Overall, we agree with the AER’s statement that Distributed Network Supply Providers (DNSPs) should only impose static exports on consumer energy resources (CER) in rare cases. However, we recommend that the Guidelines are tightened to ensure that these circumstances are as rare as possible. We propose three recommendations:

Recommendation 1: The Guidelines should be amended to say that DNSPs should do detailed, transparent analysis in the rare circumstances where a basic export service is denied. A static zero export limit will have significant impacts on consumers which justifies an in-depth investigation.

Recommendation 2: To build the trust and social licence required to harness the benefits of CER, information from this detailed network analysis must be communicated to consumers in an accessible and understandable manner. This communication needs to be extended further than DNSP websites or consumer’s connection agreements into the broader community a network operates in.

Recommendation 3: The Guidelines should be amended to say that if the analysis shows that the cost of network augmentation is only marginally higher (for example by 10%) than the benefits, networks should still augment. This amendment accounts for the costs of curtailment, such as consumer trust, that are difficult to measure. This amendment also accounts for the risk that as electrification increases in the future, network augmentation which consumers pay for to remove a static limit might become necessary anyway.”

Read our full submission here.