Chapter 14

Access Rights and Consumer Protections in a Distributed Energy System

Fiona Orton*
Tim Nelson*
Michael Pierce**
Tony Chappel*
*    AGL Energy, Sydney, NSW, Australia
**    AGL Energy, Docklands, VIC, Australia

Abstract

Within Australia’s National Electricity Market (NEM), distributed technologies are delivering energy in ways that were not contemplated when regulations governing consumer rights and protections were developed. The adoption of technologies, such as rooftop solar, battery storage, electric vehicles, and virtual power plants will give rise to an increasingly heterogeneous mix of electricity customers who will expect their utilities to cater for their individual preferences. Over time, the types of grid services that are considered to be “essential” may evolve, leading to redefined and technology-neutral access rights for electricity infrastructure. Consumer protection frameworks will need to balance innovation and consumer choice with universal access to electricity supply.

Keywords

consumer protections
essential service
grid access
distributed energy resources
solar
battery storage
virtual power plant
AGL
Australia

1. Introduction

The supply of electricity to residential and small business customers within Australia’s National Electricity Market (NEM) is considered to be an “essential service,” meaning that it underpins health, well-being, and a reasonable quality of life. Electricity retailers are, therefore, required to meet a range of government licensing conditions that deliver additional consumer protections for these customers, to guarantee access to high-quality electricity supply, regardless of the capacity to pay. These protections go well beyond Australia’s consumer laws, which apply to the sale of all products and services.
As with much of the National Electricity Law (NEL) and supporting regulatory framework in Australia, these provisions were implemented before the widespread availability of “behind-the-meter” energy technologies, and with the assumption that electricity would be exclusively supplied to customers from the grid, under a linear supply model that had been in place for decades, where electricity was generated in large, centralized, and predominantly thermal power stations, and transported via transmission and distribution networks to end users. With the rapid expansion of home energy technologies, opportunities are emerging for end users to participate more directly in electricity markets, redefining the services that customers expect from energy providers. As distributed energy resources (DERs) become increasingly mainstream, market rules and regulations must be reviewed and updated to ensure that they reflect consumer choices about how essential services are accessed, and create a level playing field on which innovative and conventional business models can compete at the grid’s edge.
Many new energy products, such as rooftop solar, energy storage, electric vehicles (EVs), digital metering and energy efficiency, along with the digitally enabled energy management and trading platforms that make use of these technologies, have not historically been covered by electricity supply regulations. As a result, markets are not “technology neutral,” with different rules often applying to the pricing, connection, and sale of demand- and supply-side appliances, based on technology type rather than fundamental properties or system impacts- positive or negative. Australian State and Federal Energy Ministers—collectively known as the COAG Energy Council (2016)—have noted this inconsistency, stating that “different customer protections apply to products and services for electricity supply behind the meter depending on the business model employed.” Policymakers and regulators are considering how market rules and structures should evolve to better incorporate emerging technologies, and to facilitate a more distributed, bidirectional, and customer-centric energy system1—a challenge faced globally, as described by energy regulators from the USA, Australia, and Europe in this volume. Nevertheless, some observers argue that reform is failing to keep pace with technology advancement and that legacy regulations are complex and inherently biased toward traditional supply models, resulting in market distortions, inefficiencies, and restricting the range of products and services available to customers (Parkinson, 2016).
While “cost-reflective pricing” will be a key determinant of the uptake rates of new technologies, the regulatory framework is equally important. This chapter explores how consumer protections and grid access rights may need to be redefined in energy markets featuring widespread DERs, using Australia’s NEM as a case study. Section 2 provides a summary of recent market developments in the NEM for context. Section 3 outlines the current uptake and future potential of DERs in the NEM. In Section 4, the impact of these products on household energy demand is examined, highlighting the heterogeneity of customer needs that may emerge. Section 5 discusses how access rights and consumer protections are currently applied and where reform may be required, followed by the chapter’s conclusions.

2. Consumer market developments in the NEM

Between 2008 and 2015, household electricity prices rose substantially, more than doubling in some NEM jurisdictions (Simshauser and Nelson, 2013), primarily due to a very significant increase in capital expenditure on distribution networks to meet tighter reliability standards and to service projected growth in peak demand, which in many cases did not eventuate. Concern about rapidly rising bills prompted customers to cut their consumption and install solar PV as a substitute for grid supply, and between 2009 and 2014, the average household demand in the NEM dropped by 18% (ESAA, 2015).
The prominence of flat “average rate” tariff structures encouraged customers to reduce consumption at the times most convenient to them, rather than at times that would produce system-wide benefits. As a result, peak demand continued to grow or remained high with the use of home air-conditioning units on hot summer days,2 while underlying demand declined, leading to a significant reduction in network capacity utilization. As energy volumes fell, unit prices were adjusted upward to recover network revenues, leading to further conservation or substitution; a phenomenon known as an “energy market death spiral.” For many customers, bills have increased significantly in return for no perceptible improvement in service quality and despite efforts to reduce consumption.
Reflecting the results of market research, Energy Consumers Australia (ECA, 2016) argues that consumers are dissatisfied with the “value for money” they are receiving for electricity services from conventional suppliers, ranking the sector below a range of others, including banking, water, telecommunications, and insurance. Energy Consumers Australia (ECA) states that customers generally neither believe that the electricity market is working in their best interests, nor that it will improve in future. Most consumers are unlikely to recommend their current electricity retailer to a friend or colleague, with “Net Promoter Scores” for the industry substantially negative. As a result, customers are actively seeking out alternative technologies and supply arrangements that reduce their reliance on supplies from conventional utilities, allowing them to reduce utility bills and take greater control over their spending, including solar PV, battery storage, and energy efficiency. New retail energy products are also emerging to provide customers with different ways to control usage and spending. For example, Origin Energy, one of the largest integrated energy companies in Australia, has introduced the “Predictable Plan,” where customers pay the same fixed bill for 12 months, regardless of consumption; and new entrant retailers, such as Mojo Power and Powershop, now offer energy “subscriptions” and online prepurchasing of low-price “Powerpacks,” which are marketed to customers as an alternative to conventional retail energy plans.
The introduction of more cost-reflective tariff structures for energy networks—particularly “demand tariffs”—has been considered for several years as an option to reduce future price rises by promoting more efficient use of the existing infrastructure, and reducing cross-subsidies between customers, as discussed in the Foreword by Conboy. Demand tariffs involve a proportion of network charges being linked to the customer’s maximum demand from the grid during predefined windows, such as weekday afternoons and evenings. In doing so, they better reflect the high capital costs associated with grid expansions to meet demand peaks that occur for only a few hours each year, and provide incentives for customers to shift demand from these times. While the broad introduction of demand tariffs would arguably provide fairer pricing and encourage the efficient deployment of energy technologies, the implementation of pricing reform is slow. In Victoria, the only NEM jurisdiction with a mass rollout of digital meters, demand tariffs are to be implemented on an opt-in rather than opt-out basis, and of the customers who could benefit, most would make only modest savings: typically less than approximately A$100 per year. Networks are therefore predicting low uptake rates—less than 2.5% of customers over the 2017–20 period (AER, 2016a). Adoption is likely to be even slower in other jurisdictions without widespread advanced metering infrastructure.
The public—and therefore policymakers—appear to be skeptical of pricing changes that increase complexity, and which may leave some customers worse off, despite the opportunity for lower costs and greater efficiencies in the long term. The Consumer Action Law Centre (CALC, 2016) states that for innovation and competition to thrive in Australian energy markets, consumers need to be willing to participate, and must “trust that the market will deliver the outcomes they expect in terms of service, quality and price.” Given the prevailing low levels of consumer trust in energy market participants and governance institutions, convincing consumers of the benefits of tariff reform remains a significant challenge.

3. Outlook for distributed technologies in the NEM

In this section, the current adoption and future potential of a range of distributed energy technologies are discussed, including solar PV, home energy storage, EVs, and virtual power plants (VPPs).

3.1. Solar PV

Australia has some of the highest rates of solar PV installation globally; by June 2016 almost 5 GW of small-scale solar PV had been installed across 1.55 million rooftops (AEC, 2016). In South Australia and Queensland, penetration of household solar exceeds 25%, with the national average around 17%. Prior to 2012, solar installations were largely driven by government renewable energy policies, which provided significant capital subsidies and premium feed-in tariffs (FiT). Over time, generous subsidy and FiT programs were scaled back, removed, or closed to new entrants. Nevertheless, as technology costs have fallen, new installations have remained popular, with self-generated solar power now representing a cost-effective substitute for grid supplies in several states with little or no subsidy.3
The installed capacity of small-scale solar PV is expected to grow steadily for the foreseeable future, particularly with new financing and business models emerging that provide solar with low or no upfront costs. Origin Energy has estimated that Australia could have as many as 5.3 million rooftops that are suitable for solar, but are currently without installations (Keane, 2015), and Jacobs (2016) forecasts that installation rates will remain high until the early 2030s when market saturation will be reached in some regions. Morgan Stanley (2016) observes: “Given the unlimited supply, large market size, and the compelling economics, the only remaining constraint is rooftop space.” Fig. 14.1 presents historical installations and a range of forecasts to 2030, all of which predict that the installed capacity will more than triple over this period. Bloomberg New Energy Finance (BNEF, 2015) predict that by 2040, around half of all residential buildings will have rooftop solar and 18% of all generation will occur behind the meter.
image
Figure 14.1 Australian small-scale solar PV installation and forecasts to 2030.4
AEMO, Australian Energy Market Operator; ENA, Energy Networks Australia; NEM, National Electricity Market.

3.2. Energy Storage

While the current capacity of battery storage installed behind the meter in Australia is very low, installations are expected to grow rapidly as system costs fall. Lithium-ion energy storage is not generally considered to be economically viable yet, with payback periods for most customers above the 10-year warranty period of commercially available units. Nevertheless there is an intense public interest in the technology, with 46% of survey respondents answering that they would “definitely” or “maybe” consider installing solar and battery storage (Morgan Stanley, 2016). For those customers who were “not interested” or “unsure,” the top reasons provided were high costs and belief that the technology would improve, or costs would go down, in future, indicating that the market is likely to grow. Indeed some analysts suggest that installing solar with storage is already cheaper for average residential customers than grid supply alone (Mountain, 2016).
There are several battery storage product offerings already available to Australian households, including from the NEM’s three large, vertically integrated electricity providers: AGL Energy, Energy Australia, and Origin Energy; several smaller energy retailers; and independent solar installers. Morgan Stanley (2016) predicts that the average installed cost of a 7-kWh residential battery system could drop by around 40% in 2 years, from almost A$10,000 in 2016 to around $5,500 in 2018, mostly due to falling battery pack costs.5 This indicates a potential market size across the NEM of 1–2.2 million homes by 2020—between 11% and 25% of households—including half a million “retrofits” of battery storage units to existing solar installations. A range of forecasts are shown in Fig. 14.2. While these analysts all agree that battery technology will play a significant role in energy markets, their predictions about when installations will accelerate are somewhat divergent.
image
Figure 14.2 Australian behind-the-meter storage forecasts to 2030.
The main reason that customers give for being interested in home energy storage is the potential to reduce grid power use and thereby cut energy bills. For many households, solar generation and household demand are not closely correlated, and battery storage provides the opportunity to store surplus daytime generation for use in the evening when demand typically peaks. Dissatisfaction with traditional energy providers and a strong desire to control energy spending may encourage some households to install battery storage, even if the economics are not considered to be conventionally viable.6 If technology costs drop to the point that a home energy storage system can be installed for less than A$5000, mainstream uptake may expand quickly, becoming a “credit card” purchase for many households, rather than an economic decision based on cost benefit. Solar installations in Australia accelerated rapidly once the typical out-of-pocket expense for households fell below this threshold, and the payback period of the investment was less than 3 years, and similar trajectories have been forecast for battery storage if these conditions are met. Households may also seek to install energy storage systems to avoid “bill shock” when their premium solar FiTs expire, suddenly exposing them to much higher energy bills. For example, the New South Wales Solar Bonus Scheme7 closed in December 2016 for over 146,000 customers, many of whom have paid low or no electricity bills for several years. The ability to maintain power supply during blackouts may also motivate some customers to install home storage.8
The structure of energy tariffs will also influence storage installation. In 2014, the Australian Energy Markets Commission (AEMC) made rules requiring networks to provide more “cost-reflective” pricing, and as shown in Table 14.1, most will begin offering demand tariffs for residential customers from 2017 on an opt-in basis. Both demand and Time-of-Use tariffs can improve the economics of battery storage, by providing incentives for pricing arbitrage; charging the battery when prices are low for use when prices are high, or using stored energy to moderate or eliminate demand from the grid during peak times. New storage products are already being developed to help customers optimize usage under new tariff arrangements, such as from Sunverge Energy (2016), which recently added demand charge management to its platform, which it estimates could reduce power bills for Australian customers by up to 50%.

Table 14.1

Cost-Reflective Network Tariffs From 2017

Network business Proposed tariff
Ergon Opt-in Seasonal Time-of-Use Energy and Seasonal Time-of-Use Demand tariffs
Energex Opt-in Demand tariff includes Hot Water Tariff for Demand customers
Ausgrid Opt-in Time-of-Use tariffs. From July 1, 2018, all new customers assigned to Time-of-Use tariffs with opportunity to opt-out to a transitional tariff. All existing customers with digital metering to be assigned to this transitional tariff on July 1, 2018
Essential Time-of-Use tariff default for new customers, new solar PV installations and metering upgrades. Opt-in Demand-based tariffs also available
Endeavour Opt-in Time-of-Use tariffs. All new customers with interval meters assigned to Time-of-Use tariffs from July 1, 2018 on an opt-out basis
ActewAGL Time-of-Use tariff default for all new residential and small business customers. Small business customers can opt-in to Demand tariffs. Possible gradual introduction from December 1, 2017 of residential demand tariff
Citipower. Powercor, United Energy, Jemena, AusNet Opt-in residential Demand Tariffs (not available in AusNet service area until 2018). Opt-in Demand tariffs for all small business customers consuming <60 MWh per annum. United and Jemena: Demand tariffs mandatory for small businesses consuming >60 MWh per annum. Powercor, CitiPower, and AusNet: transitional Demand tariff mandatory for small business consuming >60 MWh per annum. Cost reflectivity of the transitional tariff will increase between 2017 and 2022
South Australia Power Networks Opt-in cost-reflective residential Demand tariff. Opt-in “fully” cost-reflective demand tariff for small business customers. Mandatory assignment to transitional Demand tariff (50% cost reflective Demand) for new three-phase customers and progressive increases in cost-reflectivity until 2022

Source: Distribution network businesses tariff statements.

Despite forecasts of rapid deployment for behind-the-meter energy storage, coexistence with the grid, rather than full substitution is the most likely outcome for most customers (Nelson and McNeil, 2016). Wood and Blowers (2015) found that for typical customers to achieve 99.9% reliability with an “off-grid” system—equivalent to around 9 h of outage per year—5 kW of solar PV and 85 kWh of storage would be needed, at an estimated cost of A$72,000; both the large area of roof space required and the system expense would be prohibitive for most households. Hence most customers are likely to remain connected to the grid for the foreseeable future; although for households with solar and storage, this may no longer be a major source of energy supply.

3.3. Electric Vehicles

Batteries currently comprise around a third of EV costs, so as lithium-ion battery costs fall, EVs may become cost competitive with conventional vehicles on a life-cycle basis. The pairing of driverless technology with EVs could also accelerate uptake; as explored by Webb & Wilson in Chapter 6. While there are currently very few EVs in Australia, Energeia (2015) estimates that the economically efficient adoption rate is 4 million by 2035, representing around 22% of the light passenger fleet, with interim targets of around 900,000 in 2025 and 2 million in 2030. However, EV sales appear likely to fall short of these figures due to market barriers, including the high purchase price of EVs; low public familiarity; and unpriced externalities, such as greenhouse gas emissions, lack of public charging infrastructure, and technical limitations, including range.
Few EV models are currently available to Australian consumers, and costs are high and adoption rates low. Australia has not introduced national policies to support EV uptake, which have proved effective in other global markets, such as vehicle emission standards, capital subsidies, exemptions from charges and taxes, preferential access to transit lanes and parking spaces, or government subsidized charging infrastructure. EV manufacturers have, therefore, been reluctant to invest in the small Australian market, and many popular models internationally are not available in Australia, including the Nissan LEAF Gen 2, Chevrolet Volt and Bolt, and Renault ZOE (ClimateWorks, 2016). While vehicle availability and customer choice remain low, mass adoption of EVs in Australia appears unlikely, and may lag behind other global markets.
EVs are likely to have a fairly minor impact on electricity demand in the NEM. Projections prepared for the Australian Energy Market Operator (AEMO) show that even if uptake is high, 2035 electricity demand would only increase by 4% (Jacobs, 2016). However, for individual households, EV ownership can increase electricity use by 30%–50%. It is therefore unsurprising that energy retailers are beginning to develop new products tailored to the needs of early EV adopters. In June 2016, AGL Energy announced that it would offer an “all you can eat” EV plan, where EV customers receive unlimited vehicle charging, with carbon offsetting, for A$1 per day. Click Energy has also launched a new energy plan for EV drivers, offering lower energy rates for the household’s total energy purchase, not just vehicle charging.
As mobile energy storage devices, EVs also have the potential to discharge energy for use during peak times, or to provide grid-support services. To date these kinds of “vehicle-to-home” or “vehicle-to-grid” applications have generally not been supported by vehicle manufacturers. For example, Tesla has developed a range of both stationary energy storage products and EVs rather than combining their functionality into a single product. However, if new markets emerge for these services that could provide significant value to EV owners, vehicle specifications may follow.

3.4. Virtual Power Plants

Distributed energy technologies have the potential to provide services to local networks and energy markets, particularly if they can be aggregated and dispatched in unison. As a larger share of power generation moves behind the meter, and wholesale energy markets are increasingly supplied by intermittent renewables, “orchestrated DERs”—where a third-party aggregator has partial or full control over energy storage or “smart” appliances—may play a growing role in balancing instantaneous supply and demand, and providing “firm” capacity needed to maintain security. For networks, DER can be deployed to reduce or shift demand from the grid at peak times, as well as to manage voltage fluctuations, avoiding or deferring capital expenditure on infrastructure augmentation, and improving the quality of power supply. The specific capabilities of DERs to provide services along the supply chain are only beginning to be demonstrated, and the markets that would allow these value pools to be accessed are largely undeveloped. The way in which services are monetized, and value is shared among customers, aggregators, retailers, and networks will ultimately influence the economics and uptake of the associated technologies. Steiniger in this volume provides further discussion of “VPPs” and their application in global markets.
DERs may offer a range of services simultaneously, allowing value created in wholesale markets, networks, and within the home to be “stacked” to maximize customer benefit. Under such arrangements, Morgan Stanley (2016) estimates that home energy storage could become cost effective in the NEM by approximately 2018, with the value of network services comprising around half of the potential revenue pool; the remainder being from solar self-consumption, tariff arbitrage, and a relatively small wholesale component accessed via VPP aggregation.
Energy Networks Australia (ENA, 2016), an industry group representing network companies, states that the consumer value of DERs could be “unlocked” through the implementation of demand tariffs for all customers on an opt-out basis, and by giving customers with DERs the option to opt-in to providing network services, incentivized by dynamic and location-specific pricing, which would target regions where infrastructure is constrained. ENA estimates that if networks buy grid services from DER customers, this “orchestration” could replace the need for $1.4 billion in conventional network investment by 2026, and $16.2 billion by 2050. A number of distribution networks across the NEM are conducting small trials of distributed battery storage to demonstrate the technology’s capabilities. In the longer term, networks will be required to strictly ring-fence their nonregulated energy services from regulated “poles-and-wires” work. This will be important for facilitating consumer choice and innovation (AER, 2016b).
At an aggregated level, the output from a large number of distributed systems can become a VPP, able to dispatch power to the grid to be traded at wholesale pool prices. VPPs could provide hedges for retailers, to limit their exposure to volatile wholesale pricing, either through traditional financial instruments, such as “cap” contracts, or by reducing exposure to high prices by directing homes to use stored energy from batteries rather than grid supplies. Reposit Power has begun offering a “GridCredits” product, provided in partnership with selected renewable energy retailers, which links customer batteries to wholesale energy markets and enables the export of power when prices spike, for a premium payment of A$1.00 per kWh. Batteries may also be suitable to provide a range of ancillary services, which have, to date, been mostly provided by thermal generators with “spinning reserve,” such as fast-response frequency control.
In August 2016, AGL Energy announced that it was developing the world’s largest solar VPP demonstration plant, involving 1000 homes and businesses in South Australia equipped with solar PV and battery storage systems, linked through a cloud-connected control system (AGL, 2016). Once in place, the VPP will provide the equivalent of 5 MW of peaking capacity. In return for a heavily discounted home energy storage system—A$3499, including hardware, software, and installation—customers enter into an agreement that allows AGL to occasionally direct the batteries to discharge to the home or to the grid, at times of high demand or grid instability. For the majority of the time, the batteries will be used to help customers self-consume their stored solar power. Projects, like this VPP, will help to demonstrate how relationships between networks, retailers, consumers, and the market operator can create and access new value streams.
Within the NEM, the South Australian market has, by far, the highest concentration of intermittent wind and solar generation, and with the recent closure or mothballing of aging thermal plant, there are concerns about system stability and a potential shortfall of “firm” capacity available to meet peak demand (Nelson and Orton, 2016). As a result, average wholesale energy prices are higher and more volatile than in other jurisdictions. VPPs may represent a new way of managing energy peaks and grid stability, to support energy systems with high penetrations of intermittent renewable generation. If successful, this would provide an alternative to building new thermal generation, or increasing interconnection with other regions, which in a disruptive market environment, are investments that could become stranded before the end of their design lives. DER assets, with multiple potential revenue opportunities, could prove to be a more flexible and adaptable solution.
Alternative VPP models are also being trailed in the NEM, albeit at smaller scale. Ergon Energy is installing grid-connected battery and solar systems at 33 customers’ premises, but is retaining ownership and charging a fixed service fee in return for cooptimizing several value streams. Cloud-controlled demand response can also behave as a VPP by reducing energy demand during peak periods in an orchestrated way. During the summer of 2015–16, AGL Energy and United Energy undertook a trial involving the installation of “smart” air conditioners for 68 customers. During certain hot weather events, the devices were sent commands to slightly increase the set point temperature, with the aim of reducing peak demand by 25 kW.
The high level of activity in this space involving technology trials by both competitive and regulated industry participants would suggest that Australian utilities see a significant potential for VPPs to deliver customer and shareholder value in a distributed energy system. Recent findings from the AEMC (2016) suggest that behind-the-meter battery storage should be defined as “contestable”—and therefore delivered by entities appropriately ring-fenced from regulated participants. This should facilitate the development of competitive markets for services along the supply chain, and the emergence of new service providers—aggregators—to bundle these into compelling consumer products.

4. Growing customer heterogeneity: impacts of technology adoption on household demand

As households adopt behind-the-meter energy technologies to supply and manage their usage, the changes to their demand for supplies from the grid are profound. In this section, the “load profiles” of residential customers with and without DER technologies, including solar PV, energy storage, and EVs are discussed, considering both typical and peak demand days.9

4.1. Typical Demand Days

The averaged “load profile” of a sample of residential electricity customers in South Australia is presented in Fig. 14.3, for a representative mild summer day: December 13, 2015. As is typical for Australian households, daily demand peaks significantly in the early evening.
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Figure 14.3 Average SA residential load profile on a mild summer day.
Fig. 14.4 illustrates how the averaged load profile would change if a 3-kW solar PV system were installed. During daylight hours, the system generates more electricity than the household consumes, with the surplus exported to the grid. While the electricity consumed by the home remains the same, the solar system now supplies most of the home’s daytime energy needs, reducing energy demand from the grid by 48%. The volume, time, and shape of grid demand are significantly different from the previous example.
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Figure 14.4 Average residential load profile with a 3-kW solar PV system.
When a home energy storage system—with 6-kWh useable capacity10—is installed in conjunction with the solar system, dependence on the grid is further reduced. On a typical summer day, the household’s solar generation could supply 88% of its own energy needs, either consumed directly or stored for later use, with the home drawing from the grid for only a few hours in the early morning once the battery is discharged, as shown in Fig. 14.5. For the remainder of the day, the home neither needs to import or export power to the grid.
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Figure 14.5 (A) Average residential load profile with 3-kW solar PV and 6-kWh home energy storage systems; (B) Energy storage charge profile.
In this simple configuration, surplus solar generation is used to charge the battery, and power stored in the battery is subsequently discharged to the home in preference to drawing supply from the grid. Once the battery is fully charged, any additional solar generation is exported, and once the battery is fully discharged, supply from the grid resumes. In this scenario, the household self-consumes as much of their solar generation as possible. The battery does not discharge directly to the grid, and nor has its use been optimized for specific tariff structures or to provide grid support services –however reducing evening demand peaks would likely occur in all cases.

4.2. Peak Demand Days

The averaged load profile of the same sample of customers is presented in Fig. 14.6 for a hot summer day,11 when the South Australian system-wide demand peaks tend to occur, and when the grid can become strained. On this day, household electricity use was 98% higher than on the mild day, with higher demand throughout the day as a result of greater air-conditioning use. The evening demand peak was 70% higher than in Fig. 14.3.
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Figure 14.6 Average SA residential load profile on a hot summer day.
Considering the household that has installed a 3-kW solar PV system, on the hot summer day the home, both, uses more electricity and generates more solar power than on the mild day, as shown in Fig. 14.7. The use of solar reduces peak energy demand from the grid by 20% relative to the nonsolar household; however, during the middle of the day when solar production exceeds the household’s energy use, surplus energy must be exported to the grid. In fact, the household’s peak use of grid capacity is now for exporting solar generation, rather than importing power supply; the maximum capacity required by the home has only fallen by 1% compared to Fig. 14.6. In the Foreword, Conboy discusses that in some Australian neighborhoods, 50% of households have rooftop solar systems. As solar penetration continues to grow, solar exports, rather than energy imports may increasingly define the network capacity required in these areas.
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Figure 14.7 Average residential load profile with a 3-kW solar PV system on a hot summer day.
When home energy storage is added to solar in the same configuration as previously discussed, on the hot summer day the household is able to self-supply 84% of its energy requirements, and its peak demand is 52% lower, as shown in Fig. 14.8. Importantly, during the hours when the grid is most strained on peak demand days—typically 3–8 p.m. in South Australia—the home is largely self-sufficient, and draws no energy from the grid at all.
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Figure 14.8 (A) Average residential load profile with 3-kW solar PV and 6-kWh home energy storage systems on a hot summer day; (B) Energy storage charge profile.
The addition of EV charging can also significantly change the shape of a household’s energy-demand profile. If charged during the overnight off-peak period, the EV increases energy use on the hot summer day by 28%—or 56% on a typical day—and almost doubles the household’s peak grid demand, as illustrated in Fig. 14.9. However, this peak occurs well outside of the problematic system-wide peak demand period, when there is likely to be surplus available capacity.
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Figure 14.9 Average residential load profile with solar PV and off-peak EV charging on a hot summer day.12

4.3. Divergent Customer Requirements

As households and businesses adopt different energy technologies, the services they require from traditional utilities will diverge. A summary of the analysis in this section is provided in Table 14.2. As discussed in Section 3, current projections from a range of analysts suggest that by the early-to-mid 2020s, around 40% of NEM households may have installed behind-the-meter technologies and will, therefore, have nonstandard connection requirements. Customers with solar and storage may draw less energy supply from the grid, but it will continue to provide an important source of backup capacity in the event of poor weather or equipment failure. EV customers may seek product offers with low off-peak rates that correspond with their charging needs.

Table 14.2

Customer Requirements From the Grid Depend on Technology Choices

Typical demand day Peak demand day
Daily grid consumption (kWh) Share of home energy use from grid (%) Maximum demand from grid (kW) Maximum export (kW)
Grid only 11.0 100 1.5
Solar PV 5.7 52 1.2 1.5
Solar PV and Energy storage 1.3 12 0.7 0.9
EV 17.2 100 3.1
Solar PV and EV (overnight charging) 11.9 69 3.1 1.5

EV, Electric vehicle.

New service agreements may need to be developed to reflect changing customer expectations, such as the ability to both import and export energy and to be compensated for the value created for networks and wholesale markets. While the application of more cost-reflective demand tariff structures could provide additional flexibility, with costs faced by customers more representative of the services they actually use, new pricing models may also evolve. For example, customers with low grid use could be offered a new grid “subscription” product, such as a fixed fee for a defined level of grid capacity access. The importance of utility pricing structures for DERs in the Australian market is further described in chapters by Biggar & Dimasi, MacGill & Smith, and Mountain & Harris.

5. Evolution of consumer rights and protections

In this section, the application of consumer protections and access rights for electricity supplies from distributed and grid sources are discussed.

5.1. Consumer Protections in a Distributed Energy Marketplace

Since the 1990s the responsibility for supplying electricity has shifted from governments to privately owned entities, following the structural separation of monopoly state-owned electricity commissions, the introduction of retail market contestability, and privatization of energy retailing. Whereas governments have a responsibility to pursue social welfare objectives, regulatory consumer protection frameworks were introduced in each jurisdiction to ensure that access to this essential service was maintained as ownership transitioned to profit-maximizing commercial enterprises.
Between 2012 and 2015 the National Energy Consumer Framework (NECF) was adopted in all NEM states except Victoria, to harmonize obligations and retail requirements. To be licensed, electricity retailers must comply with NECF requirements or equivalent regulations, including maintaining supply for customers who are having difficulty paying their bills. Customers are guaranteed access to an offer of supply for electricity and gas, minimum contractual terms, access to ombudsman and dispute resolution services, and energy-specific marketing rules that ensure customers provide “explicit and informed consent” before entering into a contract. Retailers must provide flexible payment options, hardship programs, and energy efficiency advice, and strictly enforced rules govern how and when energy services can be disconnected. Additional support measures are targeted to vulnerable customer groups, such as government-funded energy rebates for low-income households, concession cardholders, and those who require electricity to power life-support equipment.
While these requirements typically apply to the “sale of energy,” they do not easily accommodate the proliferation of behind-the-meter technologies and evolving business models. The sale of energy devices, such as solar PV, energy storage, and energy-management systems, is not covered by energy consumer protection frameworks, rather the Australian Consumer Law (ACL) provides customers with the generic protections, which apply to the sale of all goods and services nationally.13 The Australian Energy Regulator (AER) and Victorian Government have also developed approaches to exempt some nontraditional energy sellers from NECF provisions that are not applicable or overly onerous relative to the type and level of supply. Examples include the on-selling of power to a small number of customers within a microgrid, such as apartment complexes, retirement villages, or shopping centers, and the sale of energy from solar PV via “power purchase agreements” (PPA) to customers that are connected to the national electricity grid. A hierarchy of consumer protections has therefore been established: supply from, and connection to, the national electricity grid are “primary,” whereas supplies from other sources and technologies are considered as “supplementary” and subject to lesser consumer protections.
As a result, the business model by which a technology is sold to a customer is a key determinant of the level of protections afforded for the supply, including eligibility for energy rebates and concessions, rather than the degree to which the customer depends on the source to meet their energy needs. Table 14.3 presents a summary of how this framework currently applies to different solar energy products currently available to customers in the NEM.

Table 14.3

Consumer Protections for the Use of Solar Energy

Product type Description Protection frameworka
Solar PV Consumer-owned system, purchased outright ACL
Solar PV financing plan Consumer-owned system, purchased with or without an upfront deposit, and with monthly repayment obligations ACL
Solar PPA Third party–owned system installed at customer premises. Under the PPA, the customer buys solar power from the system provider for an agreed period of time, for example, 10 years ACL and retail license exemptions framework
Solar leasing Third party–owned system installed at customer premises. The customer pays a monthly fee to lease the system for an agreed period of time, for example, 10 years ACL
GreenPower Purchase of remotely generated renewable energy from a licensed energy retailer via the energy grid ACL and NECF or equivalent jurisdictional framework

ACL, Australian Consumer Law; NECF, National Energy Consumer Framework; PPA, power purchase agreements.

a If products involve loans or product leasing, the National Consumer Credit Protection Act also applies.

As energy-supply arrangements for customers become more complex, and with grid-supplied energy likely to represent a shrinking share of total electricity use for many households, this framework may not be sustainable; recall from Section 4 that customers with solar PV and battery storage systems may source as little as 12% of their daily energy supply from the grid. Some customers may seek multiple trading relationships with retailers, for example, to charge an EV separately from household supply, raising questions of primacy, while others may wish to leave the grid altogether. Under the current pricing structures, customers that are exclusively supplied from the grid, including low-income households with limited access to DERs, would bear a disproportionate share of the costs of providing a consumer protections safety net for all customers. Opportunities for regulatory arbitrage also arise when suppliers are required to comply with different standards for the provision of products that are effectively in competition with one another. Distributed technologies are often marketed as favorable compared to the cost of grid supply, but consumers may not realize that a reduced obligation to provide consumer protections forms part of the cost differential.

5.2. Technology Connections and Access Rights

A key assumption underpinning the technology uptake projections presented in Section 3 is that customers will be allowed to install their preferred technologies and connect them to the local electricity network. As discussed above, the NEL and supporting rules guarantee customers access to an offer of grid-connected electricity supply under reasonable terms, but customers must apply for a new connection with their local distribution network service provider (DNSP) if they wish to install embedded generation, storage, or digital metering.14 The process and costs involved with grid connections depend on a number of factors, including the system size, whether it is to be used to export electricity to the grid and whether the DNSP is satisfied that its infrastructure can accommodate the connection of the device without augmentation or other electrical works (AEMC, 2016).
While efforts have been made to streamline these connection processes for retail customers—such as requiring DNSPs to provide a connection offer for all “basic” installations and to publish relevant information on their websites—application processes are not standardized and each DNSP has established different technical requirements, with jurisdictional safety regulations in some cases overlaying additional complexity. The level of technical information required for applications, associated costs, and processing times vary widely. In some distribution network areas, solar PV systems up to 10 kW are considered to be basic, while in others the threshold can be as low as 3 kW. Some DNSPs in the NEM regularly process simple applications within 24 h, while others take the maximum 10 business days allowed by the National Electricity Rules, and a couple of DNSPs have introduced fees of up to A$200 to process new connection applications.15 Upon application, some consumers are being informed that they cannot install solar systems of a certain size, or cannot install systems at all, in some cases because the network is already saturated. With continued technology uptake, this experience may become more common, particularly given that networks in the NEM are not required to publicly disclose the level of available capacity at the local feeder or transformer level. Long and complex application processes, additional costs, connection refusals, or other limitations on the use of DERs—such as system-size restrictions or output curtailment—may pose barriers to optimal technology installation.
Under current rules, connecting new energy-consuming devices, such as air-conditioning units or swimming pool pumps, does not typically require network approval, despite the potential for high coincident demand to strain infrastructure and necessitate additional augmentation. This may be changing, with some DNSPs proposing that home EV charging be placed on a “controlled load” circuit, where customers receive lower electricity rates, but are restricted as to the times they could charge their vehicle. However, this may not provide customers with the flexibility they desire. While the introduction of dynamic and cost-reflective pricing can incentivize customers to optimize their use of both demand- and supply-side technologies, a technology-neutral framework for grid connections should also be considered.
As consumer preferences change, regulatory frameworks may need to evolve to define a “right” for customers to install behind-the-meter technologies, particularly where primarily intended for self-consumption. The community may not consider connections processes to be equitable or reasonable if they result in some customers being granted permission to install devices that reduce their energy costs, while neighboring properties are denied the same opportunity. Likewise, it is unclear why safety and technical requirements for simple connections should vary significantly between jurisdictions, presenting an opportunity for standardization. With distributed technologies offering a partial or full substitute for grid supplies, policymakers could also consider whether it is appropriate to establish an independent arbiter to assess connection applications to ensure that information asymmetry is not being used to prevent legitimate deployment of new technology. New tools that provide transparent and granular information concerning the grid’s capacity to host DERs, similar to those being developed in California as described by Picker in this volume, could also be valuable in the NEM.

6. Conclusions

This chapter has explored how distributed technologies may shape the way that households produce and consume energy into the future. According to the forecasts discussed in Section 3, by the early-to-mid 2020s, around 40% of households in the NEM may install one or more DER technologies. The growing heterogeneity of grid requirements suggests that there is an urgent need for network product and pricing reform, so that customers are able to access and pay for only the services they need. However, the introduction of cost-reflective tariffs across the NEM has slowed, with few customers expected to opt-in to voluntary demand tariffs before 2020, which may exacerbate existing cross-subsidies between customers and prevent the efficient deployment of DER.
According to CALC (2016), low levels of industry trust and complex offerings may lead to customers engaging with energy markets in economically irrational and unpredictable ways:

The challenge Australia’s energy market now faces is that effective competition, innovation and market efficiency require informed customer participation, but evidence shows that consumers don’t trust, and are not engaged in the energy market. Moreover, people don’t make the decisions expected of them, almost always preferring the status quo and feeling that choices in the energy market are too confusing, too much ‘hassle’ or not genuine as the products are all the same.

Indeed, the primary reason that households have sought to install new energy technologies is to reduce energy bills by limiting their reliance upon conventional utilities. Households that have made substantial investments in energy technologies, such as rooftop solar, may quite understandably object to pricing reform that requires them to pay more, and such an outcome may further erode industry trust. It is also questionable whether the development of an even more complex suite of network pricing and access arrangements requiring sophisticated user engagement could be successful in this environment. Low levels of consumer trust in incumbent industry participants may also limit their ability to attract customers in emerging DER markets, as energy market value increasingly shifts “behind the meter.”
Importantly, reform of the regulatory frameworks governing consumer protections and grid access can build consumer trust and confidence in market participation. As the adoption of behind-the-meter technologies continues—particularly battery storage—the existing regulatory frameworks that treat DER as a supplementary supply source may need to be replaced by a technology-neutral approach that better reflects the experience of households that wish to source the majority of their energy use from DERs. An ability to install DERs may become as essential as access to grid supplies. Many households would already consider that it is their “right” to install technologies to manage or reduce energy costs, in much the same way that they can switch retailers in competitive markets to access better offers.
Policymakers should consider how appropriate consumer protections can be extended to all energy products, given that the level to which consumers consider a supply source to be “essential” is likely to be linked to the extent it is used to provide energy to their household. Consumer protections for all energy products should include three key elements: first, ensuring that customers receive appropriate information about energy products, including associated benefits and risks, to enable confident decision making; second, establishing frameworks for managing payment difficulties, hardship, and service disconnections to ensure customers maintain access to an essential service; and third, ensuring that government support is delivered in a technology-neutral manner, including energy concessions and access to ombudsman and dispute-resolution services.

References

AGL Energy (AGL), 2016. AGL launches world’s largest solar virtual power plant battery demonstration to benefit customers. Available from: http://www.agl.com.au/about-agl/media-centre/article-list/2016/august/agl-launches-world-largest-solar-virtual-power-plant

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Australian Energy Markets Commission (AEMC) Integration of Storage: Regulatory Implications, Draft Report. Sydney: AEMC Publication; 2016.

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1 For example, The Power of Choice review (AEMC, 2012), which included a series of proposed reforms to increase demand-side participation.

2 Between 2000 and 2010, the penetration of home air conditioning more than doubled, from 35% to 73%, which is close to market saturation (Productivity Commission, 2013).

3 AEC (2016) found that the payback period for a 5-kW household solar PV system was between 5 and 10 years in Adelaide, Brisbane, Darwin, Sydney, and Perth. Mountain and Harris in this volume discuss the payback for solar PV investments in Victoria.

4 The Jacobs forecasts include PV installations in NEM states, excluding Western Australia and the Northern Territory.

5 For example, the Tesla Powerwall 2 was launched in October 2016 and at 14 kWh, it is double the size of the Powerwall 1, offered for the same price.

6 Typically when the payback period is less than 7 years.

7 The solar bonus scheme provided a gross feed-in tariff (FiT) of A$0.60 per kWh, enabling a payback period of 2.1 years and a net profit per household of up to A$10,000.

8 For example, on September 28, 2016 there was a state-wide “System Black” outage in South Australia that lasted for several hours and which has been the subject of extensive media coverage.

9 Analysis in Section 4 is based on the averaged load profile of a sample of South Australian residential customers with digital meters, and normalized PV generation based on a sample of monitored systems in South Australia.

10 Equivalent to a 7–8 kWh system with a depth of discharge around 80%.

11 December 16, 2015.

12 EV charging load is based on average driving for a vehicle that travels 15,000 km per annum and slow charged from a 15-A plug. Off-peak charging is consistent with the findings of Cook et al. (2014) that EV owners in San Diego responded well to market pricing signals, with the vast majority charging overnight and in the early morning.

13 The Australian Consumer Law (ACL) provides all Australian consumers with protections relating to product safety, sales practices, consumer guarantees, unfair contract terms, and unfair business practices. Energy-specific consumer protections apply in addition to those provided under the ACL.

14 As per Chapter 5A of the National Electricity Rules.

15 For example, AusNet Services in Victoria, and Ausgrid in New South Wales have introduced application fees, although most distribution network service providers (DNSPs) do not charge for this service.

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