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Beyond Zero Emissions recognises the importance and efficacy of Feed in Tariffs and
distributed renewable generation in reducing emissions and moving towards a zero emission
future. We welcome the opportunity to respond to the Victorian Competition and Efficiency
Commission’s Inquiry into Feed-in Tariffs & Barriers to Distributed Generation.
The Issues Paper identifies two main elements to be addressed: “assessing the design, efficiency,
effectiveness and future of FiT schemes” and “identifying barriers to connecting distributed
renewable and low emission technologies into the distribution system”. We would agree the
importance of these objectives, and the (arguably even more important) subsequent actions:
implementation of an effective feed in tariff and removal of barriers to distributed generation.
Unfortunately, we believe the following discussion within the Issues Paper misses some key
points with respect to distributed generation, and misrepresents the costs of distributed solar
photovoltaics (or other distributed generation ) and feed in tariffs. In this submission we firstly
identify some of the shortfalls, misrepresentations and missed concepts in the Issues Paper, and
then also answer the ‘Information Requests’.
The key issues include:
- Incorrect use of Productivity Commission analysis
- Analysis methodology is not suitable for distributed generation (does not value distributed generation at the retail price with which it competes)
- Use of outdated Productivity Commission analysis (Incorporates outdated cost data)
- Failure to acknowledge the ‘Merit Order Effect’, a key Feed in Tariff cost offset
- Failure to acknowledge the inherent market failure with the carbon price mechanism
- Failure to accept efficacy of Feed in Tariffs and distributed renewable generation in reducing emissions and moving towards a zero emission future.
- Consideration of fossil gas as a feasible distributed technology
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