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Embark - submission to medium-scale solar discussion paper

Tony Wood
Medium-Scale Solar Working Group
Energy Sector Development Division
Department of Primary Industries
GPO Box 4440
Melbourne VIC 3001

9.11.10

Dear Tony,

Embark welcomes the opportunity to respond to the Victorian Department of Primary Industries' Discussion Paper on Medium Scale Solar.

Embark is a not-for-profit body established to facilitate the development of a vibrant community renewable energy sector in Australia.

Inspired by the success of Hepburn Wind, Australia's first community owned wind farm, many other communities are keen to participate in, and benefit from, the transition to zero carbon energy sources.

Community ownership of renewable energy facilities has been integral to the broad acceptance of clean energy technologies in other jurisdictions. A host of counties, including the UK, USA, Germany, Canada and Denmark have policy frameworks that support community ownership of renewable energy generation infrastructure.

Embark is committed to troubleshooting market failures and policy gaps so that communities may participate in the roll-out of renewable energy in their regions.

The Victorian Government's White Paper proposes to:

• pilot the most promising models of engagement and benefits-sharing with communities and regions with high renewable development potential
• develop support for communities that wish to drive, manage or own the roll out of renewable energy in their region.

The Paper establishes a goal of:

"enabl[ing] small towns to take charge of their futures by building partnerships to increase community participation and investment."

Embark's aims are very much aligned with these goals.

Embark is technology agnostic. We will support communities to harness the resources appropriate to their location wherever it is viable to do so. We are very excited by the opportunities that might be created for all Victorians by the works originating in the Medium-Scale Solar Working Group.

The Role for Medium-Scale Solar

Engagement

Solar power is currently significantly more expensive than the least cost renewable energy alternative (wind power) and is likely to remain so for much of this coming decade. As such, any significant public investment in solar power needs to satisfy more than just the driver of carbon abatement.

Domestic solar PV has been an important but expensive exercise in renewable energy awareness raising. The Solar Homes and Communities Plan cost more than $1 billion (mostly public money) to install 120 MW of solar over 100,000 rooftops. To judge this by the level of carbon abatement alone is to miss the massive value of the public engagement. Every new rooftop installation created a new household of advocates for renewable energy.

At a time when some are peddling unfounded fears that households will suffer from massively higher energy bills, we propose that one of the key policy drivers for solar, in the near term, must be to provide opportunities for individuals, and their communities, to engage positively with renewable energy.

Medium-scale can deliver all the engagement benefits sought from domestic scale programs, but projects can be developed with economics much closer to those of utilityscale projects.

Shared Ownership Models

We propose that shared-ownership schemes of renewable energy projects could drive significant growth in the medium-scale solar space. A business installing 100 kW on a factory roof will result in the same abatement as a community that installs 100 kW in the same location, however the latter has the opportunity to engage a hundred (or more) community members on an ongoing basis.

Without shared-ownership, medium-scale solar installations on commercial rooftops are likely to quickly lose visibility - with little engagement, they satisfy few policy drivers.

We propose two Community Solar Parks 'case studies' concepts:

Case 1: Regional Solar Park

A regional community group decides to build a 1 MW community solar park. With the help of a Climate Communities grant, they establish an energy co-operative and, with local government support, secure long-term access to public land previously used for landfill.

The co-operative engages a solar developer to design the project and secure grid access. The project will be sold in 1,000,000 shares, each representing 1 Watt of capacity. In order to ensure that the community engagement goals are met, no member may own more than 10,000 shares (10kW), and at least half the shares will be reserved for those living within 50 km of the solar park. In order to enable a broad cross-section of the community to own part of the farm, holdings of as few as 100 shares (representing 100 W) would be permitted.

Case 2: Urban Rooftop

A national supermarket chain creates a prototype urban solar park in conjunction with a climate action group. The supermarket provides a 25 year lease on the rooftop of a suburban supermarket to enable installation of a 200 kW array.

A community energy co-operative is established, with shares marketed to members of the climate action group and customers of the supermarket. A digital sign inside the supermarket shows production statistics and advertises the availability of any opportunities to buy-in to the solar park.

Quarterly payments for energy produced are made to shareholders, providing the supermarket with a valuable opportunity to connect with engaged customers, an adjunct to their existing loyalty scheme. The supermarket provides valuable services to the co-operative (roof space, information and administrative support) in exchange for the opportunity to develop a new level of engagement with their customers. Note that the supermarket chain does not need to access their own (expensive) capital in order to cover their roof with solar panels.

Social Equity of Feed-in-Tariffs

The Premium Feed-in Tariff (PFiT) provides a mechanism for households with PV solar systems to sell power excess to their requirements into the electricity network. The price paid is at a significant premium to energy prices (more than 10 times current average wholesale market prices), with the costs borne by electricity consumers.

While the costs of the scheme are significantly offset by policy goals (stimulating the solar sector and engaging the community in clean energy) the scheme as it currently stands has equity shortcomings. Recipients of the PFiT are necessarily those who own a suitable roof and have sufficient financial resources to purchase a viable system. The following groups are generally excluded from benefiting:

• those living in apartments
• renters
• those who are not in a position to buy an entire system, but may participate at a lower buy-in level
• homeowners with roofs that are inappropriate for solar (poor orientation, shaded, etc)

Many are becoming aware that a significant number of economically disadvantaged Victorians are unable to take advantage of the PFiT and are, in effect, subsidising financial payments to less disadvantaged Victorians. While the design of the PFiT seeks to limit energy consumer's exposure to the costs of the PFiT, it should be a goal of an equitable system to increase eligibility wherever possible.

We propose that Community Solar Parks provide a vehicle to address some of the unintended social-equity issues resulting from the current PFiT. An appropriate feed-in tariff that enabled communities to build viable solar parks would make direct engagement with solar energy accessible to a much broader segment of Victorians than current programs allow. Further Contact We greatly appreciate the opportunity to comment on the discussion paper. Please feel free to contact us should you have any questions regarding this submission.

Yours sincerely,

Simon Holmes à Court,
Chairman
Embark

Section 4: Definition of Medium-Scale Solar

QU1: It is appropriate to define medium-scale solar as falling between 100kW and 5MW?

The Premium Feed-in Tariff (PFiT) is already creating healthy demand in the sub 5 kW range. Utility scale initiatives are being addressed through the VLSSFIT and other recent initiatives.

The Victorian Standard Feed-in Tariff (SFiT) is currently failing to deliver significant numbers of solar installations in the 5 - 100 kW range. This failure is primarily due to the fact that 5 kW - 100 kW solar parks are currently uneconomic in Victoria.

One of the significant factors is that the SFiT pays the same rate for generation as the customer is paying for power delivery. As larger customers negotiate better tariffs for their energy usage, the tariff they receive for generation declines accordingly.

There are many rooftops in Victoria that can support 5 kW - 100 kW solar arrays, however unless there is new policy in the sub 100 kW space, we'll continue to see limited take up in a space that could deliver significant quantities of generation.

We suggest that rather than creating a distinct policy for 5 kW - 100 kW capacity, the definition of medium-scale be extended from 5 kW - 5 MW. This would ensure, for example, that a community program as proposed in Case 1 above would be able to achieve its required economy of scale.

QU2: Do you agree with such a definition and if not, why not?

We have argued above for a definition of 5 kW - 5 MW, slightly broader than suggested by the discussion paper.

However it should be noted that the economics of a 50 kW array on a supermarket will be quite different from a 5 MW solar park. Any tariff that encourages 50 kW arrays would be likely to make 5 MW farms provide unnecessary/unfair windfall returns.

Conversely, if a tariff that enables 5 MW farms to provide adequate returns to investors is applied to smaller projects, it is likely that farms under, say, 1 MW will be uneconomic.

As such, to avoid windfalls and/or crowding out, it may be appropriate to provide tariffs in capacity bands as touched upon in section 4.3.

Section 5: Identification of Potential Barriers to Uptake of Medium-Scale Solar

QU3: What are the immediate financial short-term barriers to investing in the medium-scale solar sector and how do these differ from investment in small or large-scale solar?

Small scale solar is driven by the financial incentives provided by the PFiT. Adequate financial incentives for large-scale will be driven by the VLSSFiT and related initiatives.

Without adequate price support, the 100 kW - 5 MW space will be even less active than the almost dormant 5 kW - 100 kW space. However, good policy design of a FiT requires more than just price support; investors must be presented with 'TLC' - see below.

QU4: What are longer-term financial barriers to investing in the medium-scale solar sector and how do these differ from investment in small or large-scale solar?

Policy designers are recommended to the Deutsche Bank (DB) paper 'Paying for Renewable Energy: TLC at the Right Price - Achieving Scale through Efficient Policy Design' (available at http://www.dbcca.com/dbcca/EN/investmentresearch investment_research_2144.jsp) which outlines a framework for efficient and effective FiT design. In order to stimulate sustained investment in renewable energy, DB suggests that policy frameworks must deliver to investors:

• transparency - how easy is it to navigate through the policy structure and understand and execute?
• longevity - does the policy match the investment horizon and create a stable environment for public policy support?
• certainty - does the policy deliver measurable revenues to support a reasonable rate of return?

Policy with adequate price support and strong 'TLC' will stimulate development of medium-scale and large-scale projects. Investment analysis for domestic/small-scale solar is likely to be less rigorous, however this market segment has been shown to be highly sensitive to price variation.

Once investors have confidence that the framework will deliver TLC, the issue becomes one of investment returns. Perhaps the most striking difference between community investors and commercial investors is the relative hurdle rates of return.

Many businesses will have a hurdle rate of at least 15% - 20% - few firms will place $1 million on their roof with returns substantially below that. This is in stark contrast to community investors who are content to invest with returns closer to 10%.

The community's far lower cost of capital lowers the financial barriers for any applicable medium-scale renewable energy project - regardless of the technology.

QU5: Have all the relevant barriers to uptake of medium-scale solar been identified in this Discussion Paper, and if not, what are they?

Metering/Offtake Arrangements

Building on the discussion in '5.3.9 Metering requirements', current metering arrangements are a significant barrier for shared-ownership solar parks.

Currently, smaller projects connect 'behind the meter' of a demand customer and will be paid a tariff equal to the tariff paid for importing electricity.

In a shared-ownership solar park, the generator owner (e.g. solar co-op) will generally be a different entity from the customer/consumer. This presents several problems:

• Commercial arrangements between the customer and the retailer (including tariffs) are liable to change at any time. Customers that have the real estate to host a shared-ownership generator are unlikely to wish to vary their electricity supply arrangements. Similarly, generators will be reluctant to invest significant capital without a formal, standardised off-take arrangement.
• Regulations prohibit sales of electricity by anyone other than a retailer, presenting difficulties of operating two entities (generator and customer) behind the same meter.
• It is quite likely that a sizable solar park will generate more energy than the customer uses, putting the customer account into credit. Currently there is no formal system requiring retailers to make payments to the customer for periods where the account is in credit.

Shared-ownership generators will typically lease land or roof space to build farms well under the 5 MW NEM threshold for market participation. Given the above, there is a need for simple, standardised off-take and metering arrangements for sub 5 MW generators (regardless of technology).

It is difficult to see what value retailers provide in this scenario. Network distributors are well set up to handle connection and metering functions, however we question whether they have capacity and motivation to adequately support small generators.

Separation of the generation asset from the customer demand would enable a wide array of new business/service models.

Consideration should be given to the creation of a body, perhaps under the Green Door initiative to provide a 'one-stop shop' for connection, metering and FiT payments for all generation-focused projects outside the domestic/consumer arena.

QU6: Can these barriers be differentiated by market segment (for example, are business entities likely to encounter different barriers to government organisations or community groups?)

It is important to understand that different segments have different investment objectives. We believe that there are three different investor types:

• utility generators - these generators will apply a consistent investment framework across a range of generation technologies to identify opportunities that meet their energy requirements and renewable energy liabilities at least cost.
• commercial customers - some commercial entities will build solar parks to offset part of their own energy demand in order to meet marketing objectives and/or the ideologies of their owners. It is expected that most companies will examine the opportunity costs of medium-scale solar investment, and only invest where projects meet their IRR hurdle rate of return. As such, few medium-scale solar projects will be built if tariffs enable returns implying an IRR lower than, say, 15%.
• shared-owner generators - our experience with community energy projects indicates that individuals are prepared to invest together with their community at rates of return in the 7% - 10% range. Such projects require significant effort and expense to bring stakeholders together, but in the process they generate broad social licence for renewables and generate significant social benefits.

Ontario and several other North American jurisdictions have implemented a 'community bonus' feed-in tariff. In Ontario's case, where a project is deemed to be community owned, the project can access a 1c/kWh bonus. This bonus offsets the costs required for administration of a shared-ownership scheme and contributes to bridging any gap related to dis-economies of scale encountered by smaller projects. We strongly endorse this concept as a clear and supportive program for community owned projects.

QU7: What is the most significant barrier affecting your particular market segment?

Solar energy is currently significantly more expensive that the least-cost renewable alternative. Neither the RET or the SFiT provide sufficient support to make solar viable. There is significant community interest in solar, however it is reasonable to assume that this will not translate into capital for medium-scale solar generation while it remains uneconomic.

A framework for sub-5 MW shared-ownership generating facilities, including connection, metering and FiT payments would unlock significant community capital and provide a platform widespread engagement with renewable energy for a broad cross-section of the Victorian community.

Section 6.1: Broader Policy Aims for Medium-Scale Solar

QU8: What level of uptake would be required for medium-scale solar to make a significant contribution to meeting renewable energy and greenhouse gas reduction targets and how feasible is such a level of uptake?

While the primary goals of medium-scale will generally not be abatement or generation targets, it is foreseeable that a large number of Victorians might participate in a sharedownership solar park program.

Household solar is expected to approach 40 MW in aggregate by 2014. It is conceivable that with effective policy design a similar scale of generation could be deployed using the community solar-farm model in a similar time frame, at a significantly lower cost.

Embark is already aware of at least 12 communities that are exploring community solar farms and we are confident that hundreds more will follow as soon as the model is viable and well known.

It is understood that more than 200,000 households in Denmark are members of community energy projects. Denmark's population is on the same order as Victoria. A program focused on encouraging efficient and widespread community engagement with PV solar could easily deliver 100 MW over the course of the decade.

QU9: What contribution is medium-scale solar likely to make to the security and reliability of supply?

Medium-scale generators have the opportunity to be placed near demand centres in the distribution network, offsetting peak demand.

Shared-ownership generators will generally be situated near the stakeholders who own the facility and generation will be proportional to the number of stakeholders, and therefore demand.

Medium-scale generators will have access to economies of scale that allow it to play an important and efficient role in improving security and reliability of supply.

QU10: How does this contribution differ from the contribution that is likely to be made by small or largescale solar?

In the absence of location-variable tariffs, large-scale solar developers will tend to place solar assets in areas of maximum solar resource. In Victoria, this is likely to result in a cluster of generators to the north-west of the state, away from population (and energy demand centres). Significant levels of generation will be subject to network constraints.

Small scale solar shares the ability of medium-scale to offset demand in the distribution network, however it is unable to access the economies of scale afforded to mediumscale projects.

QU11: What are the opportunities for establishing local manufacture and production of solar technologies? To what extent are these regionalised?

Australia fails to find a place in a recently published list of the 500 largest solar parks globally. Clearly we are starting from behind, and it should come as no surprise that industry (including the distribution networks) does not currently have the capability to install large-scale solar parks.

It is too early to speculate on which parts of the solar park supply chain Australia will be able to compete for, however our workforce should be able to provide project management, engineering, and construction labour. There will also be opportunities for Australian firms to create innovative frames, trackers and rapid deployment systems.

Medium-scale solar presents a unique opportunity to develop a broad base of Australian expertise in these areas. It has been said that we shouldn't try to build the world's biggest solar parks before we build the smallest first.

Currently only foreign firms have the expertise to build large-scale solar parks. The development of hundreds of medium-scale solar parks will provide local firms (throughout the state) with a fighting chance of developing our large-scale farms in years to come.

QU12: What are the benefits of increased community engagement in this space over and above financial benefits? To what extent can these be quantified or do they remain largely intangible?

Community energy projects enabled by medium-scale solar have the potential to provide significant social benefits to their host communities.

The Hepburn Wind project provides several good examples.

• Skills - the project employs three local residents and has developed significant skills in a greater number of regional Victorians (board members, active members and service providers).
• Social Cohesion - the project brings a shared purpose to many in the community. Every time the co-operative meets, 100 - 200 members gather, providing a valuable and positive social opportunity for many. With staff employed focusing on member engagement, it is reasonable to expect this level of engagement to be sustained for many years.
• Community Funding - the project will contribute more than $1,000,000 to sustainability initiatives over the first 25 years of the project.

Over and above the local benefits, these projects bring other non-financial benefits as they:

• create 'referenceable' examples of regional communities benefiting from, and supporting the low-carbon transition
• create large number of stakeholders supportive of low carbon policy
• create significant 'learnings-by-doing'

Lastly, medium-scale projects prepare local industries for future large-scale projects by providing opportunities to:

• develop skills and organisational capability
• develop and refine deployment technologies

QU13: What support models for medium-scale solar are likely to provide the greatest opportunities for community engagement?

Shared-ownership models for medium-scale can create high levels of enduring community engagement at a lower cost per household than small-scale projects.

Roof mounted medium-scale solar systems have the potential to quickly fade from consciousness. Shared-ownership models start with a shared purpose and by virtue of their structure, they are naturally positioned to keep the engagement alive.

The success and proliferation of shared-ownership projects in this space will depend on strong and stable tariffs. The community-focused tariffs in other jurisdictions are noteworthy:

– Maine, USA has finalised rules for its Community-based Renewable Energy Pilot Program which includes a FiT for various technologies. The scheme is limited to 50 MW total, with individual projects capped to 10 MW

– Ontario, Canada, has implemented a 1c/kWh bonus ('adder') for communityowned wind projects. Interestingly, a higher bonus is paid if the project is aboriginal-owned. The adder is paid if 50% - 100% of the project is owned by Ontario residents.

– Nova Scotia, Canada, has implemented a 100 MW target (uncapped) for community-owned distributed energy projects. (Source: Deutsche Bank)

Beyond tariffs, project will also require assistance with start-up knowledge and introductions to a network of appropriate service providers. Embark has been established to address these barriers.

QU14: Are there any further broad policy aims which should be considered?

Policy development should consider social equity issues - in developing a broad set of frameworks enabling solar at all scales, the opportunity of equitable access for all Victorians.

Policy frameworks need to be accessible and understandable so that communities can access the benefits.

Consideration should be given to extend these frameworks to other renewable energy technologies - i.e. most of our arguments in this paper can be applied to bioenergy, mini-hydro or community wind facilities.

Capital efficiency should be considered. By encouraging the deployment of panels in suitable locations at efficient scale, the community (who ultimately pays for all support, whether it is through grants, certificates or FiTs) can be assured of receiving value for money.

Section 6.2: Specific Drivers for Investing in Medium-Scale Solar

QU15: What are the immediate short-term financial drivers for investing in the medium-scale solar sector?

The Deutsche Bank TLC framework is useful for understanding the drivers for investment in renewable energy. Investors will only approach the space when frameworks provide transparency, longevity and certainty. See Q4 for detail.

QU16: What are longer-term financial drivers for investing in the medium-scale solar sector?

In addition to the above, for consumers concerned by cost of living increases, a stake in a renewable energy project can provide a natural hedge against ever-increasing energy prices, if production offsets consumption (or the price of both are market-linked).

QU17: What other drivers exist for investment in medium-scale solar and to what extent are these differentiated by different market segments (for example business, government and community groups)?

Engagement

Medium-scale solar is particularly relevant at a time when building community consensus is absolutely vital to a range of climate change related policy areas, especially those related to renewable energy.

Medium-scale solar parks utilising a shared-ownership model have the potential to positively engage a large number of stakeholders, and keep them engaged for many years.

Development of Victorian Expertise

Medium-scale projects will provide opportunities to develop local engineering, project management, and construction skills required to build solar parks. Developers of successful medium-scale projects will be in a position to compete for large-scale projects in years to come.

Hotbed of Innovation

One of the key developments in solar parks will be the development of new technologies enabling rapid deployment. These systems will necessarily undergo many generations of revision, and the technologies developed will flow on to large-scale projects.

Similarly, we can expect innovations in mounting systems and trackers to come through medium-scale solar projects.

Large-scale projects will generally be risk adverse and be unlikely to test new technologies until they have been proven in smaller farms.

QU18: What is the primary driver in your particular instance and why?

Our primary driver is to provide equitable and efficient community engagement in the low carbon transition.

If we are only interested in lowest cost abatement we can turn to large-scale wind for most of the next decade. However putting all our eggs in that basket would risk leaving communities behind. Quoting the White Paper:

To be successful - and to provide certainty to investors - Victoria's renewable energy transition needs community support. Community concerns about amenity, noise, environmental and cultural heritage impacts need to be addressed and support provided to communities and councils that are keen to capture the opportunities from new renewable energy projects.

Medium-scale projects (of all technologies) will play an important role in addressing community concerns and disperse the benefits equitably.

Section 6.3: Potential for Medium-Scale Solar in Victoria

QU19: To what extent is increased uptake of mediumscale solar a regionalised opportunity?

To maximise return on investment, proponents of large-scale solar facilities will reasonably favour the sunniest areas of the state.

Medium-scale projects have the potential to bring solar generation to the sunny parts of the state, if factors such as regional skills development, community engagement and energy supply stability are priorities.

Communities and commercial customers installing medium-scale to reduce their footprints (or shore up their 'green credentials') will be less sensitive to regional variation in solar availability. A framework enabling shared-ownership could create opportunities in all Victorian regions, urban and regional.

QU20: If a support mechanism is deemed appropriate, to what extent should this be differentiated in relation to the type of grid connection?

The concept of community owned solar can be applied across a range of scales and location types, however, each will have its own unique set of economics. A key objective of the programs should be to deliver a range of successful projects - from supermarket roofs to fields on the outskirts of a country town - however the economic return for participants in different projects should be relatively normalised and not provide unreasonable windfalls for one project compared to another.

Whether through tendering or a differentiated structure, diversity of program size and location should be a key objective of the medium-scale program.

QU22: Is labour density likely to increase or decrease when investing in larger installations? In other words, is the relationship between kilowatts installed and number of jobs created a constant, or are mediumscale installations likely to require more or less employees than smaller-scale installations?

Medium-scale projects should require significantly less labour input than small-scale (domestic) installations, due to the development of rapid deployment systems. There is an opportunity for these deployment technologies to be locally designed, manufactured and exported.

It is expected that large and medium-scale projects will share deployment technologies, with many innovations occurring in the medium-scale area first. As such, medium-scale projects may have similar labour density to large-scale projects.

Section 7.1: Potential Solutions to Addressing Current Barriers to Medium-Scale Solar

QU26: Given the barriers you have already identified as being the most significant in your particular instance, what would be the most appropriate solution and why?

Policy Stability

There have been several notorious changes to in renewable energy policy frameworks that have rapidly built industry capability only to abruptly destroy it. Many Australian businesses (disproportionately smaller firms) have faced significant hardships as a result of renewables policy instability.

Project development time-frames for medium-scale projects will be lengthy and proponents will incur almost all their costs prior to their first revenue. Abrupt changes to support frameworks will cause unacceptable hardship.

Policy framers are again referred to Deutsche Bank's excellent work on best-practice FiT policy design. The head of their policy research, Mark Fulton, is based in New York, but is Australian and will be in Australia in December.

Project Return / Feed-in Tariff

An effective and efficient FiT should be based around a target rate of return. We suggest that a range of 8 - 12% (after taking into account REC sales) is conservative and offers a good position with which to test the market.

There is evidence that individuals and communities will invest in renewables with an IRR in the vicinity of 10%, however, it is unlikely that we'll see significant uptake by corporates if projects return an IRR below their hurdle rates of return, which are generally much higher.

The solar industry is battle-weary after several boom and bust cycles - continued uncertainty and policy volatility are likely to increase costs as the industry factors in an appropriate risk premium. There's a fine line between an effective FiT and one that is 'too successful'. Policy developers need to determine how they will control the speed at which projects are implemented.

Feed-in-Tariffs as a Relocatable Right

With any policy framework that involves levying or taxing the population to distribute to a subset of society, great care must be taken to avoid social inequality - the NSW solar scheme was widely criticised as 'middle class welfare', deservedly or not.

Additional care must be taken to ensure that the system is not 'gamed' to the advantage of a few, or the detriment of the original policy goals.

Currently households may access the PFiT only if the panels are above their heads. As outlined earlier, for several reasons, many Victorian households cannot install panels above their home and are therefore excluded from the PFiT.

We suggest that access to Feed-in Tariffs could be seen as a relocatable right.

Households could purchase a shareholding in a shared-ownership medium-scale solar park that might be located elsewhere - perhaps even in a sunnier part of the state.

Depending on policy drivers, the quantum of ownership in any one farm, or in total, could be limited for any one principal place of residence.

A community solar park representing 100 households on the local supermarket would be much more capital efficient than 100 individual systems. Further capital efficiencies might be obtained by locating community solar parks parts of the state with cheaper access to land, or with better solar resources.

Community energy groups, whether they are created by climate action groups, schools or even retailers aggregating demand from many households, will create innovative opportunities enabling thousands of Victorians to own their own renewable energy infrastructure.

The emergence of smart-metering and smart-grids are likely to enable further innovation yet.