Consultation package for the solar panel serial number ...



Clean Energy Regulator consultationSolar panel serial number ledger – proposed data upload mechanism and data formatThe Clean Energy Regulator (the agency) is developing a new serial number ledger (the ledger) capability, to strengthen the integrity of the Small-scale Renewable Energy Scheme (SRES) and the solar industry. The ledger is scheduled for implementation in early 2021. Further information regarding the ledger may be found at our website.In readiness for the roll out of the ledger, the agency is conducting a consultation with stakeholders about the co-design of the ledger. We are seeking feedback from Australian manufacturers and importers of solar panels on the Clean Energy Council’s (CEC) approved PV module list and verification services participating in the solar panel validation (SPV) Initiative. Specifically, the agency would like your input on two key aspects of the ledger: the proposed data upload mechanism and the data format for which serial number data will be uploaded to the ledger.The proposed data upload mechanism and data format outlined in this document has been developed using a principles-based approach to leverage existing agency systems, solar panel validation (SPV) processes, existing manufacturer/importer data holdings and technology and automation (where possible) to reduce industry burden.Ledger overview – who will participate?The agency’s ledger will hold serial number data sourced only from Australian manufacturers/importers of solar panels on the CEC approved PV module list. The agency will not source serial number data from overseas entities including solar panel certificate holders that do not have an Australian business number (ABN).For those Australian manufacturers/importers that are not participating in the SPV initiative, the agency will be requesting your serial number data according to your existing obligations under the CEC approved PV module listing terms and conditions. Specifically, condition 28 of the CEC’s approved solar PV module listing terms and conditions requires you to keep records of the serial numbers of all modules supplied to the Australian market and make them available as required by the agency and the CEC. For those providing serial number data via SPV, the agency will collect your data directly from SPV verification service providers. The agency will also provide SPV verification service providers with serial number data that represents solar panels as ‘installed’ after the agency’s processing and validation of small-scale technology certificate (STC) claims. It is expected that eligible solar panel serial number data provided to the agency’s ledger will come as product enters Australia and with the confirmation that the serial numbers represent solar panels that are eligible for STCs and meet the terms and conditions for listing modules on the CEC approved PV module list. Australian manufacturers/importers of solar panels on the CEC approved PV module list have the option to work with an SPV verification service or provide your serial number data directly to the agency. Proposed data upload mechanismData uploaded by Australian manufacturers/importersThe agency proposes two mechanisms to be available to Australian manufacturers/importers when providing serial number data to the agency’s ledger. We propose one of two options:Client portalThe agency will enable Australian manufacturers/importers to establish, set up and access the agency’s Client Portal and REC Registry and provide business and contact details in order to upload serial number data. The agency proposes that Australian manufacturers/importers use an interface in the agency’s REC Registry when uploading serial number data and to upload data at a minimum of once a month or as soon as solar panels enter the Australian market.Application programming interface (API)The agency will make available a uniform resource locator (URL) to an API that will pull serial number data from Australian manufacturers/importers to the ledger. This will include enabling a nominated representative of an Australian manufacturer/importer to facilitate serial number data uploads via API.The agency proposes that Australian manufacturers/importers provide serial number data to the agency’s ledger via API at a minimum of once a month or as soon as it is made available to the Australian market.Data uploaded by SPV verification services acting on behalf of Australian manufacturers/importers The agency proposes one mechanism to be available to SPV verification services, for data they hold on behalf of Australian manufacturers/importers participating in SPV, when providing serial number data to the agency’s ledger:APIThe agency will make available a uniform resource locator (URL) to an API that will pull serial number data from SPV verification services. This will include enabling a nominated representative of an SPV verification service to facilitate serial number data uploads via API.The agency proposes that SPV verification services provide serial number data to the agency’s ledger as soon as it is made available to industry as part of the SPV Initiative at a frequency consistent with data it receives from manufacturers/importers it works with.The agency also proposes to provide verification services with ‘installed’ serial numbers (after the agency’s processing and validation of STC claims) via API and automated messages (webhooks). The agency will engage with SPV verification services separately to explore how this activity may be conducted.Data assuranceThe agency will, for ledger data assessment purposes, cross reference Australian manufacturer/importer business details with CEC data regarding Australian manufacturers/importers of solar panels on the CEC approved PV module list. This activity ensures only authorised Australian manufacturers/importers provide data to the agency’s ledger (and therefore only eligible solar panel serial numbers are provided to the ledger).The agency expects a declaration be made by Australian manufacturers/importers each time they upload serial number data to the ledger. The declaration will include a statement that the solar panels associated with the serial number data uploaded meets the terms and conditions for listing on the CEC approved module list and therefore meets eligibility requirements for STCs under the SRES. Declarations are also expected to be made by SPV verification services including a statement that data is unaltered except where directed by SPV participating manufacturers/importers.The agency proposes to allow Australian manufacturers/importers to de-activate (not delete) a serial number at any time after uploading data to the agency’s ledger and prior to the serial number being validated by the agency (via the REC Registry) as part of a validated STC claim. This would assist Australian manufacturers/importers to amend the status of serial numbers in case of administrative errors when initially uploading data on solar panels intended for the Australian market.Proposed data formatData from Australian manufacturers/importersThe agency proposes to collect the following information from Australian manufacturers/importers not participating in SPV and SPV verification service providers acting on behalf of Australian manufacturers/importers.Solar panel dataDescription Licence/certificate holder namename registered with the CEC for panels on the CEC approved PV module listSolar panel modelmodel registered on the CEC approved PV module list and associated with the Licence/certificate holder nameSolar panel model serial numberserial number associated with the solar panel model registered on the CEC approved PV module listThe agency proposes that Australian manufacturers/importers and SPV verification services provide data to the agency in one of two ways:include the above data in an Excel spreadsheet or .csv file when uploading to the ledger via the proposed Client Portal and REC Registry.include the above data when uploading to the ledger via the proposed agency API.The agency’s collection of the above data assumes we will be able to identify the source of the serial number data via the proposed data mechanisms (Client Portal, REC Registry and API). The agency anticipates developing guidance regarding the data format in preparation for uploading it via REC Registry or API.Submission instructionsSubmissions are due by 5:00pm EST, Friday 22 January 2021. Any submissions received after this date will be considered at the agency’s discretion. It is preferred that submissions be submitted using the below feedback form and sent electronically to the below email address. Submission email address: cer-solarpanelvalidation@.auConfidentiality and privacyThe agency will deal with personal information contained in, or provided in relation to, submissions in accordance with the agency’s privacy policy. Feedback form – ledger consultationContact detailsName of organisationContact personRolePhone numberEmailDo you want this submission to be treated as confidential? FORMCHECKBOX Yes FORMCHECKBOX NoFeedbackHow would you best describe your business?[e.g. Non-Australian business/overseas solar panel manufacturer, Australian local manufacturer/importer, SPV verification service, SRES participant]What implications do you see for your business with the agency’s proposed data upload mechanism for the ledger?Do you have an alternative to the agency’s data upload mechanism you’d like to convey?What implications do you see for your business with the agency’s proposed data format to the ledger?Do you have an alternative to the agency’s proposed data format you’d like to convey?If you are an Australian manufacturer/ importer of solar panels on the CEC approved PV module list – would you consider participating in SPV if you are not now?If you are an Australian manufacturer/importer of solar panels on the CEC approved PV module list – how often would you have new product made available to the Australian market (i.e. monthly, weekly)?Do you have other feedback you’d like to provide? ................
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