Sender: Clean Energy Council
Address:
Level 15, 222 Exhibition Street
Melbourne VIC 3000
Australia
Tel: +61 3 9929 4100
Fax: +61 3 9929 4101
Email: info@cleanenergycouncil.org.au
Web: cleanenergycouncil.org.au
ABN: 84 127 102 443
Date: 30 September 2015
To: Victorian Government Department of Economic Development, Jobs, Transport &
Resources
Address:
1 Spring Street
Melbourne Victoria 3000
By email: renewable.energy@ecodev.vic.gov.au
Clean Energy Council submission
to Victoria’s Renewable Energy
Roadmap
The Clean Energy Council (CEC) is the peak body for the clean energy industry in Australia.
We represent and work with hundreds of leading businesses operating in solar, wind, energy
efficiency, hydro, bioenergy, energy storage, geothermal and marine along with more than
4,000 solar installers. We are committed to accelerating the transformation of Australia’s
energy system to one that is smarter and cleaner.
The CEC welcomes the opportunity to make a submission to Victoria’s Renewable Energy
Roadmap (the roadmap). As you would be aware, the renewable energy industry can attract
significantly more new Victorian investment, creating jobs and making a material
contribution to reducing Victoria’s carbon footprint in the process. The role of renewable
energy in helping to reduce electricity prices and give consumers meaningful ways to protect
themselves from rising power prices is becoming more broadly appreciated among the
general public. It is easy to understand why more than 80 per cent of Australians want to
see more renewable energy.
The Andrews Government has a great opportunity to position Victoria as a leader in a sector
that is innovative and can support real employment in rural and regional areas. A
dedicated plan for renewable energy is an effective way to demonstrate a strong
commitment to the industry and will boost investor confidence about the longer term intent
of the Andrews Government.
This submission generally follows the format of the roadmap’s chapters, from section 3 –
Transforming Victoria’s generation stock towards renewable energy through to section 6 –
Government’s role in facilitating the uptake of renewable energy. It concludes with a list of
recommendations that are explained in detail in the submission.
Transforming Victoria’s generation stock towards
renewable energy
Supporting renewables
To ensure Victoria can secure the maximum benefit from renewable energy investment, the
Victorian Government should introduce support mechanisms that can attract projects under
the existing federal Renewable Energy Target (RET), as well as driving the construction of
additional projects.
Projects built under the RET will be those that deliver the most competitive Large Scale
Generation Certificates (LGCs) to the liable parties. Competitiveness is influenced by a
combination of factors including resource quality, electricity market conditions and the
planning regime. The Victorian Government can attract more projects to Victoria by creating
additional demand for renewable energy, and by ensuring an efficient and fair planning
system that doesn’t unfairly delay or obstruct projects.
An existing and proven scheme for getting projects built is the reverse auction program that
has been introduced in the ACT. Currently in its third round, the scheme has established the
ACT as a leader in large scale renewable energy investment. If the Victorian Government
wishes to replicate the ACT approach as well as concentrating on local jobs and investment,
the scheme could be tweaked to require that the projects bidding in to the auction are
located in Victoria.
The Victorian Government could also ensure that renewable energy is purchased on behalf
of the Victorian Government in order to offset some or all of the Government’s energy use.
One efficient way to undertake such a purchase would be through a reverse auction which
has been demonstrated effectively by the ACT Government.
The Victorian Government could also consider including competitive and transparent
renewable energy obligations in tenders for major contracts like tram and train operators.
The major advantage of initiatives to support renewables in addition to the RET is that the
Victorian Government can include other policy outcomes as a requirement in tenders, rather
than simply choosing the cheapest electricity. For example, the selection process can favour
bids that include the greatest number of local jobs, or the greatest amount of local
investment, or the most effective community benefit sharing scheme. The Victorian
Government can use the transition of the electricity system as an opportunity to achieve
additional benefits for the state.
Recommendation 1: The Victorian Government should introduce support
mechanisms that can attract projects under the existing federal Renewable
Energy Target (RET), as well as driving the construction of additional projects.
Limit greenhouse gas emissions from fossil fuel generators
Australia’s stationary electricity sector contributes approximately a third of our country’s
total annual greenhouse gas emissions. Based on current scientific consensus the electricity
sector will need to be at or close to zero emissions by 2050, and several EU countries have
made statements supportive of that principle. It is clear that decarbonisation of the
electricity sector is imperative to meeting medium and long-term emissions targets, and long
term and clear energy and carbon policies are critical to achieving this.
Australia’s most emissions-intensive power stations will need to close in order to transition
the generation fleet in a timely manner. An orderly transition will require a clear framework
that provides strong investment signals for zero and low emissions technologies. A
disorderly or unmanaged transition without a clear framework or investment signals would
be likely to result in higher economic and environmental costs. This is particularly true for
Victoria which currently has the highest emissions intensity of generation of any Australian
State or Territory.
Transitioning the electricity sector is likely to have regional and local impacts. The Victorian
Government can play a role in assisting the transition of affected communities as emissions
intensive generation is closed as well as overseeing necessary remediation of these assets.
New renewable energy combined with softening demand has created a generation surplus in
the Australian energy market. A number of potential policy responses are available to
address the surplus, each with their strengths and weakness with regard to their political
palatability, policy simplicity, effectiveness and ultimately the extent to which they will
deliver an agreed outcome. These incorporate both market and direct regulatory
approaches, providing either incentives to reduce pollution or a user-pays approach for
polluters.
Given current political dynamics there appear to be a number of options for achieving this:

The safeguard mechanisms have the potential to fulfil this role however, they must
clearly drive abatement and cannot be seen to entrench business as usual behaviour.
The energy sector is a clear candidate for decreasing emissions baselines over time
in line with national emissions targets.

A regulatory approach that would see either an emissions threshold (for total
emissions or emissions intensity) established for generation plant or a limit on
operational life (or some combination). A threshold could be gradually reduced over
time and require generation to reduce emissions output below that threshold or to
close by a certain date.

A price on carbon that covers the electricity sector. The form of this policy, how it
interacts with other energy policies (such as the RET) and other sectors of the
economy require considerable analysis.

An alternative regulatory approach available to the Victorian Government is to
increase royalties on coal mining.
We would encourage the Victorian Government to consider what regulatory role they could
play to facilitate this and how any revenues derived from this mechanism may contribute to
furthering the Government’s renewable energy ambitions.
A variety of international examples exist of how to approach this issue. In the United States,
the Congress first attempted to introduce an emissions trading scheme, and when that failed
President Obama announced an initiative to directly regulate greenhouse gas emissions from
coal-fired power plants via the Environmental Protection Agency1. China is experimenting
with different mechanisms simultaneously, including pilot emissions trading schemes and
forced closures of coal-fired plants. Europe has focused on carbon pricing approaches
through its emissions trading scheme. Europe has also used direct regulation to remove the
oldest and most polluting generation plant through the Large Combustion Plant Directive.
This sets limits on the emission levels of various pollutants (but not carbon) from power
stations.
Currently the RET is the strongest driver of investment in renewable energy. The RET
complemented by the Australian Renewable Energy Agency (ARENA) and the Clean Energy
Finance Corporation (CEFC) will continue to be critical in driving new investment in
renewable energy. However these policies and the Emission Reduction Fund (ERF) have
minimal direct effect on the existing carbon intensive fossil fuel based electricity generation.
At some point an explicit or implicit carbon price is likely to be required. This may take the
form of regulation or market-based mechanisms but fundamentally it will need to make
emissions intensive activities less attractive and reward clean methods of electricity
generation.
Recommendation 2: Consider what regulatory role the Victorian
Government can play to facilitate major emissions reduction in the energy
sector and how any revenues derived from this may contribute to
furthering the Government’s renewable energy ambitions.
Achieving the 2020 target
The Victorian Government announced a target of at least 20 percent renewable energy by
2020. It is important that the target is expressed in terms of energy generated (watt-hours)
and also that this concept is explained to the public. Setting a target based on an inevitably
shifting goal (Victoria’s total energy use in 2020 for example) will not be a solid basis for
investor confidence.
Victoria should also link its renewable energy target to a wider goal to ensure the
community understands the rationale behind the transition. If the Victorian Government
aims to limit emissions then the target should be explained in terms of modernising
Victoria’s generation fleet, reduction of emissions and what the growth of renewable energy
will achieve.
1
Carbon Pollution Standards, United States Environmental Protection Agency, www2.epa.gov/carbonpollution-standards.
The Government has suggested that it might undertake a 100 MW purchase of renewable
energy. CEC calculations suggest that in order to achieve the 20 per cent target, Victoria will
need to install approximately 1,200 MW of renewable energy. Half of this will likely be
delivered by the RET under business as usual conditions, and the other half will likely
require additional state support.
We suggest that the Government can reach about 600 MW of additional renewable energy
using a mixture of approaches including a staged program of reverse auctions, starting with
100 MW but then increasing in the next five years will get there. These calculations will of
course change significantly if one or more of Victoria’s most emitting generators are retired.
Recommendation 3: Increase Government ambition beyond a 100 MW
renewable energy purchase, in order to achieve meaningful renewable
energy uptake.
Recommendation 4: Set targets in terms of electricity generation, rather
than percentage of demand.
Streamlining the planning process for the large-scale
renewable energy projects
With the political debate over the RET now settled, the location of projects will in some part
be determined by state planning policies. The Australian renewable energy industry has a lot
of work to do in the next five years to reach the renewable energy target. This construction
phase will need to be accompanied by improved engagement and consultation by the
industry, in order to avoid undue stress or uncertainty among communities.
A good state planning policy;

has a clear and time-bound approval pathway that can be understood by both
project proponents and the community

is evidence-based and does not treat renewable energy projects substantially
differently from any other infrastructure project

recognises the benefits renewable energy projects bring to the landholders involved
as well as the broader local community

takes into account wider state objectives and strikes a balance between those
objectives and the costs and benefits to local communities.
Update wind farm noise compliance and monitoring
One particular aspect of wind farm operation that in some cases can cause concern to
members of the community is noise. Wind farms in Australia currently face among the
toughest guidelines in the world in relation to their siting, operation and permissible noise
levels. Despite this, a perceived lack of transparency in the monitoring and compliance
process has resulted in an erosion of community confidence in the industry and in the
regulatory process.
This concern has been heard by the Minister for the Environment. In June 2015 the
Renewable Energy Target legislation passed the Parliament revising the target to 33,000
GWh by 2020. As a part of the package, Minister Hunt made a deal with the crossbench to
progress reforms to improve the science relating to the sound of wind farms and the
monitoring and transparency of information and help for communities.
Following on from the resolution of the RET; the Senate Select Committee on Wind
Turbines released their final report in August 2015. It contained 15 recommendations which
the Department of the Environment are expected to consider, as outlined in Minister Hunt’s
letter (attached to this submission as Attachment 1).
Some recommendations in the final report concern noise regulation, and suggest that the
process be run by state Environment Protection Authorities (EPAs). The report also suggests
that wind farm owners to pay a licencing fee to the EPA. This system is currently in place in
New South Wales.
We know that such a system is attractive to Victorian Councils. In their presentation to the
Select Committee, the Municipal Association of Victoria (MAV) suggested that in the last few
years, community confidence in the assessment of noise compliance is a principle concern
for councils and their communities.
MAV said that the task of reassuring communities is beyond the expertise of local
government, which requires councils to engage acoustic engineers to peer review noise
reports at a financial cost ranging from $8,000 to $10,000. The small size of the acoustic
engineering fraternity then erodes the community’s confidence in the independence of the
review.
The establishment of an environment protection licensing regime similar to other electricity
generating facilities would go some way to addressing questions of independence, as well as
assisting local councils with a task they are not equipped to undertake. The current interim
arrangement that allows councils to access accredited noise auditors for a fee still leaves the
burden of cost on the councils.
A reasonable annual licensing fee could be paid to resource the EPA to undertake the
compliance testing of wind farm noise as well as any ongoing post construction monitoring
that the EPA deems to be necessary. This will achieve a higher standard of perceived
transparency and should also serve to reassure the community in this regard. The EPA is a
uniquely trusted expert agency that is in the best position to explain complex issues in terms
that con be understood by the wider community.
Recommendation 5: Give responsibility for wind farm noise compliance to
the EPA.
Change the planning process for modifications to existing
projects
One of the major challenges facing the Victorian wind energy sector is updating the design
of projects with existing approvals. The lack of policy certainty at the federal level over
several years has left many approved projects waiting to sign deals and commence
construction. In the years since their approvals, turbine technology has moved forward at an
impressive speed, mostly resulting in larger more powerful turbines with longer blades and
more powerful generators.
In many cases an updated wind farm design can generate as much or more power output
using fewer, larger wind turbines creating a more efficient wind farm. Clearly, building these
more efficient wind farms is beneficial for Victorian communities not only because fewer
turbines mean less amenity impact, but also because updated technology brings down the
cost of energy to consumers.
It is in the interest of the Victorian Government to work with the community, local councils,
and the wind energy sector to find a way to simplify the process of approving modifications
to existing permits. However, simplifying the process must still ensure that communities and
local councils are empowered and engaged with.
At this point, a project seeking to reduce the number of turbines but increase the turbine
blade tip height must go through a panel hearing process. This could delay approval for up
to two years because the process to be navigated includes;

the developer redesigns the layout

all technical documents and management plans are updated

modification application lodged

public notice period triggered

public submissions and panel hearing

technical evidence heard

panel reports back

report submitted to Minister and determination eventually made.
There may be a good case for cutting out the public notice period in the situation that a
developer can demonstrate that amenity impacts are reduced. This is straight forward for
impacts such as noise and traffic. However, the difficult issue is visual impact. Given that the
turbines are likely to be marginally taller, there may be modifications that increase visual
impacts and therefore a public notice period might be reasonable.
A good solution would be the introduction of a clear guideline or test describing what
constitutes an increased visual impact. Where the wind industry is able to negotiate a clear
guideline then they will likely undertake to ensure that project modifications satisfy the
requirements for visual impact, much like they will ensure modifications do not increase
noise and other impacts.
Another suggestion would be a standing committee of wind farm experts who can assess
the modification applications rather than a public notification period. This approach will
ensure that councils can assure the community that the modification has been scrutinised by
experts and has adhered to all the appropriate regulations.
Recommendation 6: Simplify the process for modification of existing
approvals for wind farms, where developers can pass clear tests to
demonstrate no increased impact.
Addressing barriers to distributed generation and
storage
Improve access to information for businesses that want to
install solar PV
Solar PV is a practical way for small and medium-sized enterprises to reduce their electricity
costs. However the process of installing commercial-scale solar PV systems can be complex
and may act as a barrier to investment by small businesses. The NSW Government has
recognised this and has assisted NSW businesses by supporting the publication of the online Guide to installing solar PV for businesses in New South Wales2. CEC would be pleased
to work with the Andrews Government to develop a similar publication tailored for Victorian
households or businesses.
Recommendation 7: Consider funding development of Victoria-specific
resources to assist Victorian households or businesses that want to invest
in solar and other form of energy productivity improvements.
Understand and be prepared for the mass deployment of energy
storage
The cost and scale of energy storage technology is improving rapidly, to the extent that
storage technology is likely to become widespread in Australian homes over the coming
decade. Thousands of these units are already being installed into homes across Australia.
The rapid development and deployment of storage technologies will have a massive impact
on Australia’s energy sector and it is critical that state governments understand and plan for
the range of challenges the roll out of storage will bring. This includes working with the
clean energy sector to:

ensure the appropriate technical standards for the installation and connection of
systems;

establish systems for maintenance and disposal of the storage units;

introduce measures for consumer protection; and

manage the flow on effect to the network and generation sector.
The CEC is undertaking a comprehensive program of work on technical and regulatory
issues in relation to battery storage. We encourage the Victorian Government to work with
the CEC to develop a complete understanding of the issues and solutions to unlock this
massive opportunity to enable more renewable energy.
Recommendation 8: Develop guidelines for the safe disposal of batteries
in Victoria.
Recommendation 9: Consider introducing regulations to require that
battery storage devices must be installed by suitably trained and
accredited installers.
2
Available at http://www.solaraccreditation.com.au/consumers.html
Support the development of product standards for battery
storage
Currently there are no product standards or regulatory framework that adequately governs
batteries considered suitable for use in Victoria. CEC is identifying applicable standards for
batteries and their potential suitability for application in Australia. This will form the basis
for an approved product list. We would welcome assistance from the Victorian Government
in this work and would be pleased to discuss partnership opportunities.
Recommendation 10: Support efforts by CEC and others to develop
approved product lists and product standards for battery storage devices.
Establishing best practice grid-connection processes for
distributed generation
The grid connection process has a long and problematic history of issues, complaints and
apparent failure to deliver fair and reasonable outcomes. For example, a survey of gridconnection experiences run by the CEC in 2014 found that 48 % of respondents relating to
mid-scale generation3 stated that they were unable to manage their risks and costs
effectively during the connection process. 77 % stated that they did not believe the
connection process meets their requirements in a fair and certain manner and as quickly as
reasonably possible. The full survey report is available on the CEC’s website4, and Victoria
specific results are also provided as an attachment to this submission (Attachment 2).
Another recent example is the ClimateWorks (et al) investigation into the compliance of
Distribution Network Service Providers (DNSPs) with Chapter 5 of the National Electricity
Rules (NER)5. Following rule changes relating to the connection of embedded generation this
assessment found low compliance with the rules some six weeks after the rule
commencement date. A repeat of the investigation found increased compliance four months
following the publication of this outcome. The low initial compliance levels indicate that
there is little oversight from the Australian Energy Regulator regarding the rules for the
connection of generation. Publication of independent benchmarking of compliance seems to
have driven outcomes more successfully.
Best-practice in grid connection processes
The issues that require resolving to facilitate the efficient connection of embedded
generation centre on the process and its timeframes, costs and information availability. In
the CEC’s experience best practice connection process would address all of these issues
while focussing on increasing certainty for both parties.
Australia’s approach to grid connection is stuck in the 20th century. The last section of this
submission sets out the reasons of this and describes a range of options available to the
Victorian Government to make Victoria a world-leading market for solar PV.
Actions that the Victorian Government can take to achieve this are discussed in the
following sections and include:
3
This submission defines commercial-scale embedded generation as being rated above 30kW (the current AS
4777 scope threshold) and below 5MW (the AEMO registration threshold). Given current technology trends
this is expected to largely be filled by solar PV.
4
http://www.cleanenergycouncil.org.au/fpdi/reports/grid-connection-experiences-survey-results.html
5
ClimateWorks et. al, 2014, Implementing the Connecting Embedded Generation Rule Change,
http://climateworks.com.au/
1. Establishing grid connection processes that embrace technical capabilities to realise
the potential of solar PV and storage
2. Implementing standards for the grid connection of commercial-scale embedded
generation
3. Establish regular knowledge sharing forums to promote open collaboration and
learning across industry
4. Frequent reporting on grid connection process performance and outcomes
5. Establishing fair, reasonable and independently approved commercial terms for
connection
6. Mapping clean energy connection opportunities.
Establish grid connection processes that embrace the technical capability of solar PV and
storage
Small scale generation and storage technologies are advancing quickly. ‘Smart inverters’ are
generally now readily available and will be an important contributor to increasing the
penetration of solar PV in Australia.
The forthcoming revision of the Australian Standard (AS 4777) for grid-connected inverters
contains a range of potential operating modes that can control the way these technologies
interact with the network. These options aim to maximise the volume of generation within
the technical constraints of networks (especially voltage management which is the most
prominent technical constraint).
It is essential that Victoria’s DNSPs understand and accept these operating modes in order
to maximise the utilisation of existing electricity network assets for the connection of
renewables. Connection processes should reflect the opportunities for renewable energy
generators to make a choice to implement these modes and avoid network upgrades or
augmentation.
Such a process should set out generator size thresholds and the alternative operating modes
that can be implemented at each threshold, should an issue arise that may limit the
connection otherwise. Table 1 shows a hypothetical example of potential thresholds and
solutions that DNSPs could accept.
Table 1: Examples of thresholds and possible solutions that DNSPs could accept in defining a
flexible grid connection process that embraces technical capabilities of generation.
Solar PV generator
capacity
0 – 5 kVA
5 - 10 kVA
10 - 30 kVA
30 – 100 kVA
Baseline operating
mode
Fixed unity power
factor
Fixed unity power
factor
Fixed power factor
ranging from unity to
absorbing at 0.95 when
generating at
maximum
Fixed power factor
Accepted alternative operating modes
Absorbing reactive power, 0.95 power factor or
below
Absorbing reactive
Curtail power if voltage
power,0.95 power
too high (P-V
factor or below
response)
Curtail power if voltage Increase reactive
too high (P-V
power import if voltage
response)
too high (Q-V
response)
Curtail power if voltage
Increase reactive
>100 kVA
ranging from unity to
absorbing at 0.95 when
generating at
maximum
Fixed power factor
ranging from unity to
absorbing at 0.95 when
generating at
maximum
too high (P-V
response)
power import if voltage
too high (Q-V
response)
P-V response or Q-V
response
Load control or
limitations on export
from site
A good option would be for the Victorian Government to direct the Essential Services
Commission (ESC) to require that Victoria’s DNSPs define a connection process that
embraces optionality for alternative technical solutions for commercial-scale generators to
consider. Connection options need to be clearly defined and the ESC should consult widely
with industry on the proposed thresholds and acceptable solutions. All Victorian DNSPs
should be required to adopt these once implemented.
Recommendation 11: The Victorian Government should consider directing
the Essential Services Commission to consult with industry to define a
flexible and adaptive grid connection process that embraces the technical
capability of small scale solar PV and storage technologies, to be adopted
by DNSPs.
Recommendation 12: Establish grid connection processes that embrace
technical capabilities under the forthcoming revision of AS 4777.
Recommendation 13: Direct the Essential Services Commission to require
that Victoria’s DNSPs define a connection process that embraces
optionality for alternative technical solutions for commercial-scale
generators to consider, including technical capabilities under the
forthcoming revision of AS 4777.
Reasonable and consistent grid connection standards for the connection of commercial-scale
embedded generators
As the Victorian Government is aware, significant information deficiencies exist for the
connection of commercial-scale embedded generators to distribution networks. The lack of
consistent grid connection standards for the connection of embedded generation to
distribution networks is a major failing of Australia’s electricity markets.
There is now a growing body of evidence supporting the need for these standards to ensure
the efficient facilitation of embedded clean energy projects:
6

Work by the Department of Resources, Energy and Tourism – now the Department
of Industry & Science – considered the feasibility (desirability, achievability and net
benefit) of introducing a standard for this purpose based on the need and willingness
of the industry6. It found strong stakeholder interest in developing this standard.

The CEC’s Future Proofing in Australia’s Electricity Distribution Industry (FPDI)
Project “Priorities for IES Connection Standards” report considered the outcomes of
the various regional and DNSP-specific technical requirements with a focus on LV-
http://www.scer.gov.au/files/2013/07/AECOM-Final-Report-Embedded-Generation-Updated-Aug-2013.pdf
connected systems (generally rated between 30-500 kW)7. This assessment looked
at the technology characteristics of inverter-based energy systems and the
implications of the various technical requirements, setting out priorities to take
forward.

Another FPDI report, “Technology Testing Survey” also identified standards related
to the testing and certification of IES systems, including BDEW, VDE and IEEE, IEC,
EN and Australian Standards8. It identified the potential benefits of a testing and
compliance framework for inverter energy systems and the willingness within the
industry to progress this, setting out the key characteristics of such an arrangement.
Recommendations included a detailed review of current technical requirements and
the establishment of nationally consistent technical requirements.

The CEC’s Grid Connection Experiences Survey Report (2013-14) also identified the
lack of clear and uniform technical standards for connection as a major concern for
the connection of small-medium embedded generators9.
While the current draft revision of the Australian Standard (AS 4777, solar PV inverter and
system installation requirements) sets out some basic criteria for connection requirements
for commercial scale solar PV, it does not address grid connection requirements. These are
generally imposed by DNSPs and can range significantly between different networks.
Unlike for larger generators, the NER is silent on connection standards for generation rated
below 5 MW10. Electing to defer to the commercial negotiations for technical matters, clause
5A.D.1 prescribes information to be published including minimum access standards and
some technical requirements for connection. As found by Clean Technology Partners (Figure
2) these requirements can vary significantly from DNSP to DNSP and appear to be based
largely on perceived levels of risk11.
Figure 1: Grid protection requirements applied by DNSPs across Australia.
7
http://www.cleanenergycouncil.org.au/policy-advocacy/arena/FPDI-project/inverter-energy-systemconnection-standards.html
8
http://www.cleanenergycouncil.org.au/policy-advocacy/arena/FPDI-project/technology-testing-survey.html
9
http://www.cleanenergycouncil.org.au/policy-advocacy/arena/FPDI-project/grid-connection-experiencessurvey-results.html
10
AEMO’s standing exemption for registration as a generator.
11
http://www.cleanenergycouncil.org.au/policy-advocacy/arena/FPDI-project/inverter-energy-systemconnection-standards.html
Transparent and consistent technical requirements for the connection of embedded
generation are necessary for an efficient connection process for commercial-scale solar PV.
The benefits of certainty of connection requirements include enabling generator
suppliers/retailers to provide firm and efficiently priced and financed system installations to
their clients, and increased efficiencies in ancillary product offerings by reducing bespoke
equipment needs. Ultimately this will lead to increased confidence in the delivery of
embedded renewable energy generators and lower delivery costs.
The CEC has been working with industry for some time to progress this matter and recently
commissioned Energeia to undertake an industry-guided scoping study to define the format,
objective and implementation framework for this standard, including an outline of the
standard’s contents and scope of work to complete and implement it1212. The planned
completion date for this work is March 2016.
The Victorian Government can take a leading role in supporting the development of these
standards and should:
1. Direct the ESC to undertake a review of the fairness and reasonableness of
connection requirements in Victoria by invoking the ESC’s capability under cl. 11.4 of
the Victorian Electricity Distribution Licences to bring into question the fairness and
reasonableness of connection requirements. The ESC should require that each
Victorian DNSP provide, for publication, a detailed demonstration of the need for the
technical requirements they apply to connecting commercial-scale generators,
including the perceived level of risk that these requirements are based on. A public
consultation should seek feedback from stakeholders on the impacts of these
technical requirements and, if necessary the ESC should be able to make a
determination on resolutions to any overly excessive requirements.
2. Work with industry to undertake independent research focusing on a detailed study
to determine reasonable protection requirements for the connection of commercialscale embedded generation to distribution networks. This research would assess the
material risks and reasonable responses to these risks. It would ideally be
undertaken at a Victorian facility with leadership from industry, including DNSPs, and
be funded by an independent source. The CEC will provide a proposal (Attachment
3) to the Victorian Government to lead this work in partnership with a leading
research agency and using a Victorian-based facility to undertake this research. The
results of this work will inform future decisions by the ESC and the development of
consistent grid connection standards.
3. Consider direct support for the development of, and design of an implementation
framework for the standards or guidelines once the CEC’s scoping study is
completed.
12
http://www.cleanenergycouncil.org.au/fpdi/reports/grid-connection-standards-scoping-study.html
Recommendation 14: The Victorian Government should take a leading role
in assisting the industry to develop and implement consistent standards
for the grid connection of embedded generation to distributed networks
by:

directing the Essential Services Commission to undertake a review
of the fairness and reasonableness of connection requirements in
Victoria

working with industry to undertake independent research focusing
on a detailed study to determine reasonable protection
requirements for the connection of commercial-scale embedded
generation to distribution networks

directly supporting the development and design of an
implementation framework for the standards or guidelines once the
CEC has completed a scoping study.
Establish and run regular knowledge sharing forums
The Victorian Government should establish regular forums to bring industry stakeholders
into an open constructive environment to discuss issues and concerns and to identify priority
areas for improvement on grid integration.
The high number of DNSPs in Victoria means high costs from failing to reveal efficiency
gains by sharing information and lessons learned across these businesses and the broader
industry. The successful evolution to a market that facilitates clean energy will rely on a high
level of participation from industry. The Victorian Government has a real opportunity to
show leadership by establishing and running these sessions on an ongoing basis.
These sessions should occur on a quarterly or half yearly basis and draw participation from
across the industry including embedded generator proponents, DNSPs, Government, ESC
and other relevant stakeholders. Their focus should be on presenting lessons learned, risks
and opportunities along with identifying any current or emergent technical issues and
ongoing discussions on reforms and improvements.
Recommendation 15: The Victorian Government should establish a regular
and ongoing knowledge sharing forum to encourage the industry to share
ideas and understand risks and opportunities.
Frequent reporting on grid connection process performance and outcomes
The Victorian Government should require the state’s DNSPs to publically report on the
performance of their connection processes and its outcomes on a regular basis. Publication
of the performance of grid-connection processes by DNSPs could be an important step to
improve the process. The ESC should require that DNSPs post on their websites their
performance in regards to grid-connection processes to be updated regularly. This should
include information such as timeframes to provide offers to connect, improvements
undertaken to connection process, connected generation capacity in the period and to date,
constraints and/or work backlogs and the capability to deliver on current workloads.
The Victorian Government and industry will subsequently gather information on connection
process performance and outcomes and be able to clearly identify areas where intervention
may be needed to improve performance. It will also enable the Victorian Government to
take a leading role on understanding opportunities for the facilitation of renewables on an
ongoing basis.
Recommendation 16: The Victorian Government should require the
state’s DNSPs to publicly report on the performance of their connection
processes and its outcomes on a regular basis.
Establish fair, reasonable and independently approved commercial terms for connection
Embedded generation projects require financing and innovative models are becoming
increasingly common. However the commercial terms signed with the DNSP for connections
to their networks are increasingly weighted towards their interests. As discussed later in this
submission the negotiate/arbitrate model that guides connections can only provide a
reasonable outcome given countervailing market power, which clearly does not exist for
commercial-scale generators.
In most cases the commercial terms for connection apply unlimited liability on the
connecting generator. As reported by ClimateWorks this is common practice by Australia’s
distribution networks. In one instance their investigation found that while one DNSP
accepted a liability limit of $50 million, they added any insurance revenues recovered by the
generator in respect of the relevant incident13.
Terms like these have the effect of markedly increasing risk and the costs of financing for
generation projects. The CEC also understands that the negative experience of negotiating
their way through the connection process under clearly one-sided conditions tends to drive
generator proponents to consider there is little hope of successfully negotiating connection
agreement terms once offered. To try to do so would only lead to unfruitful delays and
costs. Accepting unreasonable terms feels necessary to move a project ahead.
The connection process requires that a DNSP provides an Offer to Connect, containing the
commercial terms for a connection that can be signed to form a Connection Agreement.
Both Chapter 5A of the National Electricity Rules and ESC Guideline 15 require an Australian
Energy Regulator or ESC approved (respectively) agreement for small embedded generators
compliant with AS 4777. Larger embedded generators are expected to negotiate the terms
of this agreement. Clause 11.4 of the Victorian Electricity Distribution Licences sets out that
the ESC can determine the fairness and reasonableness of the terms of an Offer to Connect.
In order to ensure that the costs of financing a Victorian embedded generator project
remain efficient the Victorian Government should invoke the ESC’s powers to make a
determination on any Offer to Connect term. The ESC should act independently to develop
and publicly consult on state- wide template offer terms that reflect best practice and strike
the right balance between the negotiating power and risks carried by the generator and the
DNSP (following legal advice, some examples of improvements to these terms have been
outlined by ClimateWorks et al14).
13
ClimateWorks et. al, 2014, Implementing the Connecting Embedded Generation Rule Change, p. 26,
http://climateworks.com.au/
14
ibid, p. 26-27.
Recommendation 17: The Victorian Government should direct the
Essential Services Commission to develop and publicly consult on a statewide template Connection Agreement terms that must be used as a basis
for negotiations between DNSPs and embedded generators.
Encouraging household and community
renewable generation
Address the barriers preventing low income households from
investing in solar
In the past there have been many barriers preventing low income households from costeffective adoption of solar systems. Many of these factors no longer apply. The main
barriers low income households now face are primarily institutional in nature, and the
Victorian Government can play a crucial role in overcoming those barriers.
The first and most fundamental barrier was operating cost. When the levelised cost of
electricity (LCOE) of a solar PV system is more than the retail price of electricity, solar
systems are not an effective investment for a low income household. This is no longer the
case. In recent years the price of solar PV systems has fallen dramatically. The Small-scale
Renewable Energy Scheme (SRES) further reduces system costs. The LCOE of a solar PV
system is now less than the volumetric component of a retail electricity bill. Accordingly,
operating cost should no longer be a barrier to solar uptake by low income households.
A second barrier relating to operating cost is uncertainty over future tariff structures.
Changes to distribution network tariff structures are currently under consideration. A move
to a tariff structure dominated by fixed or demand-based charges would reduce the costeffectiveness of investments in solar. Victorian distribution network tariffs for the 2017-2022
period are currently being set under the regulatory framework of the Australian Energy
Regulator (AER). Once the future tariff structures have been set this source of investment
uncertainty will be removed. It remains to be seen whether solar will have the capacity to
reduce electricity bills under the new Tariff Structure Statement. CEC will provide further
feedback on this matter once we have had an opportunity to model the impact of the
proposed Tariff Structure Statements.
Capital cost has also presented a barrier to solar investment by low income households.
Even with the support of the SRES scheme, the up-front capital cost of a solar system often
prevents low income households from investing despite the savings that would result over
the life of the system. Innovative financing mechanisms, such as solar power purchase
agreements (PPAs), have enabled customers to access the benefits of solar systems with
zero up-front cost. Unfortunately, a complex web of regulation has effectively prevented
solar PPAs from being offered in Victoria. We note that there are two concurrent reviews of
the Victorian regulatory framework for solar PPAs. We are hopeful that the reviews will
make it possible for companies to offer solar PPAs in Victoria with the same ease that they
can be offered in other jurisdictions in Australia. Innovative solar financing will form a key
part of any strategy to enable access to solar to low income households. Victoria’s uniquely
complex regulatory framework is the main barrier to solar PPAs being available in this state.
We urge the Victorian Government to ensure that the regulatory framework for solar PPAs in
Victoria is at least as simple as that of the AER. We note that the AER proposes to introduce
a ‘class exemption’ framework for solar PPAs offered to residential customers, provided the
PPAs meet certain minimum requirements for consumer protection.
The main barrier to solar investment by low income households is the tenant-landlord split
incentive. It is not in the financial interest of a landlord to invest in solar when the savings
will be enjoyed by the tenant. It is not in the financial interest of the tenant to invest in solar
when they do not have sufficient security of tenure to ensure that the investment will pay
for itself.
For those families living in public housing, with the state government as the landlord, there
is a solution. South Australia pioneered the development of a three-way contracting model
in which the government is a party of the contract, but all expenditure on the solar device is
paid by the tenant. We urge the Victorian Government to consider adopting the South
Australian model for public housing. Electricity retailers who supply public housing should be
encouraged to offer solar PPAs where they can result in savings for tenants.
Low income families living in private housing need a different, more innovative solution.
Solar PPAs could be part of the solution. However they are not the complete solution and a
range of barriers and issues remain. Tenants do not enjoy sufficient security of tenure to
enable them to enter a long- term contract with a PPA provider. Landlords could offer their
tenants a solar PPA (most likely with the help of a solar PPA provider) and they have a class
exemption that allows them to do so. However they might be unwilling to do so because a
function like electricity metering and billing is not ’core business’ for a landlord. They might
also be unwilling to do so if they are proposing to sell, demolish or redevelop their property
in the short to medium term. There could be a role for local government in providing a
framework for enabling solar PPAs and outright purchase of solar systems for low income
private rental properties, possibly in conjunction with Environmental Upgrade Agreements.
Recommendation 18: Ensure that the regulatory framework for solar PPAs
in Victoria is at least as simple as that of the Australian Energy Regulator
(AER), noting that the AER proposes to introduce a ‘class exemption’
framework for solar PPAs offered to business and residential customers,
provided the PPAs meet certain minimum requirements for consumer
protection.
Recommendation 19: Utilise three-way contracts (as has been done in
South Australia) to enable installation of solar in public housing, with cost
savings for tenants and with little or no cost to government.
Recommendation 20: Actively encourage electricity retailers who supply
to public housing tenants to offer solar PPAs where they can result in
electricity bill savings for tenants.
Recommendation 21: Convene a working party of representatives of state
and local governments, solar PPA providers, landlords and real estate
agents and consumer organisations to develop a practical approach to
enabling access to solar PPAs by low income households in private rental
properties.
Supporting grid connection for community renewable energy
projects
Grid connection costs can be a significant portion of a project capital, and are borne in the
final stages of a project’s development and only when the project is committed. The
Government should support committed community renewable energy projects by providing
direct funding for grid connection costs.
By definition under the market rules the connection of generation is a negotiated service,
where only light touch regulation is applied (see later discussion on the “Negotiate-Arbitrate”
framework). Under this arrangement the Victorian Government could simply pay for all, or a
portion of, the connection costs in partnership with the generator proponents.
Recommendation 22: Consider supporting community renewable energy
projects by co-financing part or all of the grid connection cost.
Support grid disconnection for community renewable energy
projects
There are a number of examples in Victoria where it would make more sense (from the
perspective of safety, reliability and cost) to provide electricity supply through an
independent grid powered by distributed generation and storage, rather than a
transmission line to the main grid. Bushfire- affected communities are a particular case in
point. Under the National Electricity Rules distribution businesses are obliged to supply. It is
our understanding that a proposal to supply a community through an independent grid can
only be implemented if there is a consensus within the community. Businesses and
governments are often not well placed to develop a consensus within a community.
Community organisations might be better placed for this role because they are less likely to
be perceived as having a vested interest.
Recommendation 23: Consider supporting community education initiatives
the establishment of independent grids (particularly in bushfire-affected
communities) where there would be clear safety, reliability and financial
benefits.
Independent assessment
While the current rules expect negotiated services to produce efficient outcomes, a
safeguards arrangement involving an independent engineering perspective could be out in
place by the government, under the direction of the ESC. This would be much like an
‘owner’s engineer’ role that financiers and banks frequency use for assessment of
infrastructure investments.
The effort needed to assess the project could be tailored to its complexity, noting that low
numbers of these projects mean a case-by-case approach is likely to be acceptable. The
added benefit of this approach would also be to enable the government to build knowledge
of connection costs and an understanding of future efficiency gains for grid connections.
Facilitating the uptake of renewable energy
Need for proactive response from the Victorian Government
The current market frameworks are unable to truly facilitate the potential of distributed
renewable energy. There are three institutional barriers that prevent this:
1. Market objectives that focus on economic outcomes. In the absence of a reprioritised market objective that enforces environmental outcome the decisions made
within the market’s governance structure and regulated businesses will not truly seek
best practice actions to facilitate distributed generation.
2. The lack of incentive on DNSPs to facilitate best practice integration of generation.
The status of a generator connection as a commercially negotiated activity that the
National Electricity Rules obliges networks to undertake means that incentives for
DNSPs to truly facilitate the efficient integration of renewable energy simply do not
exist.
3. “Negotiate/arbitrate” regulation of generator connections is fundamentally flawed.
The light-touch regulation of connections under the National Electricity Rules or the
ESC Guidelines can only work if the parties either have perfect information or
countervailing market power. The monopoly nature of distribution networks and low
incentive means this framework is fundamentally incapable of facilitating the efficient
integration of renewable energy in the absence of intervention.
These characteristics have evolved from a paradigm where fewer, larger generators
dominated and (in some cases) smaller generators were actively discouraged. As a result,
investment opportunities that could be realised in a market that facilitates renewable energy
will remain elusive unless there is intervention by the Victorian Government.
Options available to the Victorian Government to design a market that facilitates clean
energy and show leadership in this domain include:
1. Guiding the ESC to undertake actions on the balance of its objectives to deliver
economic outcomes with enhanced prevalence of environmental objectives15 in
electricity, or alternatively the environmental quality of electricity supply as an
essential service. Other alternatives could be to pass legislation to effect this
outcome, or to change the ESC objectives to consider environmental and economic
outcomes coherently.
2. Establishing incentives arrangements for electricity networks to improve the
facilitation of distributed generation. This would require oversight from the ESC and
an appropriate benchmarking, reporting and reward/penalty scheme to be designed
under public consultation. The Victorian Government previously delivered the FFactor Scheme for fire prevention so has experience in developing such schemes.
Funding for such a scheme could be found by increasing brown coal royalties or a
carbon pricing mechanism.
The Victorian Government should investigate these options for significant reforms to show
leadership in the design of a market that facilitates clean energy in Victoria.
15
The ESC is already expected to balance price, quality and reliability objectives with economic outcomes with
relevant health, safety, environmental and social legislation applying to the regulated industry.
Roles and resources in the Government
The CEC encourages the Victorian Government to consider additional roles and resources to
facilitate the renewable energy industry. The Renewable Energy Advocate position in the
NSW Government has been extremely useful in that state for assisting the Government, the
industry and the community in working together and we would encourage the Victorian
Government to create a similar position.
The appointment of a case manager in the planning department would be useful in
managing timeframes in assessing applications and ensuring referral agencies also respond
in a timely fashion. Workers in the NSW Department of Industry are specifically assigned to
case manage this process and it has had a remarkable effect on the timelines in assessing
wind farm projects in particular. A CEC member reports that an identical modification
request was assessed in a few weeks and last year took 14 months. We recommend the
Victorian Government consider a similar approach.
Another NSW initiative that has worked well and could be incorporated in Victoria is the
employment of regional precinct coordinators. Strategic identification of Victorian regions
with strong renewable energy resources and connection opportunities could be targeted and
developed as renewable energy precincts. Regional staff would then work with local
communities on economic development initiatives such as skills training for renewable
energy construction.
Recommendation 24: Consider a new role to act as a central contact point
between industry, the community, and Government – similar to the NSW
Renewable Energy Advocate.
Recommendation 25: Ensure Departmental responses to planning
applications and modifications are accountable to reasonable timelines –
similar to the case manager approach adopted by the NSW Department of
Industry.
Mapping renewable energy resources
The Victorian Government should note the currently ongoing development of the Australian
Renewable Energy Mapping Infrastructure (AREMI)16. This mapping tool is being developed
by ARENA and the National ICT Australia Limited (NICTA). It aims to geographically
represent renewable energy resource information as well as infrastructure such as
transmission lines. Duplicating this work would be unnecessary, but promoting it to
communities and Government employees would be useful.
Recommendation 26: Promote existing resource maps to communities and
Government employees.
Mapping renewable energy grid-connection opportunities
Much effort has been directed into identifying opportunities for network support from
distributed generation by focussing on network planning and investment needs information.
Some examples include the ‘DANCE’ mapping project undertaken for Sustainability Victoria
16
AREMI, NICTA https://www.nicta.com.au/category/industry-engagement/environment/projects/aremi/
in 201117 (which is currently being revised on a market-wide basis18) or the Australian
Energy Market Commission’s (AEMC’s) recently completed Demand Management Incentive
Scheme rule change19.
The CEC’s view is that while important, these reforms face barriers to creating meaningful
opportunities for the uptake of renewable energy because:

Forecast long term flat demand growth limits the number of opportunities for
network support, and;

Misaligned timing, information and commercial drivers for potential third party
demand management services to DNSPs create a challenging environment for
project proponents to commit to these limited opportunities.
In practice opportunities for symbiotic investments between networks and generator
proponents are very rare because network investment profiles and renewable
energy development opportunities (especially commercial-scale PV) rarely align coherently.
For example, a commercial- scale solar PV project is based on the economics of on-site
demand, generation and energy export at a given site, having no regard for potential
network investment deferral opportunities.
While some opportunities for network support may be realised in the future, the facilitation
of clean energy (especially commercial-scale solar PV) requires a focus on the
opportunities at possible renewable energy generation locations, not areas of planned
network investment.
Currently the only way that a renewable energy proponent can identify the viability of a
proposed point to connect to the grid is to lodge a Connection Enquiry with the network. In
practice this means that the proponent may have commenced the project with an
unworkable design or project size to be advised by the DNSP after this effort that the
project would require significant network augmentation and needs to be modified.
Because there is no locational-specific information available from the start of the process,
these significant limitations are only revealed some time after entering into the connection
process.
A template for a renewable energy generation opportunities mapping tool
A facilitative approach to renewable energy would establish a mapping tool that enables a
user to easily identify the expected grid connection opportunity at the project’s location.
There are four main components needed to develop this tool:
1. Geographical Information System (GIS) data for distribution network assets. By
definition, DNSPs have this information and can make it available following some fine
tuning. Note that although terrorism risk has been used to reason protecting this
17
https://www.uts.edu.au/research-and-teaching/our-research/institute-sustainablefutures/news/decentralised-energy-victoria
18
http://www.uts.edu.au/research-and-teaching/our-research/institute-sustainable-futures/ourresearch/energy-and-climate-1
19
http://aemc.gov.au/Rule-Changes/Demand-Management-Embedded-Generation-Connection-I
data, Google Earth and existing precedents (such as the NICTA mapping project20)
have now superseded these claims.
2. Analysis to estimate the available capacity at any point along distribution networks.
This would require some effort to make a high level assessment of the available
capacity along the distribution network. Analysis of distribution feeders is well
understood by DNSPs and establishing the procedures and processes to undertake
this task is feasible (an overseas precedent is provided below).
3. A web-based interface enabling access to the GIS data to interrogate any particular
location and identify the available grid-connection opportunities adjacent to a
particular site.
4. An incentive framework would also be required to drive networks to maximise
available network capacity for generator connection. As previously discussed the
current economic regulation of DNSPs will not facilitate generator connections in
this way. The Victorian Government could design an incentive framework that sets
targets for new connections. This could be based on the number of generator
connections or the installed generation capacity on a DNSP’s network relative to the
number of customers, length of network or a similar characteristic.
Such a tool like has recently been implemented by California’s electricity networks. An
example can be found on the PG&E website21. After logging in the user can access the
information displayed in the figures below by looking at the desired location and clicking the
cursor on nearby network assets.
Figure 2: Example of the graphical interface provided by PG&E.
20
21
http://nationalmap.gov.au/
http://www.pge.com/en/b2b/energysupply/wholesaleelectricsuppliersolicitation/PVRFO/pvmap/index.page
Figure 3: Example of the information made available by clicking on the nearby distribution
network assets.
The ultimate benefit of this tool would be to quickly access clear information for potential
renewable energy projects to enable them to make a preliminary assessment and move
forward with a project they want to deliver whilst reducing their risk of technical constraints
forcing system re-design during the connection process. It would make significant long term
savings in terms of time and costs efficiencies for the grid-integration of renewables in
Victoria.
The CEC proposes a four-stage approach to developing this tool:
1. The first stage would include a brief public consultation seeking input on a
framework for the tool including the desired information to be provided, generation
technologies to be included in the analysis and the incentive framework to encourage
DNSPs to maximise the available capacity on their networks.
2. The second stage would involve Victoria’s DNSPs creating Generation Opportunities
Map Planning Reports that outline the methodology to be applied by each DNSP to
analyse the available capacity along each feeder and the presentation of information
in the Tool. This report would be open to publicly consultation with a final Planning
Report approved by the ESC.
3. The third stage would involve the development of the Tool in accordance with the
final ESC- approved Planning Report. This tool could be incorporated into the AREMI
tool discussed above.
4. The final stage is an ongoing update and compliance report to be submitted to the
ESC for approval and published annually.
Recommendation 27: The Victorian Government should ensure that a
Connection Opportunities Mapping Tool is developed and implemented for
Victoria that seeks to maximise opportunities for the connection of clean
energy generators, while also maximising early stage information for
renewable generator proponents to make appropriate choices that
manage and reduce risk.
Summary of Recommendations
Transforming Victoria’s generation stock towards renewable
energy
1. The Victorian Government should introduce support mechanisms that can attract
projects under the existing federal Renewable Energy Target (RET), as well as
driving the construction of additional projects.
2. Consider what regulatory role the Victorian Government can play to facilitate major
emissions reduction in the energy sector and how any revenues derived from this
may contribute to furthering the Government’s renewable energy ambitions.
3. Increase Government ambition beyond a 100 MW renewable energy purchase, in
order to achieve meaningful renewable energy uptake.
4. Set targets in terms of energy generation, rather than percentage of demand.
5. Give responsibility for wind farm noise compliance to the EPA.
6. Simplify the process for modification of existing approvals for wind farms, where
developers can pass clear tests to demonstrate no increased impact.
Addressing barriers to distributed generation and storage
7. Consider funding development of Victoria-specific resources to assist Victorian
households or businesses that want to invest in solar and other form of energy
productivity improvements.
8. Develop guidelines for the safe disposal of batteries in Victoria.
9. Consider introducing regulations to require that battery storage devices must be
installed by suitably trained and accredited installers.
10. Support efforts by CEC and others to develop approved product lists and product
standards for battery storage devices.
11. The Victorian Government should consider directing the Essential Services
Commission to consult with industry to define a flexible and adaptive grid connection
process that embraces the technical capability of small scale solar PV and storage
technologies, to be adopted by DNSPs.
12. Establish grid connection processes that embrace technical capabilities under the
forthcoming revision of AS 4777.
13. Direct the Essential Services Commission (ESC) to require that Victoria’s DNSPs
define a connection process that embraces optionality for alternative technical
solutions for commercial-scale generators to consider, including technical capabilities
under the forthcoming revision of AS 4777.
14. The Victorian Government should take a leading role in assisting the industry to
develop and implement consistent standards for the grid connection of embedded
generation to distributed networks. It should do this by
a. directing the Essential Services Commission to undertake a review of the
fairness and reasonableness of connection requirements in Victoria
b. working with industry to undertake independent research focusing on a
detailed study to determine reasonable protection requirements for the
connection of commercial-scale embedded generation to distribution
networks
c. directly supporting the development and design of an implementation
framework for the standards or guidelines once the CEC has completed a
scoping study.
15. The Victorian Government should establish a regular and ongoing knowledge sharing
forum to encourage the industry to share ideas and understand risks and
opportunities.
16. The Victorian Government should require the state’s DNSPs to publicly report on the
performance of their connection processes and its outcomes on a regular basis.
17. The Victorian Government should direct the Essential Services Commission to
develop and publicly consult on a state-wide template Connection Agreement terms
that must be used as a basis for negotiations between DNSPs and embedded
generators.
Encouraging household and community renewable generation
18. Ensure that the regulatory framework for solar PPAs in Victoria is at least as simple
as that of the Australian Energy Regulator (AER), noting that the AER proposes to
introduce a ‘class exemption’ framework for solar PPAs offered to business and
residential customers, provided the PPAs meet certain minimum requirements for
consumer protection.
19. Utilise three-way contracts (as has been done in South Australia) to enable
installation of solar in public housing, with cost savings for tenants and with little or
no cost to government.
20. Actively encourage electricity retailers who supply to public housing tenants to offer
solar PPAs where they can result in electricity bill savings for tenants.
21. Convene a working party of representatives of government, solar PPA providers,
landlords and real estate agents and consumer organisations to develop a practical
approach to enabling access to solar PPAs by low income households in private rental
properties.
22. Consider supporting community renewable energy projects by co-financing part or all
of the grid connection cost.
23. Consider supporting community education initiatives the establishment of
independent micro-grids (particularly in bushfire-affected communities) where there
would be clear safety, reliability and financial benefits.
Facilitating the uptake of renewable energy
24. Consider a new role to act as a central contact point between industry, the
community, and Government – similar to the NSW Renewable Energy Advocate.
25. Ensure Departmental responses to planning applications and modifications are
accountable to reasonable timelines – similar to the case manager approach adopted
by the NSW Department of Industry.
Promote existing resource maps to communities and
Government employees.
26. The Victorian Government should ensure that a Connection Opportunities Mapping
Tool is developed and implemented for Victoria that seeks to maximise opportunities
for the connection of clean energy generators, while also maximising early stage
information for renewable generator proponents to make appropriate choices that
manage and reduce risk.
If you have any further questions or wish to arrange a meeting to discuss this submission
please contact Alicia Webb via telephone on 03 9929 4100 or by email at
AWebb@cleanenergycouncil.org.au. For media inquiries, please contact Mark Bretherton on
0413 556 981.
Yours sincerely,
Alicia Webb Policy Manager
Clean Energy Council
Attachment 1: Letter from the Hon Greg Hunt MP
to Senators
To:
Senator Bob Day
Senator Jacquie Lambie
Senator David Leyonhjelm
Senator John Madigan
Parliament House
CANBERRA ACT 2600
Dear Senators
The reinstatement of native forest wood waste as an eligible source of renewable energy
under the Renewable Energy (Electricity) Amendment Bill 2015 is an important reform that
will support additional renewable energy generation and secure future employment
opportunities in regional Australia.
I can confirm that the use of native forests for the primary purpose of generating renewable
electricity has never been and never will be eligible to create certificates under the scheme.
Eligibility was, and will continue to be subject to several strict conditions, including that it
must be harvested primarily for a purpose other than energy production. There is no
evidence that its eligibility leads to unsustainable logging.
The Government understands the continuing concerns raised by sectors of the community
on the impact of wind farms on local communities. The Government supp01is the continued
deployment of solar and other emerging renewable technologies in Australia.
Subject to passage of the Renewable Energy (Electricity) Amendment Bill 2015 and
reinstatement of native forest wood waste as eligible source of renewable energy, I will
commit to the following measures at Attachments A and B to this letter.
Thank you for your ongoing support and engagement.
Yours sincerely
Hon Greg Hunt MP
Minister for the Environment
Encl.
ATTACHMENT A – ADDRESSING COMMUNITY CONCERNS ABOUT WIND FARMS
ATTACHMENT B – MEASURES TO ENHANCE THE UPTAKE OF LARGE SCALE SOLAR, OTHER
RENEWABLE ENERGY TECHNOLOGI ES AND ENERGY EFFICIENCY
ATTACHMENT A – ADDRESSING COMMUNITY CONCERNS
ABOUT WIND FARMS
1. The Minister for the Environment will issue a statement that the Government will
respond actively and in good faith to the findings of the Senate Select Committee on
Wind Turbines.
2. Subject to the outcomes of the Senate Select Committee, the Minister for the
Environment will seek the agreement of relevant Ministers to progress reforms to
improve the science relating to the sound of wind farms and the monitoring and
transparency of information and help for communities.
3. Improving science and monitoring
a. The Government will appoint in consultation with members of the Senate
Select Committee and key industry and regulatory bodies, an independent
scientific committee to provide research and advice to the Minister for the
Environment on the impact on the environment and human health of sound
(including low frequency and infrasound from wind turbines).
i. The independent scientific committee will be multidisciplinary,
adequately resourced, include at least three members and be
established by 1 September 2015.
b. The Committee will publish research on:
i. The development of Australian methodologies and frameworks in
sound measurement and standards for wind farms, including in the
field of infrasound and low frequency sound - to improve planning and
compliance decisions by state and territory authorities.
ii. Innovation in cost-effective, continuous sound monitoring of wind
farms.
iii. Options for wind farm operators to maximise transparency such as by
providing information on wind speed, operational statistics, operating
hours and sound monitoring.
4. Empowering Communities
a. The Minister for the Environment will establish a National Wind Farm
Commissioner to resolve complaints from concerned community residents
about the operations of wind turbine facilities. The Commissioner will be able
to refer complaints to relevant state authorities and help ensure that
complaints are addressed.
b. The Minister for the Environment will seek agreement from states and
territories to update and implement National Wind Farm Guidelines as
recommended by the independent scientific committee, which each state and
territory government should reflect in their relevant planning and
environmental frameworks, and with the aim of finalising the Guidelines
within 12 months. The Minister for the Environment will:
i. Promote with state and territory Environment Ministers at the July
2015 Meeting of Environment Ministers the guidelines; and
ii. Seek to obtain the agreement of state and territory Environment
Ministers through the National Environment Protection Council to
develop sound measures under the National Environmental Protection
Council Act 1994.
5. Transparency
a. The Commissioner will publish documents or links to documents, on its
website to provide the community with information including, but not limited
to:
i. The location of existing and proposed wind farms across Australia.
ii. Planning and environmental approvals in place for each wind farms
including links to state and territory planning approvals and
authorities.
iii. Renewable Energy Certificates received in respect of each wind farm.
iv. Data on wind farm operators including operating times, wind speed,
power output and sound monitoring.
ATTACHMENT B – MEASURES TO ENHANCE THE UPTAKE OF
LARGE SCALE SOLAR, OTHER RENEWABLE ENERGY
TECHNOLOGI ES AND ENERGY EFFICIENCY
1. Supporting large scale solar and other renewable energy deployment
a. The Department of the Environment to work with the relevant Departments
and agencies to develop a formal government strategy and implementation
details:
i. Which updates the government, industry and the community on the
forecast uptake of solar technologies under the RET, taking into
account new information on lower costs of solar technologies and
independent modelling which forecast that solar technologies will take
at least one third of the additional new capacity developments under
the RET; and
ii. To consider potential further support for solar and renewable
technologies, including:
1. Options to support community solar and solar-with-storage
projects by providing 'start-up funding' loans or grants to
assist with project feasibility and early-stage development.
2. Providing incentives for off-grid deployment of solar.
3. Opportunities for CSIRO to further develop and implement a
solar energy forecasting system for the NEM and SWIS.
4. Support development of appropriate safety/quality standards
and training for installers of batteries/storage on solar
systems.
5. Options to enable greater uptake of solar in government
housing.
6. Options to support and facilitate the development of other
renewable energy technologies.
2. Commit to enhanced support for solar technologies and other renewable
technologies through existing initiatives
a. The Government will write to the CEFC to ensure it adheres to its original
purpose, by changing the investment mandate to focus investment in
emerging and innovative renewable technologies and energy efficiency. This
will in turn increase the uptake of emerging technologies such as large scale
solar and energy efficiency.
3. Build awareness of existing support opportunities
a. The Government commits to develop a solar technology information package
to:
i. Highlight the funding support for solar RD&D and niche deployment
being provided through ARENA; and investment support for
deployment through CEFC.
ii. Promote the potential for the $20,000 instant asset write-off for small
businesses, announced in the 2015 Budget, to be used to invest in
solar to reduce energy costs.
iii. Highlight the potential for continued strong growth of solar and
battery technologies over the period to 2020 and beyond.