My ACCC Submission: The CEC Approved Retailer Scheme Is Not Voluntary & Is Anti-Competitive

ACCC - CEC Approved Solar Retailer Scheme

If you want to sell residential solar in Victoria or batteries in SA, CEC Approved Solar Retailer membership is de-facto mandatory.

The Australian Competition And Consumer Commission — ACCC for short — is seeking submissions on whether or not the Clean Energy Council’s Approved Solar Retailer scheme should be renewed.

I think the answer is obvious, so any submission I make should only be a formality.  Despite this, I’m definitely submitting and not letting the opportunity pass by.  I’m going to submit harder than the Italian 10th Army after Operation Compass.1 

My position is the Approved Retailer Scheme should not be renewed.  Not in its current form.  This is because it is — in practice — not voluntary.  It’s also anti-competitive and competition is one of the Cs in ACCC — even though I keep forgetting which one.

Every on-grid solar installer (the individual electrician) in Australia is Clean Energy Council (CEC) accredited.  The ACCC is not seeking submissions on changing this solar accreditation scheme.  Instead, they are asking for input into renewing their authorisation of the CEC’s Solar Retailer Code of Conduct.  Before I show you my brief but succinct and poetically written submission, I will explain the difference between a CEC accreditation and the CEC Approved Retailer scheme.  I’ll also quickly cover what the CEC is and how their Approved Retailer Scheme changed from being voluntary to de facto compulsory.  This change has resulted in reduced business opportunities for non-members as well as contributing to solar installers in Victoria being driven out of business through no fault of their own.  

What Is The CEC? 

The Clean Energy Council is Australia’s peak body for solar power, other renewable energy, and energy storage.  In Nepal, peak bodies are unpleasant frozen surprises that litter Mount Everest, but in Australia, they are business advocacy groups.  Here’s a definition taken straight from Wikipedia:

“A peak organisation or peak body is an Australian term for an advocacy group or trade association, an association of industries or groups with allied interests. They are generally established for the purposes of developing standards and processes, or to act on behalf of all members when lobbying government or promoting the interests of the members.”

This is how the CEC describe themselves on their website:

Clean Energy Council description

This sounds good, but I would say this part…

…where they say they “represent and work with” solar installers hasn’t really been true for several years as they have clearly acted to the detriment of solar installers that were not part of their privileged Approved Retailer group.  Before I go into this, as I mentioned, I’ll explain what a CEC Accredited Installer and a CEC Approved Retailer are.  I think it’s important for readers to know the difference, and it’s goddamn vital for me to know, so I’d better go over it to make sure I get it right. 

What Is A CEC Accredited Installer?

A few years ago I wrote about the difference between:

  1.  A CEC Accredited Installer, and…
  2.  A CEC Approved Retailer.

But you don’t have to go back and read that because I’ll tell you the difference right now. 

Every solar installer who oversees the installation of solar systems that connect to the grid is a CEC Accredited Installer.  Or at least they bloody well better be.  Accredited installers are the only people permitted to connect residential and commercial solar systems to the grid and their installations can receive STCs from the Small-scale Renewable Energy Scheme (SRES) that lower the cost of solar power.   This subsidy is usually called the “solar rebate“.  Technically, that’s not the correct term for it — for a start, it’s not a rebate — but a lot more people understand the term “solar rebate” than “SRES” which sounds like an expression used by kids on the internet.

To become an accredited installer isn’t easy.  It requires training and certification.  You don’t want someone who doesn’t know what they are doing putting solar panels on your roof in much the same way you don’t want me giving you a CAT scan.  The closest I’ve come to using x-ray equipment is turning on the microwave and radiologists will probably say you’re not supposed to leave people in the CAT scanner until the popping noises stop.  

The CEC Accreditation system ensures you can only put solar panels on a roof if you know what you are doing.  While a bad installer can cut corners and do sloppy or even dangerous work, they have no excuse because in order to become accredited they have to prove they can do an installation that’s up to standard.  Opinions vary on the value of accreditation. But then some people say we should just let anyone who wants to, perform brain surgery and allow people to decide themselves whether or not to use their services. I’m actually okay with a reasonable amount of accreditation.  The ACCC decision will not affect the accreditation process. 

What Is A CEC Approved Retailer?

CEC Accreditation involves individuals but the CEC Approved Retailer scheme involves businesses.  It works as an exclusive club.  Solar installation companies that:

  1.  Stick to the Approved Retailer code of conduct
  2.  Do the extra paperwork being a member requires
  3.  Pay the membership fees to the CEC

..can apply to join.  If accepted they can then use their Approved Solar Retailer status to convince potential customers they do high-quality work and are ethical in their dealings with consumers.  It takes time and money to become one, but it could be well worth it if customers decide to go with an Approved Retailer over the competition, or they are willing to pay a premium for work performed by an Approved Retailer. 

This is how the CEC describes the scheme:

CEC Approved Solar Retailer description When I explain its basics like that, the Approved Solar Retailer scheme doesn’t sound too bad and, at the start at least, it wasn’t.  Installation businesses could decide to join or not as they saw fit and customers were free to choose to use or not use an Approved Retailer as they saw fit.  While there were issues around whether or not the CEC should be running the scheme in the first place, in its early days it was not harmful to the solar installation industry or to consumers.  Unfortunately, that changed. 

Conflict Of Interest

If it seems strange to you that the organisation in charge of accreditation is also in charge of an exclusive club that solar installation businesses have to pay fees to join, I’d say you’re onto something there.  There is clear potential for conflict of interests.   

The CEC is a non-profit organization, but this doesn’t solve the problem.  For one thing, people tend to be more concerned with what they personally receive than if the organization they receive it from is profit or non-profit. And the more money an organization brings in the more opportunity there is for larger salaries.  But there is no need for money to be involved at all for overreach to occur.  As Shakespeare’s Macbeth said…

“I have no spur to prick the sides of my intent, but only vaulting ambition, which o’erleaps itself.”

I’d say the CEC Solar Retailer scheme has definitely o’erleaped itself and squished a considerable number of businesses that did nothing wrong on the way.

An Unfair Advantage

If someone wanted to start something similar such as Bob’s Approved Solar Retailers or The Solar Justice League or The Avenge-solars, they are clearly going to be at a disadvantage compared to the CEC that is in charge of the accreditation process and gets heaps of free advertising as a result. 

Also, if Bob’s scheme doesn’t want to run afoul of the ACCC she is going to have to make sure her league doesn’t use its market power to engage in anti-competitive practices. 

To prevent the CEC Approved Retailer Scheme from abusing its position, the ACCC only gave it temporary permission to exist with the requirement that the scheme is voluntary.  Because, in practice, the Approved Solar Retailer Scheme is no longer voluntary, I don’t think the scheme should be renewed. 

No Longer Voluntary

Politicians tend to be a bit shit at getting stuff done.  This is because the political system rewards getting elected over actual management competence.  I know I’m making it sound like we have a bad system, but it is a lot better than what we used to have.  If you want to go back to being ruled by royalty you can always move to the UK and enjoy the reign of King Boris the Bad (hair).2

Politicians also know that even if they get everything right it’s still a crapshoot whether or not the public will see it that way.  For this reason, politicians have a strong incentive to cover their arses.  This way, if something goes wrong because of their own incompetence or due to bullshit flung by internal and/or external opponents, they can claim they didn’t do anything wrong.  The Approved Retailer scheme has been used for political arse covering and — to their shame — the CEC has actively encouraged this. 

There have been state subsidies for batteries that have only been available if the installer is a member of the Approved Solar Retailer scheme.  Because home batteries are fairly new this has mostly reduced opportunity for solar installers rather than destroyed existing businesses.  But this is still a bad thing that the ACCC does not approve of and — I presume — is grounds alone for them not renewing the scheme.

To their credit, some politicians have at least recognized there is a problem3 and changed the details so that adhering to a code of conduct is all that is required rather than the CEC Approved Retailer code, but this still gives CEC Approved Retailers a huge first-out-the-gate advantage.

The greatest problem has been caused by the Victorian Solar Homes Scheme.  I wrote about it here while Finn wrote about protesting against it here.  It initially gave up to a $2,225 subsidy for Victorian residential solar power systems and this was only available if the system was purchased from a CEC Approved Retailers.  If a residential installer couldn’t access this subsidy they would clearly be driven out of business in Victoria, because who is going to pay around $2,000 more for a solar system if they don’t have to?  By agreeing to participate in this travesty, the CEC helped damage perfectly good businesses that had done nothing wrong.  This reduced competition in the market, which is against the interests of consumers. 

It was at this point that I would say the CEC went from merely failing to do its job to promote the interests of the solar installation industry to actively working against the overall interest of the industry and the public’s interest.  The ethical thing for the CEC to have done would have been to refuse to participate.  All they’d have to do is explain that they represent the industry as a whole and so any subsidies or schemes that only apply to CEC Approved Retailers would not be ethical. 

The CEC Should Use The Right Tools To Increase Industry Standards

Some people make the argument that every solar installer should meet the standards the CEC Approved Retailer scheme requires.  And that’s not a bad argument to make, it’s just that getting there by forcing everyone to join the Approved Retailer scheme is nuts.  If standards in the industry need to be raised as a whole, then surely that should involve stricter accreditation and more effort put into ensuring compliance with existing standards than forcing everyone to pay fees to join an exclusive group run by the organization responsible for setting standards?  I can’t be the only one who thinks this idea is nuts.

If the CEC’s goal was to improve the quality of rooftop solar installations and customer service then I think they went in the wrong direction with their Approved Retailer scheme.  Instead, I think it would have made much more sense to have a robust independent inspection and mystery shopper scheme that installation companies could join.  Members could then use the inspection evaluations as a marketing tool.  This is an option for what the scheme could become, but I doubt it will happen. 

Member Quality Has Declined

Many installation companies have gone to a lot of expense to become Approved Retailers.  They did this because it gave them an edge over the competition.  But decreased standards has resulted in membership no longer meaning what it used to, and this has eroded the value of their investment.  When the Victorian Solar Homes Scheme made CEC Approved Retailer membership effectively mandatory, applications to join skyrocketed.  In July 2017 there were only 43 CEC Approved Retailers in the country.  There are now 975.  Among them are a number of companies I would not recommend anyone use.  I won’t put their names in print *COUGHnotevenincoughformCOUGH* but I will warn everyone that — while most CEC Approved Retailers do good work — it is no longer a guarantee of quality or good service.  These days you have to do research and check online reviews, the quality of the hardware they use and even that they have an Electrical Contractors Licence in your state4, before deciding to go with an Approved Retailer.  I’d even suggest getting multiple quotes, but then, I guess I would say that.

Solar Installers Should Not Be Hurt Further

There are installers who have put in a lot of work to become CEC Approved Retailers and they are being hurt by the lower standards and poor quality vetting of new members.  The extra paperwork they have to do and the fees they need to remain a member no longer provides the same benefit.  If everyone has to become a CEC Approved Retailer to stay in business then there is no market advantage to being one.  Anyone in an installation business in favour of compulsory membership should consider this.5

If the Approved Retailer scheme is going to continue to exist in some form, then it must actually provide value to members.  They don’t want to pay fees to the CEC for no advantage.  To preserve the remaining value of being a CEC Approved Retailer and ensure it continues to have value in the future, the best thing to do may be to separate the Approved Retailer scheme from the CEC entirely so there is no connection between the two organisations.  It will also have to be genuinely 100% voluntary and receive no special favours from government subsidies.  This way the scheme can survive on its own merits.  If high standards aren’t maintained then good installers will see no point in joining or remaining and the scheme will fade away.  It will still have an unfair advantage from the initial support it received from the CEC, but it’s better than the current situation.

Another alternative is to simply wind up the scheme, but gradually and while maintaining high standards, so members who have done the right thing and do good quality installations don’t get screwed over. 

The New Energy Tech Consumer Code Is Coming

I put this off because it’s going to make things a little confusing — but the CEC intends to replace the Approved Solar Retailer Scheme with a new, but very similar code called the New Energy Tech Consumer Code (NETCC) within the next 3 years.

The NETCC’s ACCC authorisation is currently under appeal in the Competition Tribunal. ‘Zero Interest Finance’ vendor Flexigroup is appealing the new code because it places tighter restrictions on ‘Buy Now Pay Later’ financing schemes.

Also, the administrator of the NETCC has not been appointed yet. Although, the CEC seems to have assumed it will administer the code as it recently advertised a position specifically to manage the NETCC.

While names are changing and there will be more focus on batteries, if the CEC administer the NETCC, I am not expecting any major planned changes in the operation of the CEC Approved Solar Retailer scheme as it morphs into the New Energy Tech Consumer Code.  As Shakespeare said:

“A rose by any other name will still have pricks.”

My Submission

I said I’d show you my submission at the end of the article and here it is…

Dear ACCC… yadda yadda yadda… here is my submission:

I don’t think the Clean Energy Council’s Approved Solar Retailer Scheme should be reauthorised by the Australian Competition and Consumer Commission in its current form on account of how the past operation of the CEC Approved Retailer Scheme has…

  1.  Not been voluntary in practice.
  2.  Reduced competition which has been against the public interest.
  3.  Has resulted in the CEC acting to the detriment of solar installation companies that are not Approved Solar Retailer members.

Not Voluntary: Various subsidy schemes — most notably the Victorian Solar Homes Scheme — have required participants to be CEC Approved Retailers to access the state solar rebate.  If you are not a CEC Approved Retailer in Victoria, your solar systems will be about $2,000 more expensive.  Because of this, membership was clearly not voluntary but a prerequisite of remaining in the residential solar business in Victoria.

In SA you cannot access the SA Home Battery scheme rebate (about $4000) unless you are an Approved Solar Retailer. If you want to be in the residential storage installation business in SA you are forced to be an Approved Solar Retailer.

Reduced Competition:  Subsidy schemes that require CEC Approved Retailer membership reduce consumer choice and are anti-competitive.

Does Not Represent the Industry:  The CEC claims to represent the rooftop solar installation industry but has taken actions to promote members of its Approved Retailer scheme to the detriment of installation companies that were not members.  This has resulted in installers being driven out of the residential business in Victoria, not for the quality of their work but simply because they were not members of a group the CEC describes in its application or authorization as “voluntary”.  There was obvious potential for conflict of interest in the organization in charge of setting standards and accreditation creating the Approved Retailer group and in practice, it has been glaring. 

The current CEC Approved Retailer Scheme should either be wound down or altered significantly from its current state.  I can make a few suggestions, but the issue needs more consideration than I’ve given it so far:

  1.  Wind down the CEC Approved Retailer scheme in a way that causes minimal disruption and inconvenience for existing members.
  2.  Completely separate the existing Approved Retailer scheme from the CEC.
  3.  Replace it with a robust, independent, inspection and mystery shopper scheme with publicly available results that provides consumers with clear information on the quality of installations. 

Any Changes?

If there is anything you think I should add to my submission — or subtract — let me know in the comments.  But make it quick, because I’m going to submit it this afternoon. 

Footnotes

  1. One of my three grandfathers was a Montgomery and — just like General Montgomery — he was short and annoying.
  2. I do realize Australian PM’s are, regrettably, increasingly acting like an unelected one-person executive — or team Captain as Sir Tony of the Onion put it.
  3. See?  Politicians can be useful.  They’re actually quite handy compared to the average tyrant or, say, Skynet.
  4. In NSW, ACT and SA you need an ECL to sell solar power. We have found a number of ASRs that are listed as operating in NSW, SA or ACT that do not have those ECLs.
  5. If membership was compulsory, do you think fees would decline due to economies of scale or do you think they would they mysteriously increase for no adequately explained reason?
About Ronald Brakels

Many years ago now, Ronald Brakels was born in Toowoomba. He first rose to international prominence when his township took up a collection to send him to Japan, which was the furthest they could manage with the money they raised. He became passionately interested in environmental matters upon his return to Australia when the local Mayor met him at the airport and explained it was far too dangerous for him to return to Toowoomba on account of climate change and mutant attack goats. Ronald then moved to a property in the Adelaide Hills where he now lives with his horse, Tonto 23.

Comments

  1. The current scheme is just a money grabbing exercise. Pay to be an approved retailer…..pppffffttt!

    • Alex Khassapov says

      “non-profit” only means they don’t pay taxes, which is even more of corruption

  2. CEC Approved Retailer Is trash

  3. Definitely need to have your paragraph 3 adopted amongst others. The very existence of the facebook website member “Crap Solar” shows this with it’s almost daily disgraceful exposures. It would also seem that the instruction for placement and wiring of DC isolators features very strongly on the list of things needing attention.to even be an accredited installer let alone an approved retailer.

  4. I recognise the ‘not really voluntary any more’ nature of the scheme, and agree it’s a quandary. But how could the CEC ‘refuse to participate’ in the Victorian Solar Homes Scheme? It was a government decision to require Accredited Solar Retailers for the scheme. Whether or not this was what the CEC wanted, it’s not really up to them.
    As a consumer advocate, I admit I supported the requirement. I would much prefer appropriate regulation of a minimum standard for key aspects of the solar/battery etc. industry (e.g. regarding reasonableness of performance estimates, appropriately regulated financing, good information provision, dispute resolution, etc.) – then the CEC scheme could be what it was intended to be, a ‘best practice’ accreditation. But in the absence of appropriate consumer protection regulation for theindustry, consumers who don’t really know what they are doing are vulnerable to poor outcomes from the Dodgy Brothers Solar Co.
    We have tried for years to get governments to implement basic and appropriate consumer protection regulation in the new energy industry, so consumers have confidence and voluntary schemes can be about best practice and stay truly voluntary. Unfortunately governments have been unwilling to regulate and instead decided that voluntary schemes are more appropriate. It’s a tricky issue. But solar is no longer a niche product, it’s mainstream and that means consumers are not well informed about what they are buying (in general) and consumer protection of some kind is more necessary.
    For transparency: I am one of the people behind the NETCC. That too is a second-best solution, only needed in the absence of appropriate regulation. But the absence of appropriate regulation is where we still are. Also, the organisation I work for (Renew) has a rep on the Consumer Advisory Panel for the CEC Accredited Solar Retailer Code.

    • Finn Admin says

      Unfortunately, there are plenty of “Dodgy Brothers Solar Co’s” who are Approved Solar Retailers. It is beyond my comprehension how some known bad actors are Approved as ‘the best of the best’.

      • I agree, that shouldn’t happen. I believe you can give feedback to the CEC on poor performance of Approved Retailers and they investigate

      • Stefan Jarnason says

        That is the real issue. We need to drive out the dodgy crap solar. New customers cant do this alone.

        SolarQuotes does a great job weeding them out. CEC Accredited retailers also does a reasonable job.

        My view is that we need the good bits of the Accredited Retailer code or similar to be mandatory and ubiquitous, then the penalties for dodgy solar to be increased (not for trivial issues).

      • Finn, if you knew what you are talking about you would know that the dodgy Approved Solar Retailers have their designation removed for such offences thereby helping improve the standard. Or should just do nothing?

  5. That is a terrible uneducated article.

    The idea of the Approved Solar Retailer Scheme was to create a set of standards that are so badly missing in this industry. To call it a “exclusive club” again displays some ignorance of what bodies like this are about. Take the Chartered Institute or CPA for accountants. They are bodies that set the standards of behaviour or code of conduct. If you don’t understand that then you should keep shut on the topic.
    We get pretty sick of having to deal with irate customers who have had shoddy work done by installers who don’t know what they are doing or don’t care or both.
    You are not out there in the field, you don’t see what we see. The Approved Solar Retailer Scheme has tremendous merit. It makes those who want to be admitted and keep their membership accountable.

    • When a company can buy a badge of credibility from a lobby group.. you need to wonder.

      Good article guys.
      Cutters against ASR

      • Absolutely @lloyd soikes. And if people still don’t believe there are issues for the ACCC to review, here’s more proof: To connect a solar system to the grid, an inverter has to be CEC approved by the distributor. Approval lasts for as long as the local distributor or manufacturer wants to sponsor it’s re-approval (each approval only lasts 2 years before the CEC expires it, IIRC).

        While this ensures only the latest equipment is being installed, it also forces people to buy the latest gear from the top of the market, when they may only need what older, cheaper equipment can provide. It also prevents any reuse, and sends the majority of used solar equipment to landfill.

        For example, brand new grid-tied inverters that are no longer CEC approved are routinely sent to landfill. Every time a vendor or distributor goes bust, ‘new old-stock’ is scrapped. Occasionally some gets advertised online for nominal amounts, among a sea of unused and second hand inverters that are only allowed as direct replacements for an existing inverter. Many are advertised that can never be re-connected lawfully.

        In effect, the CEC are:
        1. Artificially inflating the cost of new equipment (most of which is subsidised by the taxpayer, as there is little to no competition from older models or used equipment.

        2. Forcing consumers to pay thousands of dollars more because they cannot use or re-use an existing inverter- even one that meets the current standards, and is perfectly fit and serviceable.

        3. Preventing the re-sale of used solar systems. Almost no second hand market can develop as lawful re-use must be off-grid only.

        4. Creating an incentive to unlawfully re-use equipment, which should never be encouraged as it is likely to result in work that ignores electrical standards and regulations. This will kill people.

        5. Preventing the industry from optimising existing installations by upgrading inverters to more suitable models, as doing so costs more than it could.

        6. Orphaning every consumer’s present solar equipment within a few years of installation. Re-sale value becomes zero. Changes to installations thus require extensive upgrades, usually complete replacement. Old equipment cannot be removed and re-used because older solar panels no longer attract STCs, even if they work perfectly- and, of course, re-connecting an inverter that the CEC has removed approval is prohibited.

        The CEC knows exactly what their approved equipment status means. Every day it diligently works as an arbiter of what is, and what isn’t allowed. It collects a financial incentive from the parties that pay for each model to stay on the approved list, but which in real terms is operating a mechanism which supresses competition and even seeks to exploit government subsidy. Given that it also directly regulates the market in STCs,this is clearly racketeering.

        Whilst most in the industry think this acceptable, many would because they haven’t thought about it. Some perhaps as they preceive they can make more money from the rules that prevent re-use, and encourage people to buy new and apply for more STCs.

        But in the long term, the entire industry is at risk as our use of words like ‘clean’, ‘renewable’ and ‘sustainable’ will become more and more questionable. This may meet the political agenda of some parties, but it hard to see it being in the interests of a Clean Energy Council.

        It is high time the industry and the CEC begin acting in the best interests of tax-payers, consumers. The lobbyists prevent them taking a long view.

        And for now, the ACCC needs to understand that the CEC is preventing natural market competition by forcibly de-certifying equipment that meets applicable regulations and standards. Regulation is complex enough in these matters to have behaviour like this. Bodies in pivotal roles should be behaving for the long term good, let alone the common good, or the public interest.

        At the end of the day, someone has to turn the tide of old equipment going to landfill. Even at 10-20 years old, many solar panels still operate and 80 to 90% of their capacity. If an inverter still works and meets the relevant criteria, why must the consumer, the vendor or the ACCC accept that it should not be re-purposed, or that its value must be zero?

        • Hi Nino,

          CEC listings for inverters can last up to 5 years, and panels for 3.
          And CEC have an approval extension process for stock left at the end of a manufacturing run (as long as the product still meets the current standards).
          The main reason for the high turnover in approved panels and inverters, is changes to the mandatory test standards that apply to them,
          Since 2015, there have been 2 rewrites of the inverter standards, and 2 re-writes of PV panel standards!
          This is a symptom of rapidly changing technology and development of the industry.

          In particular, the main standard for grid connected inverters (AS 4777.2) was updated in 2015, with many new requirements for inverter functions, so any inverters manufactured earlier than October 2016 cannot be re-used. (except for replacements in existing systems as you discussed).
          The CEC is not making profit by encouraging turnover in equipment listings. The costs incurred in the testing and certification process are spread over large volumes of inverter sales and don’t make a significant difference to the price that solar customers pay.

          FYI: I work for the CEC product approval team.

          • Thanks for making the time to respond, Bruce. You seem to have missed my point, that in orphaning expensive equipment after 2 years, what the CEC is doing is *DIRTY*. I think you should explain or admit that, rather than make excuses.

            A temporary approval, let alone a short 2 year period, prevents almost all re-use, and literally sends perfectly good panels and inverters to landfill, when all these assets should be utilised wherever possible to reduce carbon emissions. Retiring it before its end of life increases pollution, and costs, when the alternative does the opposite, *and* allows the community to maximise these assets’ economic value.

            Your point that a vendor’s option to maintain an approval for 5 years is not helpful, as residential inverters are almost exclusively approved for a 2 year period. It could only help if the approvals for at least a significant number were longer.

            This is at the heart of the problem the CEC has, and continues, to cause. i.e. Ending the life of equipment that is not just expensive to make. And doing so long before there is **any** suitable recycling process or facilities in place to begin dealing with all the assets presently being removed from service, (as Craig Hardcastle’s War on Waste program showed some of) the extent of this problem with old, but still serviceable, solar panels).

            To be clear, this is something the CEC, as the regulator, may prefer to ignore, but ultimately must accept responsibility for.

            Your comment about the cost the CEC levies for approving each product really just underscores this as an attitude, culture or worse, policy of avoidance, for it suggests that somehow this is less of a problem as the cost of this process does not include a profit. However there are no figures, and you do not point to any financial transparency around this. However, regardless of costs, my point is that the CEC shouldn’t orphan anything unless it is unsafe to connect- which in itself creates considerable long-term costs for everyone investing in solar and SSG systems.

            Preventing the re-use of something that is acceptably left in situ elsewhere on the network is clearly an obtuse way to manage assets. However, managing network assets is up to the network owners. Having the CEC orphan equipment is over-reach at best, perhaps even meddling and abuse of power because, equipment either meets the standards, or doesn’t. If ageing, or presenting a limitation to network operators, these parties can simply make changes to the standards, as they normally do. They have no need whatsoever for the CEC to push their case, as they have been driving the evolution of these standards (a large amount of which are about maintaining network integrity. As well as capability), it should be retired at that point, not before.

            The CEC, and the network providers all have the specifics provided of the SSG equipment installed at each site. Reviewing that list periodically, and encouraging owners to upgrade in time for network changes would be more comprehensive, and prevent anyone worrying if a enough 20 year old inverters are still generating enough power to interfere with a particular new management feature.

  6. Hi Ronald, very timely and well researched. I made a submission about 6 months ago stating much of what You have written. I have also contacted the CEC many time about this and have requested phone discussion and or email response and gotten nothing from them. I have also been contacted several time by the ACCC asking permission allow them to make my submission public. I did noit authorise them to make it public as I fear repurcussions frm CEC – such is the power they will have if this goes ahead in its current form. The ASR is a poor strategy to improve solar credibility and is unfair to installer retailers. Anybody whom has commented here ought to send their submission to the ACCC – it is so important to our industry. Once again large corporations will be the winners and small business will bear significant bureaucratic burden and cost – many may not survive. So please take the time to make your submission

    • Glen I am a small business and an ASR and have not seen any significant bureaucratic burden or cost. This strategy is better than doing nothing. I have seen ASR’s lose their designation because of it.

      • Jolyon Parslow says

        Peter regarding accounting bodies, as a small business person I used 5 different accountants over the years. Three, in my view were unethical or gave poor advice. Most compulsory industry bodies are captured by those who want to advance their interests, not the public interest, and become very powerful lobby groups, not regulators. Look at past scandals regarding big accounting & liquidation firms & financial planners.

        At the moment there is something. If it is compulsory there will be something on paper & nothing in practice, in my view as a consumer & business person.

  7. Jolyon Parslow says

    Precisely how many lost designation over what time period? Where can we see this evidence?

    Other people above said they complained and got no response from CEC.

    It would be more useful if you could take a deep breath, and be a reasonable person and explain how many dodgy brothers have been got rid of and explain why others can make no headway trying to get action on dodgy brothers.

  8. This is a refreshing article and I support it. I believe that the acceptance of retailers has changed over time. Some of the competitive quotes from approved retailers clearly have consumer terms that are not in line with the current requirements. The current mantra of the CEC is to adopt their terms (of course which are available for a steep price). We had to give up trying to have our terms or variations accepted as we were under duress to be an accepted retailer to be able to continue to service our Solar Victoria rebate customers. Interestingly the CEC had a 12 month ABN requirement rule. I spent 6 months appealing this with the CEC because this precludes the sale and purchase of solar companies that transition to a new ABN. The CEC of course wouldn’t have any issue with this as the new company could just sign 12 months later; however, who would buy a residential solar company in Victoria if they had a 12 month exclusion to the Solar Victoria program. Luckily I was able to have them change the ABN rule but it just shows how protracted and ineffectual Solar Victoria’s Program was in it’s implementation. Thank goodness we are doing more business outside of Victoria and less reliant on the CEC accreditation.

    There are countless examples of businesses being accepted under the program who are not doing the right thing and not being penalised. Of course Captain Green had a suspension published online last year but outside of that I havent seen or heard of a retailership eing revolked.

    Interesting the comment on CA/CPA. I myself am a CA and the two bodies are not appropriate to compare. One is a professional body that designates individuals based on them completing a professional course and designation along with a mentorship program. It has the power to audit it’s members, requires continual education, etc. The other is a voluntary membership for organisations where sign up is an agreement to a set of guidelines. A better comparison may be the MTAA (Medical Technology Assoc. Aus). The MTAA has the same voluntary approach but the industry does not preclude tendering or business when an organisations decides not to become a member. Therefore it protects the voluntary nature of the organisation and aspires to enforce its code which highly discriminates immoral and unethical practice. Effectively what we all want more of in solar 🙂

    Keep up the good work solarquotes!

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