Analysis of the NSW FiT
Analysis of NSW FiT changes (2009)
SunWiz distributed this analysis to clients following the announcement of a gross Feed-in Tariff for NSW. Some of the questions posed have been answered since the implementation of the solar bonus scheme legislation and regulation. Further analysis has shown that if a 10% reduction in PV system installed price occurs in each year, the economics of solar power shall continue to be excellent, principally because of the large (63% over 3 years) electricity tariff increases proposed by IPART.
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Since the release of SunWiz’s “Successful Solar Strategies” report, NSW announced a gross Feed-in Tariff. An email notification from SunWiz on 13/11/09 provided distilled the key points of the draft legislation. The passage of legislation makes invalidates some graphs and analysis within the report. This document and the accompanying spreadsheet provides an update of analysis relevant to the NSW gross Feed-in Tariff. It is supplemented by information from the NSW government department responsible for implementing the associated regulation (Provided during the PV directorate by Ellen Kelly, Project Officer, Sustainable Energy from Industry & Investment NSW, Minerals and Energy Division).
The NSW gross Feed-in Tariff was passed by parliament on the 27th November 2009. It is due to commence on the 1/1/09, though certain transitional arrangements apply. To summarise the legislation:
Eligible: | Small electricity consumers ( |
Existing Systems: | receive gross FiT |
Duration: | until 31/12/2016 (not a sliding window) |
Transition Day: | 1/7/09 |
Distribution boards: | Receive net FiT until transition day |
Cash or Credit: | Mandated credit on accounts, credit accounts can be paid out in cash at the discretion of the retailer |
Concerns
At this stage there is no clear picture of what will happen to existing or new systems connected to distribution boards.
Until transition day, systems will receive net 60c/kWh FiT.
As the legislation stands, after this date systems connected to distribution boards will not receive the gross FiT, without some solution amenable to the local electricity distributor.
Changing this in legislation this would require political amendment, considered unlikely in the foreseeable future due to the recent change in Premier.
An option exists within the legislation to extend the transitional arrangements. This could be done through regulation, avoiding the need to involve parliament. This may mean systems that could otherwise not receive gross FiT may receive net FiT.
Is 10 kW based on panel or inverter capacity?
The project officer from Sustainable Energy from Industry & Investment was unaware of the difference between panel and inverter capacity. The PV directorate campaigned for recognition of inverter capacity. This issue has not yet been resolved, but the FAQ states: “The capacity limit applies to the entire generator, not just individual components of the generator. The entire generator must fall within the 10 kilowatt capacity limit”, suggesting that the panels must be less than 10 kW too.
Observations and Implications
Small systems prevail
The payback from a 1.5 kW system now clearly outshines that of larger systems. Economies of scale can overcome a 4xREC multiplier to make payback quicker for larger systems, or a $20 REC price with 5x multiplier. However, for the meanwhile 1.5 kW is both highly affordable and the best investment.
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The REC price is prevented from going too high by the availability of free solar PV or Solar Hot Water Systems. If the REC price gets near $50, then free solar PV and free solar hot water systems compete for a share of the REC market. As the REC market isn’t that large, it wouldn’t be long before supply exceeded demand and the REC price would dive again. Large-scale renewable energy technologies are also competing to create RECs, with over 800 MW of wind power ready to be deployed in the next 1-2 years4, and up to 6000 MW over the next 10 years5
The figure below conceptually illustrates the “piece of the pie” that the solar power industry has to compete for amongst other suppliers. Solar Hot Water systems had already created 5.4m RECs in 2009 by September, capturing 55% of the market this year. Other renewable energy technologies have created 5.4m in recent years, but modelling performed by Carbon Market Economics – plus other renewable energy technologies such as bagasse, landfill gas, etc. A high REC price hastens the development of these power stations, which can flood the market with RECs and thus lower the price dramatically. Therefore, solar power businesses cannot expect a high REC price anytime in future.
6 suggests that wind farms alone may create another 2m RECs over the next 1-2 years. The 10,000 schools7
within the National Solar Schools Program could generate about 1m RECs, and the 63,000 system backlog of Solar Homes and Communities Program could generate 1.3m RECs. How many RECs are left for Solar Credit PV systems?
4 Carbon Market Economics, “Renewable Generation Projects 2009 – 2028, Revised Final Report”, January 209
5 “Australian renewables law to spark wave of wind projects”, BusinessGreen.com, 21/8/09
6 Carbon Market Economics, “Renewable Generation Projects 2009 – 2028, Revised Final Report”, January 209
7 http://www.abs.gov.au/AUSSTATS/abs@.nsf/MF/4221.0
In summary, here are the threats that face solar power businesses:
• There is a huge oversupply of RECs available on the market – perhaps enough to cover 2010.
• Subsidised sectors such as Solar Hot Water, Solar Schools, and the Solar Homes and Communities Plan continue to supply RECs almost without regard to their price
• The REC price is prevented from getting much above $50 by the resulting “free” solar systems
• Other large-scale renewable energy technologies could flood the market with RECs in coming years
• The Solar Multiplier means very few systems can be installed before the REC requirements are met.
The following graph puts this all together into an outlook for RECs supply and demand. While it is difficult to estimate the exact amount of RECs that will come from each sector in future years, combining analysis of a number of scenarios with some sensible assumptions allows the exploration of likely outcomes. Consider that:
• There may be 18 million RECs available by the end of 2009, 8 million more than needed
• This would mean 2010’s requirement of 12.5 + 1.9 = 14.4 million RECs (RET + GreenPower) would only require creation of 6.4 million RECs.
• Existing wind farms and other renewable energy power stations create 5.6 million RECs per year.
• Solar Schools and Solar Credits are likely to produce 0.6 million RECs in 2010
• This leaves at least 0.2 million RECs required in 2010 between Solar PV and Solar Hot Water
The major unknown for 2010 and 2011 is the performance of Solar Hot Water. Considering that it has already created 5.4 million RECs this year, it seems likely that it will easily create 0.2 million RECs in 2010. The graph below shows scenarios of a 10% contraction of SHW to end of 2009, and a 75% and 50% contraction (conservative and highly conservative estimates) for 2010, and the same levels of SHW deployment in 2011.
The graph clearly demonstrates that even with significant contraction in SHW, there are enough banked RECs to cover most of 2011’s requirements. Solar power RECs are necessary to meet the target only if HW retreats to its 2008 installation level, and there is no other renewable energy power station development. However, the major players have 6000 MW of wind development representing billions of dollars of investment, and the deployment of 800 MW of wind can create 2 million RECs.
In summary, there is not much need for solar power systems to create RECs until 2012, and the phantom RECs they create exacerbate the problem. Thus the future of the solar power industry might be quite constrained.
Although we’ve discussed the “piece of the pie” that remains for the solar power industry, remember that if a wind farm is financially viable with $35 RECs, or there is high demand for solar hot water systems even with $30 RECs, then it is likely that the REC price will remain near that level. The technology that can survive with the lowest REC price is likely to gain greatest market share, and if the solar power industry has difficulty selling systems when RECs are less than $40, then there could be significant downsizing within the industry. So too, if one company within the solar power industry discovered a way to sell a large volume of solar power even with a REC price of $25, then the rest of the (solar PV and renewable energy) industry may suffer.
REC Price Volatility
The REC price is quite volatile, which can have a huge impact upon solar power businesses. Because RECs take three weeks to register and clear, and because solar PV businesses are now highly exposed to and dependent upon REC prices, any significant movement in REC price can hurt both in the short- and long-term. Consider that the past 18 months has seen $7-10 price falls happen over the course of weeks. A $10 drop in REC price can cost solar power businesses $1550 per 1.5 kW system. If a business has installed 20 systems in the last two weeks – that’s $31,000 they must wear… and then try to carry on business with a higher sales price.
There are a number of reasons the REC price is volatile. Like any market, the REC market is subject to player’s perceptions of what the price will do in the future. This can easily be influenced by government announcements, or the construction of a new renewable energy power station. The REC market gamed in favour of the buyers, further complicating matters. In simple terms:
• The buyers only have to surrender their RECs once per year. They have all year to strategically make REC purchases. If they have RECs in the bank, they can wait indefinitely before their next purchase.
• There are a huge number of sellers whose cashflow and livelihoods depends upon selling their RECs so that they can continue to install solar power, solar hot water, and heat pumps. These pressures mean that they need to sell, often at below-market rates. Also due to this reason, any sudden downwards shift in RECs price can unleash plenty more RECs from desperate installers wanting to cut their losses. For reasons explained above, the buyers can simply wait until the price bottoms out before taking advantage of the situation.
Summary
To summarise the threats to the industry, and to the success and sustainability of solar power businesses:
• 2010’s RET has effectively already been met, keeping REC prices low for at least the year ahead.
• SHW installations also act as a significant supply of RECs
• A flood of Solar Credits could supply the entire REC requirements for the coming years
• Other subsidised markets including schools and SHCP backlog will also contribute to supply RECs, independent of REC price
• Other large-scale renewable energy projects that have been waiting for an expanded RET will be deployed, leading to bulk increase in supply of RECs.
• REC market forces favour the buyers in the market
• Although market forces also act to stabilise the REC price, the REC multiplier creates a high degree of sensitivity to REC price fluctuations for the solar power industry.
Granted, it’s unlikely that all of the above comes true to its fullest extent – that would be a nightmare scenario. It’s more likely that a low REC price would dampen development of certain renewable energy technologies and of particular projects. However, some renewable energy technologies are supported by direct government rebates, grants and commitments – these projects may be less impacted by a low RECs price, and thus continue to create RECs and thereby keep the REC price low? Furthermore, solar power businesses are five times as exposed to REC price fluctuations than other technologies.
Many market analysts have suggested that a low REC price is likely for the foreseeable future. Unfortunately, a solar power industry that was solely reliant upon RECs would probably generate far fewer RECs if certificate prices dropped to $10 – the industry would grind to a near-complete halt.
Policy Solutions
As the present legislation stands, the 20% renewable energy target will not truly be achieved. This is because the phantom credits created by the solar multiplier mean that far less electricity will be produced than certificates are created. In order to achieve policy goals, the phantom credits issue must be addressed. This market correction could simply take the form of increasing the Renewable Energy Target each year by the amount of phantom credits that exist from the previous year.
Other market distortions should also be addressed if a government goal of “lowest cost deployment” of renewable energy is to be achieved. The state and federal subsidies for solar water heaters mean that subsidised RECs are being created, thus harming the chance of deployment of wind farms and solar power alike. This could be addressed by ensuring that renewable energy technologies received a subsidy or RECs, but not both.
However, these two measures will not impact upon the REC price until 2011, by which the excess of banked RECs might have been cleared. Consequently, deployment of wind, solar power, and solar hot water will be set back by two years or more. In the short term, increasing demand for RECs seems to be the best solution. This could be achieved by bringing forward the renewable energy target – achieving 20% renewable energy by 2015. GreenPower also creates demand for RECs, and a government mandate of 10% GreenPower for residential customers (with provisions for opt-out) could also restimulate the REC market by clearing banked RECs. Alternative support for solar power should be considered – one government revenue-neutral measure such as a nation-wide gross Feed-in Tariff would mean far greater certainty for solar power and reward high-quality, high-performing installations, without creating a boom-and-bust cycle that causes harm and cripples investment.
