New federal government-backed rules aimed at weeding out shonky rooftop solar operators and preventing dodgy retail and installation practices come into effect around Australia on April 1 – that is, in less than 24 hours – making it a good time to take another look at what it all means.
The suite of reforms to the Small-scale Renewable Energy Scheme were unveiled in draft form in November, based on the findings of an Integrity Review of the Rooftop Solar PV Sector that was commissioned with some urgency by federal energy minister Angus Taylor in mid-2020.
The 63-page report made 13 recommendations, resulting in the Renewable Energy (Electricity) Amendment (Small-scale Renewable Energy Scheme and Other Measures) Regulations 2021, with the new rules scheduled to be rolled out in various stages throughout 2022, starting on April 01.
So what comes into play tomorrow?
The big change, as the Clean Energy Regulator has explained here and via a multitude of linked explainer documents and sample forms, is to the documentation required from rooftop solar installers, designers, agents and retailers when making claims for small-scale technology certificates (or STCs).
New rules for designers and installers
For designers and installers of rooftop solar systems, new documentation requirements include a written compliance statement confirming all relevant design and install standards have been met according to the requirements of both the SRES scheme and local, state and territory rules.
The statement must also confirm that the installer has a copy of the design and the system was installed by the book, including the electrical work being done by a licenced electrician, using PV modules and inverters approved under the SRES scheme. You can find a sample document prepared by the CER here.
Pics, or it didn’t happen
Further, the accredited installer of the rooftop solar system must provide evidence demonstrating they have physically installed or physically supervised the installation, such as time-stamped photos of this in action, including during job set up, during mid-installation check-up, and during testing and commissioning.
More information on how to meet on-site attendance obligations can be found on the CEC’s website. Essentially, the CER wants to ensure that the person ultimately responsible for the safety and quality of the installation is on site when needed and not, say, in another country.
“It is intended that the accredited installer responsible for the installation is on site for the majority of the time that the installation takes place,” the CER has said.
New rules for retailers
Retailers must also provide a written statement from April 01 onwards, in their case confirming: the name of the installer; whether the installer is an employee or subcontractor; that the unit is complete and generating, or is capable of generating, electricity; that (if applicable) the unit is connected to the grid, or the retailer’s obligations are complete in relation to grid connection.
Further, retailers are now required to confirm in writing that the solar system will perform in accordance with the contract – so, do what they said it would do – except to the extent that this is prevented by circumstances outside the retailer’s control.
This includes confirmation that all the relevant details about solar feed-in tariffs and grid export limits have been provided in writing to the owner and that information on the expected payback period, energy or cost savings for the unit has been provided in writing to the system.
This particular part of the new rules, which raised some concerns from the industry when it was first floated, is explored in some more detail in this Q&A document published by the CER.
Key questions include: “How can a retailer accurately provide an expected return on system performance, savings or payback periods given consumer consumption and feed-in tariffs change?”
The CER makes a decent effort to answer this, noting that as long as all key inputs are factored in – and potential changes to those inputs flagged – then this should suffice. Obviously, the main goal here is to stop dodgy operators from making promises to unwitting consumers that their solar systems can’t keep.
New rules for agents
The registered agent behind the solar install, who provides the STC assignment form, must include a mandatory declaration where the system owner assigns the right to create STCs to the registered agent.
The CER says that registered agents must ensure that their legal entity name is correctly reflected in the mandatory declaration and matches their REC Registry account name.
Further, if requested, they must provide information demonstrating that the inverter serial number(s) entered into the REC Registry is the serial number(s) of the inverter(s) installed at the address, such as a clear photo of the barcode label or sticker, obtained from the inverter label.
Inverter barcodes that have been scanned from cargo manifests or similar do not demonstrate the installation of panels. It is recommended that these photos are taken at the time of installation to avoid returning to site after installation and delays in processing.
If the solar retailer and registered agent are the same entity, this should be disclosed in writing to the system
owner as part of the package of information provided to them.
The CER provides this checklist to help agents collect all required information and complete mandatory documents according to the new rules for rooftop solar STCs.