AER Finally Gets to Work on Flexible Export Rules

AER flexible export limits paper

Regulations to govern Flexible Exports of household solar PV to the grid took a step forward this week when the AER published its “final response” to a consultation conducted late last year.

According to the AER’s media release, the response is part of the regulator’s preparation of:

“regulatory arrangements needed to support the efficient implementation and uptake of flexible export limits across the National Electricity Market”.

In plain English: they want to ensure these Flexible Export rules work well and that everyone knows and follows them.

What Are Flexible Exports?

Flexible Exports, also known as “flexible export limits” or “dynamic exports”, refer to a system that dynamically adjusts the power solar installations can export back to the grid. This adjustment is based on the grid’s capacity to accept the energy at any given time.

How Flexible Exports Work:

Dynamic Adjustment: Your Distributed Network Service Provider (DNSP) will monitor their network’s capacity and adjust the export limits of solar installations in real-time or near-real-time. The dynamic exports are typically held between 1.5  and 10 kW compared to the legacy fixed 5kW export limit in most parts of Australia.

Network Capacity: If the electricity distribution network has ample capacity, solar installations can export more energy. Conversely, if the network is nearing its capacity, the DNSP will reduce the amount of rooftop solar energy that can be exported.

Inverter Control: The DNSP communicates with solar inverters, which will adjust their export levels based on the limits set by the DNSP.

Expected Benefits:

Efficient Utilisation: Flexible Exports aim to maximise the shared solar hosting capacity on the distribution network. This means more solar energy can be exported when there’s capacity.

Consumer Benefits: The net effect of an maximum 10 kW export limit is that solar owners should export more energy over 12 months, translating to more feed-in tariff revenue offsetting their electricity bills.

Lower Electricity Prices: As more solar energy is fed into the grid, it can lower wholesale electricity prices, benefiting all consumers, not just those with solar.

Grid Stability: By dynamically adjusting export limits, the system ensures that the grid remains stable and isn’t overloaded with excess energy.

Next Steps For Flexible Exports

This paper (PDF) details the regulatory actions the AER believes it needs to take to roll out Flexible Exports across the NEM.

For now, static export limits would remain the default, with the AER saying Flexible Exports should be offered on an opt-in basis. That’s interesting because it’s already mandatory for new connections in many parts of South Australia.

If you have an existing solar PV system and want to opt-in to Flexible Exports, you may require a new inverter and consumption meters to join the party.

Earlier this month, SA Power Networks became the first DNSP to require new systems and upgraded systems to support Flexible Exports. Anthony reported that one unintended consequence will be the scrapping of perfectly good solar inverters and panels when solar arrays are expanded (for example, when a household gets an EV and wants more energy for their home EV charging). The paper does not discuss this problem. Oops.

A Nationwide Comms Protocol For Flexible Exports

Getting technical, the AER will decide on a nationally-consistent communication protocol for DNSPs to make Flexible Exports work.

The AER has provided some insights into the communication protocol for controlling solar inverters:

  • Communication Protocol: The protocol facilitates communication between the DNSP and inverters to enable flexible export limits.
  • Standard in Use: While there isn’t a single mandated standard in Australia, the most common standard DNSPs use for this communication is CSIP-Aus (Common Smart Inverter Profile – Australia). This has been developed specifically to support communication exchanges between Australian DNSPs and customers to communicate flexible export limits.
  • ESB’s Consideration: The Energy Security Board (ESB) is currently considering whether to adopt a nationally consistent communication protocol in the form of CSIP-Aus.
  • AER’s Stance: The AER supports a nationally consistent protocol backed by a rigorous cost-benefit analysis. They plan to work with other market bodies to provide guidance, including any potential adoption of a nationally consistent approach to CSIP-Aus implementation.

I wrote a love letter to CSIP-AUS here – recommending Victoria adopt it for their emergency remote solar shutdown system.

In essence, while there’s no single mandated standard, CSIP-Aus is the most common one in use, and the AER supports moving towards a nationally consistent communication protocol.

It’s going to be CSIP-Aus isn’t it?

Conclusion

The AER is finally getting its act together on Flexible Exports – better late than never, I suppose. In the theatrics of consultations, the grand spectacle of cost-benefit analyses, and 67-page word salads,  they’ve missed a few points, such as perfectly good systems going to scrap, and the weak link that is consumer Wi-Fi connections but hey, no one’s perfect, right?

Thanks to Richard Chirgwin for help writing this post.

About Finn Peacock

I'm a Chartered Electrical Engineer, Solar and Energy Efficiency nut, dad, and the founder and CEO of SolarQuotes.com.au. I started SolarQuotes in 2009 and the SolarQuotes blog in 2013 with the belief that it’s more important to be truthful and objective than popular. My last "real job" was working for the CSIRO in their renewable energy division. Since 2009, I’ve helped over 700,000 Aussies get quotes for solar from installers I trust. Read my full bio.

Comments

  1. I understand that having control of the solar input is necessary to ensure a stable grid but given the amount of time this mob spent on this report the following quot directly from their document makes me seriously doubt either their competence or honesty on a fundamental level.

    “Consumer Benefits: The net effect is that solar owners should export more energy over 12 months, translating to more feed-in tariff revenue offsetting their electricity bills.”

    Can someone explain to me how curtailing exports achieves more feed in tariff revenue? Am I to believe that “they” are going to raise the feed in tariffs sufficiently to offset the reduced exports?

    By all means prepare papers and studies but at least provide a balanced and candid statement of the probable outcomes and any underlying assumptions used to support the conclusions.

    • Finn Peacock says

      The export limit rises from the legacy 5kW to mostly 10kW. So you are likely to export more kWhs. So you should make more $ than with a fixed, 5kW export limit.

      • George Kaplan says

        5 kW is only for single phase though correct? Those on triple phase are already exporting 15 kW or so – don’t quote me though it’s a while since I checked what the ‘limit’ was!

        The real limit for $ is actually the bonus FiT rate’s export limits. Once you hit the FiT cap you drop to a base rate that’s so low you need to export 2-3 kWh to make comparable revenue.

        • Finn Peacock says

          Legacy, fixed export limits are 5kW per phase in most parts of Australia, the new upper limit on flexible exports is 10 kW per phase.

          • Corey Ingleton says

            I also thought it was 5 kW per phase.
            I’m on 3 phase and can export up to 10 kW. Several retailers actually ask what size the inverter/system is because they’ve set limits at 10 kW.

  2. So…, this seems to mean that the 5Kw solar export limit imposed in Qld will/might be substituted with a flexible limit, ie, between NO limit, whatever can be produced and 0Kws.
    Do you know what meters and inverters woukd allow thus now?
    Have an order placed for Sungrow 5kw hybrid [actually 4.999kw] + 5kw standard inverter with 13 kw pvs, but will be holding out for its 9.999kw inverter.
    I assume one would need to change the export limit configuration in inverter to 0 and the distributer, Energex, would access the system to regulate, and to do this would require some hardware by which to do it.

    Seems this could subvert providers like Amber whose model to.some extent relies on increased consumption/battery charging when spot price is negative in middle of a summer’s day due an excessive of rooftop solar as would expect negative sp to be few and far between if NO rooftop solar is being exported.

    • Finn Peacock says

      The limit for QLD and SA is 1.5-10kW.

      Here’s a list of compatible inverters: https://assets.cleanenergycouncil.org.au/documents/products/Inverters-with-SCC-230614.pdf

      If that link breaks (which happens as its updated) go here and click on the link labelled “Inverters with Software Communication Clients”.

      Interesting point about Amber – if you have a local issue that throttles your exports despite a high wholesale price, that would be a bummer. And, yes when widespread this could reduce the amount of time the wholesale price goes heavily negative.

      • Dumb question, but no Enphase on here? Is there some difference between string and micro-inverters for flexible exports?

        • Finn Peacock says

          Enphase IQ8s “have been deemed-to-comply with the transitional arrangements as detailed in Dynamic Exports guideline sections 9.8.2 and 10.5.2″ – which is a South Australian thing and means they are:

          A designated electricity generating plant which can achieve, through a compatible communication software client, the critical functionality (listed below in table 9-2) of the communications software client test procedure, such that said plant can:

          * Successfully complete the dynamic exports capability test provided by the DNSP, and;
          * Receive, process, and enact an export limit sent from the DNSP utility server
          * Is deemed to comply with the Remote Updating Methods guideline so long as the manufacturer of that electricity generating plant has applied to the DNSP for recognition of this arrangement and public listing (including specific mention of non-certified functionality)

          Any such listing by the DNSP shall be valid until 1 April 2024, or until the manufacturer achieves complete certification of the relevant communication software client through the DNSP’s communications software client test procedure and the plant/client pairing is listed by the Clean Energy Council as CSIP-AUS compliant prior to 1 April 2024.

          So it looks like the IQ8s are on the way to being on the list. No luck for any Enphase installed before last week when IQ8s allegedly finally arrived in Aus.

  3. Thanks Finn.

    “The net effect is that solar owners should export more energy over 12 months, translating to more feed-in tariff revenue offsetting their electricity bills.”

    So the current maximum (often 5kW?) export limit will be raised at times of higher demand?

    • Finn Peacock says

      The current schemes in SA and QLD go up to 10kW, I’ve been told that they expect it to be 10kW most of the time – but that is coming from the DNSP…..

      • Finn, in South Australia, when you use the SAPN Smart Apply app you’ll be able see the previous 12 months of inverter control or uptime from the feeder for flexible exports eligilbe suburbs. This is to aid system designers who are required to calculate a systems generation when providing a quotation.

        It should be noted that if you lose internet communication with the network your inverter will default to 1.5kW/phase export.

  4. Andrew McDonald says

    Thanks, Finn. Another great, informative and clear article.
    The Flexible Exports proposal looks great on paper. A stable energy network is very important. May I please ask, what stops the DNSP working with the coal-fired power station or the big-business owned mega-battery to preferentially take electricity from them and leave the home-owner’s solar electricity unused. Seems easy to do if they control the home-owner’s inverter. Buying home-owner solar doesn’t generate much profit. Making home-owners pay elevated prices for other sources of electricity is in the financial interest of big-business.
    Already, they limit our solar exports, despite only 30% of houses having solar. Rather than limiting solar export at the home owner’s cost, I wonder how possible it might be to limit the flow of electricity into street substations to allow the substation to take in more home-owner solar and remain stable? Surely this is a great “green” solution to our energy needs? Unfortunately as it won’t generate income for the poles and wires people, it feels unlikely.
    Value your thoughts on my cynicism.
    Andrew

  5. No word about actual curtailing and implications for households. We/they have data for past and can predict how it intend to work. Will we still have our max export?, will that become minimum allowed going forward? My local situation is during summer – we constantly having high voltage error, does that mean those on new rules will be limited to 0 export most of summer time?

  6. Michael Paine says

    Looking at this another way, DNSPs will be able to throttle back grid exports whenever they like (supposedly to avoid overloading the grid) which means they can control the amount of feed-in tariffs that they pay. So, for example, if they are using very cheap power from wind generation they can cut back on drawing from home PV and save money.
    Similarly, throttling is likely when many homes in a suburb are generating loads of solar energy and so we may not gain much from flexible exports (swings & roundabouts!).
    I suppose we have to go along with these issues in order to keep the grid stable.

  7. Forrest Gardener says

    My crystal ball says that feed in tarriffs are heading toward zero. If right this is a complex solution to a soon to be non-problem.

    Especially after the recent tarriff increases (broadly paying 28c and receiving 5c), my naive analysis says that I should aim to maximize self-consumption. Supplying power to the grid means my self-consumption is sub-optimal.

  8. I feel this to be a step in the right direction, how ever I feel potentially down the track as more and more Solar gets installed, the amount you could export would gradually get less and less. Purely because as more places get solar installed, the demand on the grid will lower, and than the solar export would potentially be throttled. May not be a major issue right now (although we do already see it with negative costing of electricity during the day), but what about 5 years from now? or even longer. Since it is not unrealistic to expect a decent quality system to be up on the roof for 15 to 25 years. You could potentially find that in 10 years time you might be almost constantly stuck on the lowest export of 1.5.

    Personally I prefer the guaranteed 5kw export just because it is guaranteed, as opposed to a variable “you will get anywhere between here and here”.

    • Surely you’re not suggesting that the consumer would get screwed by the big players and the “powers that be”?

      (Yes, I’m being sarcastic.)
      However ANYTHING involving “limited exports” is better than the disgusting approach by Qld, using ripple control to completely turn your inverter off- even if you’re self consuming your solar, eg: charging a car or battery.

  9. Doug Mason says

    Thank you, Finn, for your clear account of Flexible Export Rules. Although the new rules are unlikely to apply to my legacy system, I read your article and responses with interest. To be clear, I think it is important for domestic solar users to be part of the distributed grid energy system, and so should accept curtailment of export from time to time for balancing the grid. I was left wondering what financial impact the new rules will have on domestic solar owners.

    I have used my Enphase production and consumption data to evaluate potential curtailment of export. My domestic system is average: Adelaide Hills location; 7.24 kW PV nominal; NE orientation with some morning shading in winter; 2 occupants working from home; twin-peak consumption profile; 8459 kWh solar produced (35% used, 65% exported); 7368 kWh total used; FiT is 5.2c/kWh.

    To estimate curtailment, I need to make some assumptions:
    – Export may be curtailed over a number of days, likely on days of peak solar production in summer. Probably more than 1 day, likely not 10, maybe 4. I assume the highest 4 production days are curtailed.
    – Export is likely to be curtailed during peak daily solar production, say for 4 hours between 11am-3pm.
    – Although curtailment may range down to 1.5 kW as per the rules, I assume all production in those hours is curtailed.

    The result is that 89 kWh would be curtailed, for a FiT loss of $4.57.

    Conclusion: Under the assumptions, domestic solar systems can be curtailed and contribute to increased stability of the national grid for the price of a cup of coffee in lost FiT annually.

  10. Yes we need better regulation for dynamic exports, but we also desperately need to regulate the inverters used to control the exports. Chinese made smart-inverters pose a very real threat.

    Imagine if all inverters are ‘flexed down’ to only allow 1.5-2KW through during peak generation times and a foreign actor overrides the controls and spikes it all the way back to 10KW.

    Not an issue if there are 1 or 2 affected inverters, but what if there are 100,000 or 1,000,000, now you’ve got a massive spike entering the grid and, at best, throwing the grid way off sync.

  11. Brendon Burgess says

    Hi, have signed up for a 6.6kw panel/Fronius 5kw inverter system with Battery Solar Solutions, install booked for December 2023. Noted that SAPN will be putting me on the Flexi export plan. City of Onkparinga. My folks live in the next street on fixed 5kw. Seems possible that I could be seeing less export compared to them. But its a new scheme, so not too much info/data to verify? Pretty sure SAPN won’t let me go onto the legacy of fixed 5kw either. Do I having thing to be concerned about? And is there anything I should be considering before the system is installed? Thanks!

    • Finn Peacock says

      The latest data shows SA flexible export customers get 10kW of export limit 98% of the time – so I think you’ll be fine.

      • Can you provide a link to this “latest data”? I’ve now observed export limiting of my system on 12 of 26 days that I’ve been on flexible exports.

  12. Yes this flexi exports plan is mandatory in SA we have no choice, when told about it by the salesman I said no that’s not for me then he told me I had no choice, it is taking control of your solar, an example of how you get ripped off my solar had played up for the last 2 weeks every day I was pulling the full days sun and it was distributed as PRODUCED 56 kw, EXPORTED 43 kw this is daily on sunny days, total of feed in tariff $2.11 not bad if you get 7 days worth, solar issue was resolved have a nice sunny day using the flexi mandatory plan I PRODUCED 23KW and EXPORTED 13 KW WELL BELOW THE 43 KW from the previous day my feed in tariff raised a miserable 0.11 cents, there is no record for you of the amount of solar you actually produce and the amount they take and sell to others for 80 to 90 cents a kw, SO WHERE IS MY CREDITS FOR THE POWER THEY TAKE FROM MY SOLAR, it’s our solar we should have a choice, it’s a rip off

  13. Adam Lewis says

    Thanks Finn,
    this was a great update. Looks like things are moving to some extent in the right direction, albeit at the glacial pace of Australian politics.

    Under this process can battery inverters feed into the grid? The aim should be to store in a battery, and send back into the grid when the price is highest. In that way everyone can become a genuine electricity producer. The communication protocol should include room to communicate the spot price?

    (Thanks also for the ‘Plain English’ part at the front – it really saved my brain cells, even though I worked for a long time in the public service!!)

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