PIAC considers it important to design a regulatory system that appropriately addresses consumer protections and reliability in situations where stand-alone systems are the sole energy supply for customers. Customers whose energy needs are wholly served by a stand-alone system will require greater protections, regulation and reliability and service standards than those using the services of local battery or solar PV, while remaining connected to the grid. PIAC considers that this is the case, regardless of the ownership model for a particular project, but acknowledges that there may be a need to accommodate incremental deviations from the standard to reflect the varying degrees of risk associated with different ownership models. Generally speaking, the less choice that a customer has, the greater the risk involved in a transaction. PIACbelieves the complexity of these schemes requires a more in depth consultation process, including working groups, forums and a further issues paper. We recommend that the discussion paper include case studies that demonstrate the current regulatory and legal constraints and possible solutions.
