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Page 1 of 13 APVA Response to PV Costs and Abatement in the Productivity Commission Research Report: Carbon Emission Policies in Key Countries, May 2011 June 2011 The Productivity Commission had particularly challenging terms of reference for this report. Calculations of policy impacts such as those undertaken by the Commission are inherently counter factual requiring carefully chosen methodologies involving many and diverse assumptions and, consequently, judgements. A key issue is that such choices need to be transparent, equivalent across the policies being compared, and appropriate to the task at hand. Results should also be contrasted with other studies as appropriate, and presented in terms that highlight their limitations. Most importantly, such work needs to focus on the key question – how analysis of existing policies can guide future policy efforts. Unfortunately, the Productivity Commission report appears to be lacking in many of these regards. We focus in this APVA response, particularly, on the Commission Report’s assessment of photovoltaics (PV). Their analysis appears to have chosen an inappropriate methodology and applied some questionable assumptions that, in aggregate, would seem to have greatly inflated the economic subsidy associated with PV deployment in Australia. The APVA is also concerned that the Productivity Commission report misses a key point in the move towards a less carbon intensive economy – the new technologies which need to be developed require market deployment at scale in order to move down the development cost curve. Carbon prices alone, especially prices as low as $10-$20 per tonne, as currently proposed, would not in themselves be sufficient to drive industry investment. Because of this, programs such as the PV Rebate Program, the Solar Homes and Communities Plan, the Renewable Energy Target and the various State Government Feed-in tariffs were established with a range of objectives, with emissions reduction being only one. To therefore use abatement cost as the sole measure of the value these programs have provided to Australia is misleading and risks destroying the new industries and jobs which have been built up over the last decade. Without these industries, Australia would face an even tougher challenge in meeting its emission reduction goals and would lose its capacity to participate in the new vibrant low carbon economies of the future which are now absorbing over 25% of global venture capital. Given the significant problems in both methodology and factual content of the Productivity Commission's report, the APVA considered it necessary to provide a preliminary response as soon as possible. As such, the following represents a 'first pass' response and does not claim to cover all the report's inadequacies in detail.

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APVA Response to PV Costs and Abatement in theProductivity Commission Research Report: Carbon Emission

Policies in Key Countries, May 2011

June 2011

The Productivity Commission had particularly challenging terms of reference for this report.Calculations of policy impacts such as those undertaken by the Commission are inherently counterfactual requiring carefully chosen methodologies involving many and diverse assumptions and,consequently, judgements. A key issue is that such choices need to be transparent, equivalent acrossthe policies being compared, and appropriate to the task at hand. Results should also be contrastedwith other studies as appropriate, and presented in terms that highlight their limitations. Mostimportantly, such work needs to focus on the key question – how analysis of existing policies can guidefuture policy efforts. Unfortunately, the Productivity Commission report appears to be lacking in manyof these regards.

We focus in this APVA response, particularly, on the Commission Report’s assessment of photovoltaics(PV). Their analysis appears to have chosen an inappropriate methodology and applied somequestionable assumptions that, in aggregate, would seem to have greatly inflated the economic subsidyassociated with PV deployment in Australia.

The APVA is also concerned that the Productivity Commission report misses a key point in the movetowards a less carbon intensive economy – the new technologies which need to be developed requiremarket deployment at scale in order to move down the development cost curve. Carbon prices alone,especially prices as low as $10-$20 per tonne, as currently proposed, would not in themselves besufficient to drive industry investment. Because of this, programs such as the PV Rebate Program, theSolar Homes and Communities Plan, the Renewable Energy Target and the various State GovernmentFeed-in tariffs were established with a range of objectives, with emissions reduction being only one. Totherefore use abatement cost as the sole measure of the value these programs have provided toAustralia is misleading and risks destroying the new industries and jobs which have been built up overthe last decade. Without these industries, Australia would face an even tougher challenge in meetingits emission reduction goals and would lose its capacity to participate in the new vibrant low carboneconomies of the future which are now absorbing over 25% of global venture capital.

Given the significant problems in both methodology and factual content of the ProductivityCommission's report, the APVA considered it necessary to provide a preliminary response as soon aspossible. As such, the following represents a 'first pass' response and does not claim to cover all thereport's inadequacies in detail.

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Main points:

- The costs of PV quoted in the report are overstated.- Emission reductions due to PV are understated.- The costs of emissions abatement due to PV are therefore overstated.- The report neglects to acknowledge the broad aims of the renewable energy target, PV rebates

and feed-in tariff schemes, or to consider the economic development, employment, technologydevelopment or other benefits associated with solar subsidies to date, and overlooks the near-future potential for PV:

o Rebates, renewable energy certificates and feed-in tariff support for PV have beeninstrumental in creating an industry with a $2 Billion turnover and over 10,000 jobs

o 400,000 or more Australian families now have some insurance against rapidlyincreasing electricity prices

o In 10 years, the Australian PV sector has reduced PV system prices to the point wheregrid parity is in sight. Within about 5 years PV on the distribution network will requireno subsidies. The coal and other fossil fuel industries continue to receive subsidies forfreight, port facilities, exploration, diesel generation and other costs after 100 or moreyears of deployment. In addition, to date they have not been required to pay for theimpacts of their pollution

o Complementary support measures are needed over the short term for PV systems toreach grid parity, after which the PV system owner’s cost of abatement will benegative.

The Productivity Commission Methodology

Estimating the economic subsidies associated with the range of climate policies assessed by theProductivity Commission (PC) is particularly challenging. Nevertheless, PC estimates of economicsubsidies ($/tCO2) appear to be roughly half to one third that of credible alternative studies for theNSW GGAS, roughly half to equivalent that of the Queensland Gas scheme, equivalent to two timesgreater than these studies for the large-scale eRET, and around two to four times greater than suchstudies for PV. These discrepancies are not well addressed by the PC. The following table summarisesthe PC’s subsidy estimates as well as some key alternative work. Key elements most relevant to PV arethen discussed.

Scheme Statedobjectives

Productivity Commission estimate ofeconomic subsidy ($(2010)/tCO2)

Alternate estimates ofeconomic subsidy($/tCO2)

Estimate of energyconsumer subsidy ($/tCO2)

Notes: Schemes shouldbe assessedagainst objectiveswhich are oftenfar broader thanjust emissionreductions.

In estimating the subsidy equivalent the Commissionis attempting to measure the resource costsassociated with actual abatement, and not includingstraight transfers between participants. Note alsothat PC has attempted a static analysis for 2010which is highly problematic for policy assessmentbecause these policies are intended to drive changeover time, and have succeeded in doing so, withconsequent price reductions projected into thefuture.

Many possiblemethodologies andassumptions can be used forthis calculation.Nevertheless, a range ofalternative estimates areavailable that might havebeen better described by PC,and evident opportunities toimprove estimates.

Subsidy as paid by electricityconsumers (this is the subsidythat impacts on electricity bills)

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NSW GGAS Reduce emissionsassociated withNSW electricityconsumption

$4.57

PC uses 2009 NGAC spot price (note that the schemefuture was in significant doubt in 2009 and the pricehas been above $10 for most of the scheme’s life)

$10-14

Key question is the LRMC ofabatement projects ratherthan spot price towards theend of scheme’s expectedlife. However, difficult toestimate when such a widerange of projects are eligibleto claim abatement. Spotprices earlier in the schemelife likely to be a betterguide than 2009 price.

$30-100Key issue is that of additionalityas electricity customers requiredto pay for all NGACs, yet onlysome of these represent actualadditional abatement. Estimatesof additionality difficult to makehowever PC reports DCCEEestimate that only 0.7Mt of over15M NGACs in 2009 representedadditional abatement. Even at $5NGAC that represents real priceof $100/tCO2 for the energyconsumer.

Grattan Institute estimates $15-$40.

Qld GasScheme

Increase gassupplyinfrastructure inQueensland, andreduce emissionsfrom its electricityindustry

$18

PC uses 2009 GEC (Gas Electricity Certificate) priceof $6.49 (note that effective future of the schemewas in significant doubt in 2009 given the CPRSproposals and the GEC price was between $10-16for first four years of the scheme.

$20-40 (Grattan Institute)

Can estimate directly fromLRMC of gas-firedgeneration vs. coal inQueensland. Otherwise,early GEC prices likely to bebest guide to actual projecthurdles that had to beovercome by the scheme.

Not estimated.

As the PC notes, significantquestions about the additionalityof the scheme given that gas-fired generation investmentsoccurring in other States withlow-cost coal. As an example, ifadditionality was only 50% thencustomer subsidy would be oforder of $40-$80.

Large-scaleeRET

Increaserenewablegeneration andreduce emissions

37-111

High range value assumes LRMC cost for wind (i.e.REC price of $60 required to drive investment) andlow abatement (offsetting gas generation ratherthan coal+gas mix). Note that LRMC estimates notused for GGAS and Queensland Gas Scheme, norGGAS electricity reductions offsetting gas generationrather than coal+gas mix. If PC used samemethodology as used for GGAS and QueenslandScheme then approx. $40.

$30-70 (Grattan Institute) $30-70

Some early additionalityproblems in the original MRETwith old hydro and solar hotwater. The large-scale eRETshould, however, be largelyadditional because renewablegeneration generally has higherdirect costs than conventionalsupply.

Small-scale PVrebates, eRETand feed-intariffs

Original PV rebateobjectives topromote theuptake ofrenewableenergy, reducegreenhouse gasemissions, help inthe developmentof the AustralianPV industry andincrease publicawareness andacceptance ofrenewableenergy.

Feed-in tariffsaims are localinstallations andjob creation

$432-1043

PC applies a surprising methodology. Rather thanuse LRMC estimates of the cost difference betweenPV and conventional supply as with large-scale eRET,instead estimates total fiscal subsidy without anyattempt to separate economic subsidy fromtransfers (unlike other PC scheme assessments suchas that undertaken for GGAS). For eRET subsidy, onlyconsiders 15 years of abatement although assumingan economic life of 20 years, hence 5 years ofuncounted abatement. Also apply a low abatementscenario as per large-scale eRET without justification(if it is to be included, then it should also be appliedto NSW GGAS).

For most State feed-in tariffs, assume all generationinstalled at end 2010 had been installed for entireyear which will increase subsidy. Assume householdswith net feed-in tariffs get paid the feed-in tariff ratefor 50% of their production which according topublished estimates is excessive and likely to betypically 17-28%. Doesn’t account for front-loadingof some feed-in tariffs; e.g. NSW scheme provided a7 year production subsidy for an asset with assumed20 year economic life – ie. PC methodology doesn’tinclude 13 years of ‘free’ abatement.

McKintosh et al (20101)estimate social abatementcost from PVRP (broadlycomparable to economicsubsidy) of $229-274 for2009. This estimate,however, underestimatestotal abatement by about0.5Mt (14%)

2. Also, they

assume effective futureclimate policy that reduceselectricity industryemissions intensity over 50%by 2040 (which isn’tincluded in the PCassessments and representsaction that hasn’t yet beentaken)

More importantly systemcosts fell 30% in 2010 from2009 levels suggesting thatthis estimate is far too high.Prices have fallen by 30%from 2010 to 2011.

Not estimated.

Methodological problems with PCstudy as noted previously meanthat their estimates don’t appearcredible. Furthermore, theirreport explicitly states that theyare attempting to assessincreased costs to the economy,rather than transfers such asthose involved to determineelectricity customer subsidies.

Note that some earlyadditionality problems withoriginal PVRP. Current supportshould, however, be largelyadditional because of the highcosts of PV at present.

1McIntosh et al, 2010, The Australian Government’s Solar Rebate Program: an evaluation of its cost effectiveness and

fairness”, The Australia Institute, Policy Brief 21, November 2010.

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Emissions Abatement is understated

The abatement cost of a PV system connected to the distribution network can be calculated bycalculating the difference between a PV system’s Lifetime Cost of Electricity (LCOE) and the retailelectricity price then dividing it by the estimated abatement. The LCOE approach assumes appropriatediscount and interest rates (say 7% and 2.5%) and so reduces the future value of PV electricity andincreases the abatement cost.

The Productivity Commission uses a highly simplified means of calculating emissions abatement fromsolar power that understates both installed capacity and electricity generation, translating 21 million PVRECs created in 2010 into 344 GWh of generation through assignment of certificate value that implicitlyassumes all PV systems attracting solar credits were 1.5kW in size. However, as shown by the Office ofthe Renewable Energy Regulator (ORER) in Figure 1, this is incorrect, meaning that fewer Solar Creditswould have been created per kW installed and generation would be higher than stated by the PC.

Figure 1: System Size Trends3.

A more accurate methodology is to translate the installed capacity into actual energy generation. TableD7 in the PC report illustrates that 336.5 MW was reported installed in the major solar States andTerritories – even adopting the conservative assumptions used by ORER’s deeming calculations, thistranslates to 453 GWh of annual PV production4, 32% higher than the 344 GWh estimated by the PC.This in turn translates into 415kt of annual emissions abatement, rather than the PC’s 317kt.

2APVA, 2010, APVA Response to the Australia Institute Policy Brief 21: “The Australian Government’s Solar Rebate

Program: an evaluation of its cost effectiveness and fairness”, November 2010.

3Livingstone, A., “Renewable Energy Targets and Compliance”, AUSES Solar Seminar 2011, Brisbane

41185kWh/kWp/year installed for the majority of Victorian and Tasmanian installations and 1382kWh/kWp/year for the

majority of the rest of Australian installations – 61.6MW and 274.8MW respectively in 2010 by Table D7.

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Technology costs are overstated

The PC overstates the cost of solar electricity by using the costs cited in AEGTC 20105, which estimatesthe cost of PV systems at nearly twice their current installed cost6.

Comparisons are with wholesale rather than retail tariffs

The Productivity Commission overstates the level of the feed-in tariff subsidies when it assumes thatsolar generation that is exported to the grid offsets only the cost of daytime wholesale power. Thisignores the avoided cost of losses in transmission and distribution, as well as Use of System chargeswhere relevant.

PV electricity exports are overstated

Whilst the PC’s REC calculations assume every system is 1.5kW system in size, they also assume that50% of the electricity is exported to the grid and thus attracts the feed-in tariff in jurisdictions with anet feed-in tariff. This ignores other reports demonstrating the amount of power exported from 1.5kWsystems typically ranges between 17% and 28% 7. This is in line with earlier APVA estimates shown inFigure 2.

Figure 2: Expected PV electricity exports by system size and household load8

5EPRI (2010) Australian Electricity Generation Technology Costs – Reference Case 2010, by the Electric Power Research

Institute for the Australian Government Department of Resources, Energy and Tourism, February 2010

6See for instance APVA, (2011), PV in Australia 2010, Australian PV Association for the International Energy Agency, as

well as a range of publicly available websites of PV installation company’s offers

7AECOM (2010) Solar Bonus Scheme: Forecast NSW PV Capacity and Tariff Payments, by AECOM Australia for Industry &

Investment NSW, NSW Government.

8APVA 2007, Submission to the Government of South Australia’s Discussion Paper on South Australia’s Feed-in

Mechanism for Residential Small-Scale Solar Photovoltaic Installations, February 2007.

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PV generating lifetimes

A well designed PV system will keep generating much longer than the 7 year life of the NSW SolarBonus Scheme, or the 15 years of the eRET deemed generation. Most PV modules are sold withwarranties of 25 years and the International Energy Agency uses 30 years for its life cycle analyses9.The PC report appears to ignore the front loading of feed-in tariff and other programs, and hence themuch longer generating life of PV assets. For example, the Productivity Commission analysis of the NSWFeed-in tariff effectively ignores 23 years of potential abatement from the PV systems.

Summary of abatement cost issues

While acknowledging that PV is not currently the least-cost form of abatement, few other initiatives inthe electricity industry have led to any significant abatement in the urgent timeframe in which it isneeded. PV is one of the few options successfully deployed over the past decade and over 570MW ofPV is now generating emissions free electricity across Australia every day. The Productivity Commissionhas taken an historical and ‘static’ view of the PV industry and PV prices for medium-scale systems arecurrently approximately half the prices quoted in the Productivity Commission report of $400 -$473/MWh. The cost of PV has been reducing at a consistent rate of 22% for each doubling of capacity,and is expected to continue to do so. Snapshot views of a rapidly expanding industry, such as thattaken by the Productivity Commission, especially when reliant on historical data, are simply unable totake these considerations into account. A more appropriate methodology for calculating PV'sabatement cost is given in Appendix A.

Regardless, though the abatement cost of PV is currently more expensive than some other methods,once grid parity is reached, which in many parts of Australia could be within five years10, the cost ofabatement for the system owner (on the basis that they pay the full cost of this system without anygovernment assistance) will be zero. After this time it will be negative.

Australia’s electricity has one of the highest emission intensities in the world so, even at past highuptake levels, PV contributes only a relatively small proportion of Australia’s total emission reductionrequirements. Nevertheless, it represents emission reduction at a time when electricity use, mainlyfrom coal-fired power stations, has continued to grow and when no commitment has yet been made toa carbon price. Whilst Australia has been discussing the potential role of emissions trading since thelate 1990s, nothing beyond some limited State Government efforts has yet been achieved. Meanwhile,PV, and renewables more generally, have undergone a near complete transformation in capabilities andcost effectiveness.

9IEA PVPS, 2009, Methodology Guidelines on Life Cycle Assessment of Photovoltaic Electricity, IEA-PVPS Report T12:01-

2009.

10APVA, 2010, Residential System Modelling of the Australian PV Sector, report for the Australian Solar Institute, shows that

grid parity is expected to be reached in about five years. This timeline is consistent with international reports, such as theNREL report ‘Break-Even Cost for Residential Photovoltaics in the United States: Key Drivers and Sensitivities’, which showedthat grid parity could be reached in many parts of the United States by 2015.

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Wider aims of PV support programs

The PV Rebate Program commenced in 2000 with the aims of:

i) Encouraging the long-term use of photovoltaic (PV) technology to generate electricity fromsunlight.

ii) Reducing greenhouse gas emissions.

iii) Assisting in the development of the Australian PV industry.

iv) Increasing public awareness of renewable energy.

The Renewable Energy Target aims were:

(a) to encourage the additional generation of electricity from renewable sources; and

(b) to reduce emissions of greenhouse gases; and

(c) to ensure that renewable energy sources are ecologically sustainable.

The NSW Solar Bonus Scheme was expected to provide:

a significant boost for renewable energy in NSW and

the potential to generate an additional 500 green jobs.

Similarly, other State Government FiT schemes cited local employment creation and increased localrenewable energy generation as key aims.

Summary of PV support outcomes

Over the past 10 years, PV support programs have been instrumental in changing the Australian PVsector markedly. Key outcomes include:

Contributed significantly to the increase in annual PV installations from less than 3 MW in1999 to 383 MW in 2010 and a corresponding increase in industry turnover from $67million in 1999 to $2.3 billion in 2010.

Installation of 400,000 PV systems accounting for 545 MW of PV generating capacity andresulting in a total installed capacity of 571 MW by end 2010.

Creation of an Australian market for grid-connected PV where previously only an off-gridmarket existed.

Generation of more than 700 GWh of electricity a year for 20 or more years.

Greenhouse gas abatement of more than 15 Mt CO2-e over 20 years and 20 Mt over 30years.

Establishment of industry standards, installer training programs and an accreditationsystem.

An increase in consumer awareness and acceptance of PV.

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Complementary support measures

Continued support is needed to transition PV to the point of grid parity, at which point it will be able todeliver cost-effective carbon abatement without subsidy. Internationally, the need is well recognisedfor measures complementary to a carbon price. Comprehensive analysis reveals that in order to reducethe total longer term cost of agreed-upon emissions trajectories (rather than the short-term staticcost), higher-cost abatement measures need early-stage support. The increased deployment thatresults from early stage-support lowers the price of technology deployment (due to learning-curveeffects), which lowers the eventual cost of abatement whilst avoiding the lock-in of technologies whoseabatement cost starts out low but becomes increasingly expensive when reducing emissions to zerobecomes necessary, such as the case may be for carbon-capture and storage from gas turbines11.Interestingly, technologies such as nuclear have a negative learning cure, with costs increasing as thesafety, risk and long term commitments become better understood12.

After a decade of support, Australia now has a competent, responsive, and competitive solar industry,capable of reducing purchasers’ electricity costs, with the beneficial side-effects of immediateemissions abatement and local employment. As a consequence, solar power prices are decreasing andgrid parity (when the levelised cost of PV electricity equals retail electricity prices), is expected thisdecade. When parity is reached, Australian households will enjoy the benefits of a highly-competitivesolar power industry offering affordable clean energy, without need for further subsidies. In themeanwhile, most large solar providers are offering financed-packages whose electricity price savingsare greater than repayments on system purchase – thus making solar affordable to all, even for thosewho can’t afford the up-front cost. And those households wise enough to take advantage ofgovernment support mechanisms to invest in solar power for their future are already enjoying far lowerelectricity bills.

The issues now facing the PV sector are caused by this successful acceptance and include, not just thesudden changes to support mechanisms, but increasing concern from the electricity sector, as PVreduces customer demand and hence retail revenue, and as increasing levels of distributed generationfed into electricity networks changes the way the electricity system needs to operate into the future.

11Cédric Philibert, 2011, “Interactions of Policies for Renewable Energy and Climate”, International Energy Agency, Working

Paper.12

Gruber, A., 2010, The costs of the French nuclear scale-up: a case of negative learning by doing, Energy Policy,doi:10.1016/j.enpol.200.05.003.

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APVA Conclusion

Thanks to the institutional capacity and market momentum created over the past decade by the variousPV capital cost, renewable energy certificate and feed-in tariff programs, PV remains one of the fastestgrowing renewable energy sectors in Australia. It is likely to reach an installed capacity of 4.5GW by2020 and to make up more than 10% of the Renewable Energy Target if appropriate policies are inplace. In fact, its very success has been the cause of several dramatic policy changes over recent yearsto reduce incentives.

The incentives provided through the various support programs enabled Australian households to investwisely for the future. Their investments will reap benefits for themselves and for Australia for 30 ormore years to come, at a time when some of the simplest energy efficiency measures, let alone anationwide emissions trading scheme, are still at the first hurdle.

Strategically placed, PV offers valuable generation capacity during peak summer cooling load periodswhen network infrastructure is strained. PV may not be calculated as the cheapest greenhouse gasmitigation option right now, but it is an important component of the mix of measures Australia needsurgently to adopt. The climate change challenge is not to reduce emissions modestly in the short-termthrough the most immediate and lowest cost abatement options. It is, instead, to fundamentallytransform the Australian electricity industry over the next 30 years towards near zero emissions. Thiswill almost certainly require a range of technologies, and significant technology innovation. Technologyinnovation requires societal investment. PV is one of the easiest generating technologies to deploy,especially in urban areas, and so is an essential component of longer term aims for net zero energybuildings while creating immediate building asset value. It is also increasingly being deployedinternationally for medium-scale power stations, an application likely to grow in Australia over the nextdecade and take the industry into the next level of development.

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Appendix A: A Common Method for Calculating Abatement Cost

The abatement cost of PV can be calculated by calculating the difference between a PV system’sLifetime Cost of Electricity (LCOE) and the retail electricity price then dividing it by the estimatedabatement. The LCOE approach assumes appropriate discount and interest rates (say 7% and 2.5%) andso reduces the future value of PV electricity and increases the abatement cost.

The cost of PV has been reducing at a consistent rate of 22% for each doubling of capacity. Twoyears ago the average system cost in Australia was about $12,000/kW (without rebates), whereas in2010 systems could be bought for $6,000/kW and in 2011 for as low as $5,400/kW (both again withoutrebates). These drops have occurred due to a combination of reduced PV module costs and innovativePV business models. Continued high growth in PV uptake rates internationally and a range of newproducts and technologies coming onto the market are expected to see ongoing price reductions. Retailelectricity Price Determinations already in place will see electricity prices increasing over the next threeyears and most likely continue to do so after that time.

As shown in Figure 3, as system costs halved between 2008 and 2010, and the price of electricityincreased, the cost of abatement dropped significantly – reaching around $90/tonne CO2-e to$95/tonne CO2-e depending on the installation location. The combination of PV price reduction and gridelectricity price increases mean that PV electricity in Australia is likely to be the same price as retailelectricity within the next 5 or so years - this is known as grid parity. At this point, the abatement costfor the PV system is zero. After this point, the abatement cost is negative. It is for this reason thatGovernments around the world are providing support to expand the PV market.

Figure 3 also shows some possible abatement costs out to 2020, for Qld, NSW and Vic.13 Theseprojections are only approximate and will be influenced by a number of factors that affect both theinstalled cost of PV and electricity prices (which vary within each state and include flat, stepped andvarious types of TOU tariffs). Nonetheless, it can be seen that the abatement costs have declinedsignificantly in the last few years, and are predicted to continue to do so, albeit at a slower rate.

This grid parity timeline is consistent with international reports which showed that grid parity couldbe reached in many parts of the United States by 2015, although there was significant variationbetween regions due to differences in electricity prices, solar insolation levels and financing options.14

13These abatement costs are for the full system cost (no government rebates or FiTs etc). They are calculated by

subtracting the relevant retail electricity rate from the levelised cost of PV electricity, then dividing that by the emissionsintensity of the avoided electricity. The projected retail tariff is based on price determinations where known then onreasonable increases based on industry projections and historical trends. The levelised cost of PV electricity is based onprojections of system costs into the future. The emissions intensity of avoided electricity is derived from ANAO (2010)Administration of Climate Change Programs, by the Australian National Audit Office, Commonwealth of Australia. A price onGHG emissions is not included, and would increase the cost of avoided electricity and so reduce the abatement cost.

14NREL (2009) Break-Even Cost for Residential Photovoltaics in the United States: Key Drivers and Sensitivities, National

Renewable Energy Laboratory, US Department of Energy

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Figure 3 PV Abatement Costs to 2011 and Projections to 2020

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Attachment B: Background on the APVA

The APVA is an association of companies, government agencies, individuals, universities and researchinstitutions with an interest in solar photovoltaic electricity. In addition to Australian activities, weprovide the structure through which Australia participates in an International Energy Agency (IEA)programme called PVPS (Photovoltaic Power Systems), which in turn is made up of a number ofactivities concerning PV performance and implementation. Further information is available fromwww.apva.org.au.

APVA Objective

The objective of the Australian PV Association is to encourage participation of Australianorganisations in PV technology and industry development, policy analysis, standards and accreditation,advocacy and collaborative research and development projects concerning photovoltaic solarelectricity.

APVA membership provides:

Information

Up to date information on new PV developments around the world (research, productdevelopment, policy, marketing strategies) as well as issues arising

Access to PV sites and PV data from around the world

International experiences with strategies, standards, technologies and policies

Australian PV data and information

Standards impacting on PV applications

Networking

Access to international PV networks (PV industry, government, researchers) which allow personalrelationships to develop and can be invaluable in business, research or policy development orinformation exchange generally

Opportunity to participate in international projects, with associated shared knowledge andunderstanding

Opportunity to meet regularly and discuss specific issues which are of international, as well as localinterest. This provides opportunities for joint work, reduces duplication of effort and keepseveryone up to date on current issues.

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Marketing Australian Products and Expertise

Opportunities for Australian input (and hence influence on) PV guidelines and standardsdevelopment. This ensures both that Australian products are not excluded from internationalmarkets and that Australian product developers are aware of likely international guidelines.

Using the information and networks detailed above to promote Australian products and expertise.

Working with international network partners to further develop products and services.

Using the network to enter into new markets and open new business opportunities in Australia.

The International Energy Agency PV Power Systems Programme (IEA PVPS)

One principal activity of the APVA is to manage Australian participation in the PVPS Programme.This work is arranged by Tasks, each with its own commitments of time and resources. Support isprovided by the Australian Solar Institute. At present Australia participates in:

Task 1: PV Information Exchange and Dissemination

Task 11: PV Hybrid Systems within Mini-grids

Task 14: High Penetration of PV in (Smart) Electricity Grids

and maintains an interest in:

Task 8: Very Large-Scale PV Systems

Task 9: PV in Developing Regions

Task 13: PV System Performance

For further information on the Australian PV Association visit: www.apva.org.au

For further information on the IEA PVPS Programme visit www.iea-pvps.org.