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Defining small scale and large scale solar systems

28 February 2019
RET

Contents

The guidance and scenarios help participants clarify scheme eligibility for large and complex solar photovoltaic (PV) systems such as multiple adjoining or electrically connected devices. Please refer to the Renewable Energy (Electricity) Amendment (Small-scale Solar Eligibility and Other Measures) Regulations 2019 or explanatory statement for full details.

The Renewable Energy (Electricity) Regulations 2001 (the Regulations) clarifies how the boundary of a device should be determined where multiple solar PV systems are installed. In particular, connected systems under subregulation 3(2) which in aggregate exceed 100kW are not ‘small generation units’ defined in Renewable Energy (Electricity) Act 2000 (the Act).

This guidance and scenarios are not intended for typical scheme participants in the Small-scale Renewable Energy Scheme and Large-scale Renewable Energy Target.

Key concepts in the scenarios

The National Meter Indicator (NMI) is equivalent to the grid connection point and a commercial sub-meter is equivalent to a commercial meter that is subsidiary to the connection point. A commercial meter is used to record the consumption of electricity for the purposes of a financial transaction between unrelated parties in relation to the consumption of electricity as defined in subregulation 3(1) of the Regulations.

When a system is off-grid and does not interact with an external transmission or distribution network, the boundary of the device will be determined based on the system’s entirety, including all and any interconnected components.

Where the total capacity of a device exceeds 100kW, the device may be accredited as a power station under the Large-scale Renewable Energy Target.

Exceptions

The default position of the Clean Energy Regulator will be subject to the Act and supporting Regulations when assessing applications for solar PV systems as Small Generation Units and power stations.

If an applicant is aware of any technical or contractual arrangements that result in a proposed system not fulfilling the requirements, then the applicant must provide full details of the proposed system to the Clean Energy Regulator, outlining why the system does not fit the requirements and why it is eligible for the scheme the applicant wants to register for.

Participants who have previously received advice from the Clean Energy Regulator which is contrary to the requirements set out in subregultion 3(2) of the Renewable Energy (Electricity) Regulations 2001 are encouraged to contact the Clean Energy Regulator prior to system installation to clarify scheme eligibility.

Disclaimer

This information is for general use only and does not represent a statement of the policy of the Commonwealth of Australia. The Commonwealth of Australia and all persons acting for the Commonwealth preparing this information accept no liability for the accuracy of, or inferences from, the information, or for any action as a result of any person’s or group’s interpretations, deductions, conclusions, or actions in relying on this information.

This information provides examples of how the Boundaries of a solar photovoltaic (PV) device can be determined. This information should be read in conjunction with the Act and supporting regulations. Changes to the legislation may affect this information.

This information is not intended to provide legal advice. Entities are responsible for determining their obligations under the law and for applying the law to their individual circumstances. Entities should seek independent professional advice if they have any concerns.

Scenarios

Scenario 1: Five stores in a retail complex, each with a 50 kW PV system, have commercial sub-meters and all connect to the grid via one NMI.

  • Commercial sub-meters define the boundaries of the devices.
  • Each system would be considered a separate device with a capacity rating under 100 kW and therefore could be eligible for small-scale technology certificates (STCs) under the Small-scale Renewable Energy Scheme.
  • These systems would not be eligible for large-scale generation certificates (LGCs) under the Large-scale Renewable Energy Target.

Scenario 2: Five stores in a retail complex, each with a 60 kW system, have commercial sub-meters and all connect to the grid via one NMI. Two of the stores are electrically connected behind the commercial sub-meters.

  • Commercial sub-meters define the boundaries of the devices.
  • The two stores that are electrically connected behind the commercial sub-meters are considered to be one device that exceeds 100 kW which is not eligible for STCs under the Small-scale Renewable Energy Scheme.
  • For the remaining three stores that are not electrically connected to any other stores, the 60 kW systems are considered to be separate devices and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 3: In a retail complex with two stores, each with commercial sub-meters and all connect to the grid via one NMI. One store has two 60 kW systems and the other a single 60 kW system.

  • Commercial sub-meters define the boundaries of the devices.
  • The store with two systems is considered to be one device that exceeds 100 kW which is not eligible for STCs under the Small-scale Renewable Energy Scheme
  • For the store with one system, the system is considered to be separate device and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 4: A single commercial facility spread over three adjacent properties, each with a 50 kW system. All connected to the grid via one NMI.

  • NMI defines the boundary of the device.
  • The system would be considered a device that exceeds 100 kW and therefore could be eligible for LGCs under the Large-scale Renewable Energy Target.
  • This system would not be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 5: A single commercial facility spread over three adjacent properties, each with a 50 kW rooftop system. Each connected to the grid via separate NMIs. The electricity generated is used on-site.

  • NMIs define the boundaries of the devices.
  • Each system would be considered a separate device under a 100 kW and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • These systems would not be eligible for LGCs under the Large-scale Renewable Energy Target.

Scenario 6: A single commercial facility spread over three adjacent properties, each with a 50 kW system. Each property is connected to the grid via a separate NMI but all properties are electrically connected behind the NMIs.

  • As the facility is electrically connected throughout, the three NMIs are considered the boundary of one device.
  • The system would be considered a device that exceeds 100 kW and therefore could be eligible for LGCs under the Large-scale Renewable Energy Target.
  • This system would not be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 7: Two retail complexes are on adjacent properties, each connected to the grid via a separate NMI. Each complex includes one store which has a commercial sub-meter and one store without a commercial sub-meter. The stores each have a 60kW system installed. The stores with a sub-meter have an electrical connection between the stores behind the commercial sub-meters.

  • The two stores that are electrically connected with behind the commercial sub-meters are considered to be one device that exceeds 100 kW which is not eligible for STCs under the Small-scale Renewable Energy Scheme.
  • The two stores that are not electrically connected to any other store or to the connection point at the adjacent retail complex are considered to be separate devices under 100 kW and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 8: A university is connected to grid via a single NMI with individual non-commercial sub-meters on individual buildings (the sub-meters are used to maintain building management systems). The university precinct includes a main building with a 100kW system and two sets of housing each with a 5 kW system.

  • NMI defines the boundary of the device.
  • The sub-meters do not meet the definition of a commercial meter.
  • The system would be considered a device that exceeds 100 kW and therefore could be eligible for LGCs under the Large-scale Renewable Energy Target.
  • This system would not be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 9: An apartment complex connected to the grid via a single NMI. The complex includes a communal precinct with a commercial sub-meter, a 100 kW system and four apartments with non-commercial metering, two of which have a 3 kW system.

  • For the communal building, the commercial sub metering defines the 100 kW system as a device. The system is considered a device that is 100 kW or less and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • For the apartments, the NMI defines the boundary of the device for systems installed, not the non-commercial meters. Since the combined system size for all apartments is 100kW or less, the two 3 kW apartment systems could be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • None of these systems would be eligible for LGCs under the Large-scale Renewable Energy Target.

Scenario 10: A housing estate where each house has its own NMI and an individual 5kW system owned by the developer and leased to the householders.

  • NMIs define the boundaries of the devices.
  • Each system would be considered a separate device under 100 kW and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • These systems would not be eligible for LGCs under the Large-scale Renewable Energy Target.

Scenario 11: A solar farm developer has installed ten ground mounted 100 kW systems on ten adjoining sites each with separate NMIs that are connected to the grid via one substation installed as part of the development. There is no material onsite use of the electricity generated.

  • The system would be considered a device that exceeds 100 kW if at least three of the following criteria apply:
    • 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.
  • This applies regardless of ownership or operational control of the 100 kW systems and/or interconnecting infrastructure.
  • All four criteria are met in this scenario so this system would not be eligible for STCs under the Small-scale Renewable Energy Scheme but could be eligible for LGCs under the Large-scale Renewable Energy Target.

Scenario 12: A farm with an 80 kW system on a shed and a 50 kW system on the house, both connected to the grid via one NMI, and one 80 kW off-grid pumping system.

  • NMI defines the boundary of the grid-connected device. The system would be considered a device that exceeds 100 kW and therefore could be eligible for LGCs under the Large-scale Renewable Energy Target. This system would not be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • The off-grid system would be considered a separate device under 100 kW and therefore could be eligible for STCs under the Small-scale Renewable Energy Scheme.

Scenario 13: A residential household with a 50 kW PV system.

  • NMI defines the boundary of the device.
  • The system would be considered a device under 100 kW and could be eligible for STCs under the Small-scale Renewable Energy Scheme.
  • This system would not be eligible for LGCs under the Large-scale Renewable Energy Target.

Scenario 14: A 1 MW solar farm with one NMI, and connected to the grid via one substation.

  • The system would be considered a device that exceeds 100 kW if at least three of the following criteria apply:
    • 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.
  • This system would not be eligible for STCs under the Small-scale Renewable Energy Scheme but could be eligible for LGCs under the Large-scale Renewable Energy Target.

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