We welcome the opportunity to comment on the Australian Energy Regulator (AER)’s Export Tariff Guidelines for Distribution Networks Consultation Paper. We support the AER creating strong guidelines for determining basic export levels and when and how networks propose export tariffs. Strong collaboration and guidance are necessary as we move from large scale generation and low consumer investment to lower scale generation and high consumer investment.

The introduction of basic export levels and export tariffs recognise that distribution networks no longer exist just to serve consumption, but also to serve exports. Basic export levels should be set to enable most consumers to install sufficient solar to meet their basic needs. If set correctly, export tariffs can send strong signals to consumers to change their behaviour in ways that will allow for more solar to be added to the grid, benefiting everyone. If network investment is required to allow for more solar to connect to the grid, effective export tariffs allow the cost of these upgrades to be more effectively recovered by those with solar, as opposed to those without it.

While there may be circumstances that require the use of export tariffs, the network application of export tariffs should in principle be rare, observable, and effective.

We go into further detail on each of these instances in our submission here.