When is a small-scale solar power system a large-scale system? The Department of Environment And Energy wants to clarify this through changes to renewable energy regulations.
The Department is quick to point out that its proposed amendments will not affect incentives provided to Australian households and businesses installing solar power systems under the Small-scale Renewable Energy Scheme (SRES); i.e. the “solar rebate“.
Section 3(2) of the Renewable Energy (Electricity) Regulations 2001 states an eligible system under the SRES is a device with a capacity of no more than 100kW and that generates no more than 250MWh of electricity annually.
But what is considered a “device”? It’s not unheard of for a single site to have multiple 99kW commercial solar systems, making all of them potentially eligible for inclusion under the SRES.
The Department states there needs to be clarification on what should be considered the boundary of a solar PV device.
“The lack of clarity is creating uncertainty for scheme participants and adding burden for both scheme participants and the Clean Energy Regulator,” it says.
By providing more explicit criteria, the Department says this will prevent gaming of the system; stopping large solar projects from participating in the SRES instead of the Large-scale Renewable Energy Target (LRET).
Among the proposed related amendments contained in the Renewable Energy (Electricity) Amendment (Small-scale Solar Eligibility and Other Measures) Regulations 2019, 2 or more photovoltaic systems will be considered a device if at least three of the following criteria are met:
- the systems are located at a single site or multiple adjoining sites in the same area;
- the systems are installed for the primary purpose of generating electricity for export to a grid;
- electrical infrastructure (other than metering equipment) is needed to connect the systems to a grid;
- more than 50% of the total kW rating of all systems is from ground mounted systems.
Other situations where multiple systems would be considered a single device under the proposed changes can be viewed here.
Solar installers are encouraged to provide their feedback on the amendments by December 14. Submission instructions are here.
To date, more than 1.97 million solar power systems have been installed under the SRES. According to the Clean Energy Regulator’s latest Small-scale Renewable Energy Tracker, 50,689 small-scale solar systems were installed from July to the end of September this year. Among these were 4,844 commercial sized solar PV systems (10-100kW).
To me, three system size definitions would be appropriate – per property or grid connection –
Small Scale – up to and including 10kW capacity
Large Scale – greater than 10kW and up to 100kW capacity
Utility scale – greater than 100 kW capacity
But, hey, I am just a layman, and, what we plebs think, does not matter to those in power.