Submission: Draft decisions and reasons for proposed changes to the scope and design of the electricity licensing regime

Share on twitter
Share on linkedin
Share on facebook

Compliance Quarter supports the Northern Territory Utilities Commission’s proposal to take a risk-based approach to determining if an activity requires an electricity supply licence or can operate under an exemption. This approach aligns regulation with the potential impacts of an activity and avoids imposing unnecessary obligations and costs.

Compliance Quarter agrees with exempting electric vehicle charging stations from licensing requirements. They also support a standing exemption for small energy storage systems to facilitate uptake and benefit consumers.

Compliance Quarter submits that power purchase agreements (PPAs) for small-scale solar PV systems and battery storage systems should be exempt from licensing. Their reasons are:

  1. PPAs provide a supplemental service as customers retain their grid connection. Electricity supply remains accessible even if PPA supply is curtailed.
  2. Exempting PPAs would align with other Australian jurisdictions. This reduces confusion and uncertainty for businesses operating nationally.
  3. There are few risks to consumers from PPAs and they can be managed under exemption conditions. Generic consumer protections also apply.
  4. The costs of licensing PPAs outweigh the likely benefits. Licensing imposes fees and costs that may discourage emerging technologies and business models. Licensing is a barrier for businesses looking to offer PPAs in the NT, resulting in fewer options for consumers. Safety risks can be addressed through a condition to comply with electrical safety requirements.

Compliance Quarter submits that the existing small-scale renewable energy exemption should be amended to apply to the sale and supply of electricity by the owner or operator of a renewable generator to site occupants. Condition 3(b) should be amended to require excess energy be supplied to a licensed retailer or exempt operator. The existing requirement for a ‘contract’ may require a separate excess energy contract, whereas this may be covered in a supply contract allowing for excess energy.

Compliance Quarter does not agree that the existing small-scale renewable energy exemption should incorporate non-renewable generation. Non-renewable generators have unique risks that should be considered separately, e.g. installation and safety risks. While backup diesel generators should be permitted in some situations, exemptions should tie into appropriate installation and safety regulations.

Compliance Quarter submits that exempting PPAs adopts an approach proportionate to risks, reduces barriers to emerging technologies, and aligns with other jurisdictions. An exemption with conditions to comply with technical and safety requirements should sufficiently protect customers while enabling them to benefit from PPAs.

More to explorer

Autumn leaves falling with copy space on black background

Avoiding Compliance Atrophy: The Critical Role of Assurance Reviews for Growing Energy Retailers

As energy retailers expand their customer base and operations, ensuring ongoing compliance with regulatory obligations can become increasingly challenging. A key risk is “compliance atrophy” – where initially compliant documents, processes and systems slowly deteriorate and waste away over time if not regularly monitored and reviewed. What is compliance atrophy? Compliance atrophy is typically a result of documents, processes and systems being ‘updated’ or ‘reworded’ to reflect changes in focus for the business and input from other stakeholders including marketing

person holding debit card

AER payment difficulty framework review

The Australian Energy Regulator (AER) is conducting a review of the consumer protections available under the National Energy Customer Framework (NECF) for those experiencing payment difficulties. On 14 May 2024, the AER released an issues paper for consultation. The review is driven by the commitment in Action 8 of the ‘Towards Energy Equity’ strategy in which the AER committed to considering whether improvements could be made to the NECF to ensure that consumers experiencing payment difficulties are identified early, engaged

Technicians installing photovoltaic solar panels on roof of house.

Compliance Quarter’s Submission to the AER’s Review of the Compliance Procedures and Guidelines

On 11 April 2024, Compliance Quarter put forward its submission on proposed changes to the AER Compliance Procedures and Guidelines. The AER is reviewing its Compliance procedures and guidelines, which set out the manner and form in which energy businesses in jurisdictions that have adopted the National Energy Retail Law must submit compliance information and data to the AER. We argue that there should be consideration of measures to incentivise early reporting of potential breaches. These may, for example, take the

Leave a Reply

Your email address will not be published. Required fields are marked *