On 15 February 2018, the Queensland Parliament re-introduced a Bill to change the Electricity Act 1994 (Qld). This Bill provides the industry with clearer rules about adding PV panels, generating systems and/or energy storage devices (such as batteries), to PV systems that already qualify for the 44 cents/kWh Feed-in Tariff (44c FiT) without forfeiting this premium tariff.
If the Bill is passed in its current format, 15 February 2018 will be the date that the changes come into effect rather than the previously advised date of 15 June 2017.
Therefore, if a customer with a PV system that qualifies for the 44c FiT does any of the following after 15 February 2018, they may forfeit eligibility for the 44c FiT (subject to some transitional provisions described later in this Update):
- add extra panels to create a total array kW capacity that exceeds the rated AC power capacity (kW) of the existing inverter/s,
- add an energy storage system (such as a battery) that can discharge at the same time as the PV system (other than during a network outage) or export to our supply network, or
- add another generating system to the same tariff that can operate at the same time as the PV system (other than during a network outage) or export to our supply network.
Until the Bill is passed, if we receive an application for an array upgrade on a 44c FiT-eligible PV system that will create a total array capacity exceeding the rated AC power capacity of the existing inverter/s, our Solar Team will contact the applicant to confirm their intent. The applicant can then choose to:
- proceed, knowing the customer’s 44c FiT will be forfeited, although the 44c FiT will only be removed once the Bill has passed,
- resubmit an application for an increase in array capacity that will not cause the total array capacity to exceed the inverter capacity, or
- withdraw their application.
Remember that under the energy legislation and our connection contracts, you must obtain our consent before making modifications to a generating system (including, but not limited to, increasing array or inverter capacity and changing export limitation settings). This consent can be requested by lodging a network connection application through our Electrical Partners Portal.
If a customer entered into a contract to purchase additional panels that take the total array capacity above the inverter capacity before 15 February 2018, those panels can still be installed without forfeiting the 44c FiT if:
- the installation occurs within a reasonable timeframe,
- the customer financially committed to purchase the panels before 15 February 2018, and
- evidence of that financial commitment is provided to our Solar Team on request.
We understand that one or more panels in an array may need replacement under warranty. These rule changes have implications for the customer’s 44c FiT eligibility where the array with failed panels is already the same or a higher capacity as the connected inverter(s). We also understand that the existing panel wattage cannot always be matched exactly due to discontinued panel models, leaving only higher-wattage panels available.
We have worked with the Department of Natural Resources, Mines and Energy to provide the following guidance:
- The installer must make every effort to match the wattage of the new panels with the wattage of the original panels, whether replacing one panel or the entire array.
- Where the wattage can’t be exactly matched, an increase in wattage of up to 5% across the entire array is allowable without impacting the customer's eligibility for the 44c FiT.
- If a high proportion of panels in an array need to be replaced, it may be necessary to reduce the number of panels to keep the increase to the total array capacity within the 5% allowance.
- Any increase in the total array capacity up to and including 5% will not require our consent.
- Any increase in the total array capacity over 5% will require our consent (meaning a new network connection application must be lodged) and will jeopardise the customer’s eligibility for the 44c FiT.
Battery energy storage systems
The changed rules are designed to allow customers on the 44c FiT to install a battery system if they wish, without forfeiting the 44c FiT. However, it is important to note that the system cannot be programmed in such a way that could result in the battery discharging while the PV system is operating or more electricity being exported than would otherwise be possible.
Applicants should attach a schematic diagram to any application to add batteries to a 44c FiT-eligible PV system, including a description of the battery charging/discharging mode, demonstrating compliance with these requirements. Applications to add a battery system to a 44c FiT-eligible PV system are being processed on the understanding that the programming will comply with the changed rules.
Please note we use automated meter data filters to identify sudden increases in exported electricity volumes. If we investigate and identify a battery system that is not compliant, the 44c FiT will be forfeited. The installer may also be referred to the Clean Energy Council.
Additional generating systems
The Bill clarifies, rather than changes, the current policy about adding additional generating systems to 44c FiT-eligible PV systems. If any type of generating system is added to the same tariff circuit and operates at the same time as the qualifying PV system (except during a network outage) or is able to export to the grid, eligibility for the 44c FiT will be forfeited.
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