussion paper on community-owned wind farms later this year, and are keen to see that community projects be exempt from the current “no-go” zones in the planning system. - In its advocacy work, we would encourage the Victorian Government to continue to highlight the importance of targeted renewable energy policies as an essential element of a broader framework of policies to deliver climate change action. - Senvion Australia welcomes the Government’s commitment for 100 megawatts of new renewables. An ongoing and longer-term commitment to purchasing renewable energy would help to restore much-needed investor confidence in the renewable energy sector. - We support the introduction of targeted policies to manage the exit of existing coalfired generators. We also support targeted action to assist local communities that are affected by the closure of local power plants. - Senvion Australia supports the Government’s commitment to improve the connection process, and identify grid constraints. - In the Government’s planned investigation into energy storage, we would encourage the Government to look at the role that energy storage could play in facilitating an increased uptake of renewable energy, and the policies needed to support this. - If there is a strong and sustained market for new renewable energy projects, then employment and manufacturing opportunities will emerge. - Senvion Australia would encourage the Government to provide favourable support to businesses that are looking to establish local manufacturing capability in the renewable energy sector. - Senvion Australia welcomes the proposal to introduce a Renewable Energy Advocate in the State. Detailed submission Transforming Victoria’s generation stock towards renewable energy The Victorian renewable energy roadmap acknowledges that moving to a lower carbon economy requires a transformation of the energy sector. In order to make any meaningful contribution to global efforts to tackle climate change, Victorians will need to rely less on abundant brown coal resources for power – which can only be achieved through energy efficiency improvements, and a shift to cleaner energy supplies. Luckily, Victoria has abundant renewable energy resources, making it well positioned to significantly increase its clean energy generation infrastructure. A 20% renewable energy target by 2020 in Victoria sends a good signal of intent to both renewable energy developers and investors. However, strong and supportive policies to attract investment in clean energy in Victoria are needed to ensure that this target becomes more than just an aspirational goal. By 2030, the level of ambition for renewables must increase significantly in line with international consensus about the urgent need to move towards lower carbon energy systems in order to tackle climate change. Determining specific targets should be done as part of a broader discussion about Victoria’s future energy mix. In particular, renewable energy policy should complement policies designed to tackle Victoria’s ageing and greenhouse intensive fleet of coal-fired power stations. Analysis indicates that moving to 100% renewable energy in Australia is technically possible. For example, an exploratory study by AEMO looking at scenarios of 100 per cent renewable energy in the NEM in 2030 and 2050 found that, in the context of a high level review, “operational issues appear manageable”1. However, this study also noted that accelerating the uptake of renewables would lead to stranded assets in the form of existing generators – which is an area that could benefit from effective Government policy. From Senvion Australia’s experienced perspective, the wind industry has the capacity to significantly ramp up delivery of new wind farms in Victoria. 1 https://www.environment.gov.au/climate-change/publications/aemo-modelling-outcomes 3.1 – Advocate for strong Federal Government policy on renewable energy While the uncertainty around the future of the RET to 2020 has been resolved, a key question for the clean energy sector is what the longer-term policy framework for renewable energy looks like. We therefore welcome the Victorian Government’s commitment to continue to advocate for strong clean energy policies at the federal level. Unfortunately, in current debates about emission reduction pathways, renewable energy is often dismissed as not delivering least-cost abatement. This perspective misrepresents the essential and cost-effective role that renewable energy plays in transforming energy infrastructure to deliver ongoing greenhouse emission reductions in the long-term. In its advocacy work, we would encourage the Victorian Government to continue to highlight the importance of targeted renewable energy policies as an essential element of a broader framework of policies to deliver climate change action. 3.2 – Reform of Victoria’s wind farm planning laws We welcome the Government’s actions to remove some of the most onerous barriers to wind farm development in Victoria, such as reducing the right of veto to 1 km. We look forward to the Government’s discussion paper on community-owned wind farms later this year. We are aware that a number of community proposals are currently in “no-go” zones, and are keen that this is resolved in the planning system. 3.3 – Using Government energy purchasing to support renewables Senvion Australia welcomes the commitment by Government to source Renewable Energy Certificates for around 100 megawatts from new projects in Victoria. An ongoing and longer-term commitment to purchasing renewable energy would help to restore investor confidence in the renewable energy sector. As an example, the ACT wind auction Stage 1 (200 megawatts) and Stage 2 (a further 200 megawatts currently in process) have been incredibly important in stimulating investment in renewables at a time of great policy uncertainty. 3.4 – Review policy options to transition generation stock in Victoria Victoria is home to some of the oldest and most greenhouse intensive fossil fuel generators in the world. These generators have played a critical role in Victoria’s economic development by providing us with cheap and reliable power. However, increased global awareness about the impact of greenhouse pollution, and increasing community concerns about the health impacts of coal-fired power have created a strong rationale to facilitate the closure of existing brown coal generators in Victoria. There are significant barriers preventing the exit of existing coal-fired power stations. Government has an important role to play to facilitate the strategic and measured closure of these power plants. While the closure of existing coal-fired power plants is inevitable in the absence of effective policies, the timing is unpredictable. This unpredictability is not good for the local communities that house the power plant workers, and does not give investors clarity about the future opportunities for renewable energy. We support the introduction of targeted policies to manage the exit of existing coal-fired generators. As an example, the US is taking a leadership role in this area by introducing carbon pollution standards for new and existing generators. We also support targeted action to assist the transition of local communities that are affected by the closure of local power plants, particularly in helping them build the skills and industries to support a new, clean energy, economy. In parallel, there continues to be a need for strong and effective policy to promote clean energy, including renewable energy. Addressing barriers to distributed generation and storage 4.1.1 – Improved process for distributed generation connection 4.1.2 – Investigate technical grid constraints impacting on distributed generation Senvion Australia supports the Government’s commitment to improve the connection process, and identify grid constraints. Our company would be very happy to provide access to our technical experts to discuss their experiences of connecting wind farms in Victoria. 4.3 – Review of market status and regulatory settings for energy storage Lower cost energy storage has the potential to support the increased penetration of naturally variable renewable supply. In the Government’s planned investigation into energy storage, we would encourage the Government to look at the role that energy storage could play in facilitating an increased uptake of renewable energy, and the policies needed to support this. Encouraging household and community renewable generation 5.1 – Provide support for pioneering community energy projects Senvion Australia is proud to have delivered Australia’s first community wind farm at Hepburn. We welcome the Government’s commitment to support community energy projects. A key priority must be to act on the Government’s intention to exempt community wind farms from the current no-go zone restrictions in the planning system. Government role in facilitating the uptake of renewable energy When Senvion first established its headquarters in Australia in 2002, Victoria was seen as the best place to invest. An ambitious wind energy target, and a clear policy framework were significant factors in establishing a Melbourne office, and Senvion now employs over 90 people with the majority based in Victoria. As is noted in the roadmap, changes to the policy environment both at a State level in terms of onerous planning restrictions, and at a national level in terms of policy uncertainty about the Renewable Energy Target have had a significant impact on investment in our sector. Our organisation has shrunk considerably compared to our peak where we employed over 300 people. We are encouraged by the return to a supportive environment for renewable energy in Victoria – but investors require stable long-term policies. Longer-term renewable energy targets, and a clear policy about the exit of coal-fired generators will provide the clarity that investors in clean energy are seeking. We are hopeful that stable Government policy will provide greater clarity in the sector in the future. 6.1 – Promoting new energy jobs and technologies We welcome the Government’s commitment to promoting new energy jobs and technologies. If there is a strong and sustained market for new renewable energy projects, then employment and manufacturing opportunities will emerge. One of the most disappointing outcomes associated with ongoing uncertainty about the national policy framework for renewable energy over many years has been that the industry has not been able to fully realise the significant manufacturing opportunities associated with new wind farms. In addition, a lack of certainty about the future for renewables has curtailed industry investment in local training and education. For example, several years ago, Senvion Australia ran Australia’s first wind farm specific electrician apprentice program in partnership with RMIT. The program received over 700 applicants for 10 places, highlighting the appetite for this sort of training. Unfortunately, we have not been able to continue this initiative in the absence of a more stable future market for wind farm projects. The ACT wind auction has seen some very exciting local projects emerge in the training and education space as a result of a tender process that requires successful projects to also deliver direct benefits to the ACT. 6.2 – Provide information to support renewable energy uptake 6.2.1 – Develop industry development plans Senvion Australia believes that there would be value in looking at the supply chain for renewable energy projects and identifying opportunities to support local manufacture and supply. Senvion Australia would encourage the Government to provide favourable support to businesses that may seek to establish local manufacturing capability in the renewable energy sector. The ACT auction demonstrates that local benefits of wind farms can be amplified given the right policy settings and incentives. 6.2.2 – Update renewable energy project and resource map From the perspective of the wind industry there is enough information about wind energy projects and resources in the public domain. This activity may be useful to less mature renewable energy technologies. 6.3 – Renewable energy project facilitation 6.3.1 – Reinstate coordinated renewable energy project facilitation Senvion Australia welcomes the Victorian Government’s return to facilitating renewable energy projects and believes this will be helpful to attracting investment into new renewable energy projects in the State. 6.3.2 – Investigate new models for renewable energy project facilitation Senvion Australia welcomes the proposal to introduce a Renewable Energy Advocate in the State. Our experience with the equivalent role in NSW has been positive, and provided a useful connection between industry and Government. 29 September 2015