Policy submission

The missing middle is holding back Australia's electrification

The AEMC self-initiated the Electricity Network Regulation Review to test whether the economic regulation of electricity networks is still fit for purpose as the system transitions. Public EV charging, neighbourhood batteries and paddock solar are too big to plug in like a house and too small for a bespoke connection campaign. Our submission sets out how to fix the connection process that is holding them back.

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Connection process gaps

The problem we're solving

Look at the transition by project size and a gap opens up in the middle. The two ends are catered for. The scale that the next phase depends on is not.

Small - Under 100KW

The household layer is scaling fine

Rooftop solar, home batteries and home EV chargers connect under standard arrangements. From a network perspective this layer is broadly efficient, and uptake is growing quickly.

Middle - 100KW - 5MW

The "energy farmer" tier has no process built for it

Public EV charging, neighbourhood batteries and warehouse, barn and paddock solar are too big to plug in like a house and too small to justify a bespoke connection campaign. Distribution planning does not cater for them.

Large - Above 5MW

Utility scale has a process, frictions and all

Big projects get bespoke project management and dedicated connection teams. It is slow and expensive, but there is a defined path and it eventually lands them.

Mid-scale projects face a process built for neither end — slow, firm-by-default, augmentation-gated and opaque. Developers report twelve to eighteen months of connection lead time, much of it bespoke manual study for what are highly repeatable projects. The recently finalised distribution planning reforms help networks document the future, but do not change what they deliver.

Policy

What we're recommending

Five changes the Commission can make in Package 1 so that mid-scale distributed energy gets built in far greater volume, far faster.

01

Make mid-scale connections fast and standard

A sub-5MW solar-and-storage project or kerbside charger should connect through a standardised, largely automated assessment in weeks — not twelve to eighteen months of bespoke study.

02

Measure connection performance publicly

Volumes, timeframes against standard, firm versus non-firm. Networks cannot be held to a connection standard no one measures.

03

The network's job is the powerpoint, not the appliance

Networks provide and are accountable for connection, access, data and coordination. The market competes in the services on top.

04

Make open network data a duty, not an encouragement

Low-voltage hosting-capacity maps and pole-suitability data, published for everyone at once.

05

Carry pace of connection through the framework

Make it an explicit lens in the prioritisation framework and assessment criteria.

Download

Submission to ENRR Package 1 and related rule change requests

Our full response to the AEMC, judging the framework by one test: does it help Australia electrify and decarbonise faster? Covers connection and facility access reform, the services question, and what open network data should be required. Five recommendations to the Commission, drawing on the AER's 2025 export services report. 5 pages, PDF, free to share.

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