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:
- PPAs provide a supplemental service as customers retain their grid connection. Electricity supply remains accessible even if PPA supply is curtailed.
- Exempting PPAs would align with other Australian jurisdictions. This reduces confusion and uncertainty for businesses operating nationally.
- There are few risks to consumers from PPAs and they can be managed under exemption conditions. Generic consumer protections also apply.
- 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.