The Policy Update Overview

A revised policy surrounding Power Station Applications for the purpose of creating LGCs has been released by the Clean Energy Regulator (CER) this week.

This policy impacts the manner in which information must be conveyed from site stakeholders to Ecovantage, and the requirements for Ecovantage to lodge Power Station Applications with the CER.

In the past, we have divided information gathering into three steps

1. Form 1 Placeholder – Lodged immediately on contract signing. This set the ‘accreditation date’ for LGCs to be backdated to once the application was approved.
2. Form 2 Primary Information – The majority of information required, excluding only commissioning documentation. Lodged on receival from site.
3. Form 3 Commissioning Documentation – Lodged on receival from site to close the application for approval.

The revised policy will alter this process in four ways

1. Applications can only be lodged when all information included in Form 1 and Form 2 is present, and Form 3 where a site has been commissioned. This is referred to as a ‘properly made’ application. The lodgement of Form 1 Placeholder, is not deemed to be a properly made application.
2. The ‘accreditation date’ is now set as the date an application is deemed to be properly made, or the date the site starts generating – whichever is later. In summary, for not yet commissioned sites, this is the date of first generation. For already commissioned sites, this is the date a complete application is lodged.
3. Incomplete applications will be denied, and reapplication must be made. Therefore, Ecovantage will not lodge an application until all information is available.
4. Requests for Information must be provided and submitted within 10 calendar days from the date of request. Should this timeframe not be met, the application may be withdrawn by the CER.

What Does This Mean For New Applications?

For new applications, this means the former three form process, is now separated into two processes, depending on whether your site has been commissioned, or is in the process of being commissioned. We recommend that you begin the LGC process well in advance of a site commissioning, to ensure adequate time is allowed for all information to be gathered and submitted to Ecovantage.

Beginning the LGC process immediately following the contract being signed between the site and EPC will ensure that a properly made application is lodged prior to commissioning, therefore setting the accreditation date and safeguarding all generation to create LGCs.

Once an application has been submitted, Ecovantage will allocate a 10 calendar day timeframe for information to be provided should an RFI be raised. The date that this information is due will be provided to you by your project compliance manager for all requests. This will also assist in fast-tracking the application process.

What Does This Mean For Existing Applications?

Rest assured that any existing Power Station Applications will not be impacted by the above changes to the accreditation date. The single element impacted will be for future RFIs. Your project compliance manager will request a response within 10 business days, where the due date will be detailed in their request.

Our New Processes

Our primary processes are as follows:

For Sites To Be Commissioned

1. Site proposal is signed. Followed by the delivery of a contract, and a list of  required information from the EPC and site representative.
2. All information is delivered to Ecovantage prior to site commissioning, excluding commissioning documentation.
3. Ecovantage lodges a properly made application, where the accreditation date is set.
4. Should any RFIs be raised, a response is required within 10 calendar days.
5. Commissioning documentation is provided once available to finalise the application for approval.
6. The application is approved, and LGCs are created from the date of first generation.

For Sites Already Commissioned

1. Site proposal is signed. Followed by the delivery of a contract, and a list of  required information from the EPC and site representative.
2. All information is delivered to Ecovantage, including all commissioning documentation.
3. Ecovantage lodges a properly made application, where the accreditation date is set. Generation prior to this date is not eligible to create LGCs.
4. Should any RFIs be raised, a response is requested within 10 calendar days.
5. The application is approved, and LGCs are created from the accreditation date.

Risk Mitigation Measures

We understand the extent to which this policy update will impact your internal processes. We provide the following guidance as risk mitigation, to ensure we work together to safeguard all generation to create LGCs.

1. Begin the application process with Ecovantage concurrently with contract signing.
2. Gather all necessary documentation and information per Ecovantage’s forms a minimum of 4-6 weeks prior to a site commissioning.
3. Ensure that all requests for information are responded to within 10 calendar days.
4. Request guidance or support at any time from your project compliance manager. They will assist you in clarifying the information required, to ensure a smooth process.
5. Request a project commencement meeting where needed. Our team is here to support you through the process, and often a project commencement meeting with your account manager and compliance manager can assist with breaking down the information needed and answering any questions you may have.

For any questions, queries or concerns in relation to the updated policy and requirements, please reach out to our team directly.

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