A crackdown on installers cutting corners when claiming STCs serves as a reminder of installers’ and designers’ responsibilities, writes Clean Energy Council risk and governance coordinator Leanne Nichols.
The Clean Energy Council was recently provided with evidence of accredited installers signing false declarations on the paperwork required in order to claim Small-scale Technology Certificates (STCs).
By falsely declaring that they either physically installed systems or were physically on site to supervise the installation of systems when travelling overseas, 33 installers have had their CEC accreditation cancelled this year, with further investigations ongoing. These installers may also be subject to action by the Clean Energy Regulator and the registered agents who created the STCs.
As a result of these developments, now is a good time to remind installers and designers of their obligations when claiming STCs.
More than just paperwork
By signing the STC paperwork – STC Assignment Form, written statements and electrical safety certificate – installers and designers are declaring that the installation complies with all relevant Australian Standards, state and territory regulations, grid-connection requirements and the CEC Guidelines as well as confirming the modules and inverters installed were approved by the CEC at the time of installation.
Providing false or misleading information on the paperwork required for STC creation contravenes the Renewable Energy (Electricity) Act 2000 and can result in prosecution for fraud.
Individuals and companies are responsible for their conduct and blaming administrative or clerical errors may not protect installers, designers or registered agents from the consequences of their actions.
Where an installer is subcontracted by a retailer and is asked to sign off as the designer of the system on the STC paperwork, the installer is declaring that the design of the system also complies. In these circumstances, it is important that the installer is given the opportunity to either redesign the system or not take on the job if the system design is not compliant.
The CEC understands that this can be a difficult situation for installers and recently engaged a leading law firm to prepare a template Solar Subcontractor Agreement to provide installers with some protection against under-quoting and necessary on-site changes to installations.
On site means on site
In order to comply with section 6.1 of the CEC Install and Supervise Guidelines, installers must either physically undertake the installation or supervise the installation by physically attending the site at least three times during installation, including at commencement, mid-installation and for testing and commissioning. Reviewing photographs or videos from another location is not regarded as attending the site.
Section 6.2 of the CEC Install and Supervise Guidelines limits the number of new installations an installer can sign off on to two per day. Under certain circumstances, a formal exemption may be sought from the CEC prior to the commencement of the installations for the purposes of STC creation.
To protect against fraudulent use of CEC accreditation, installers should never advertise or display their accreditation number and should notify the CER and the CEC immediately after becoming aware of suspicious activity relating to their accreditation.
Before signing the system owner’s declaration on the STC Assignment Form, system owners should ask to see an installer’s digital identification for verification.
Dodgy work will be found out
Under the Small-scale Renewable Energy Scheme (SRES) the CER undertakes random inspections of systems for which STCs have been claimed to ensure that the installation requirements have been met.
Following an inspection, a draft report is prepared and sent to the installer who is given 14 days to respond. Installers are encouraged to use this time to respond to the report and their comments are taken into consideration when the CEC receives and assesses it. If an installer returns to site during this period to rectify, it is highly recommended that photographic evidence be taken which can then be provided to the CEC as proof of rectification once the final report is prepared.
The final inspection report is then provided to the system owner, the registered agent, system designer and installer, the CEC and state or territory electrical and building regulators.
Reports of non-compliant installations received by the CEC are allocated demerit points and installers may be required to return to site to rectify and/or undertake additional training through online assessments. As the installer has signed a declaration on the STC paperwork confirming the system was compliant at the time of installation, demerit points are allocated regardless of whether rectification is subsequently completed.
Installers are required to undertake substantial additional training and are required to complete 100 CPD points per year to maintain their accreditation and to ensure they remain up to date with the numerous changes to Australian Standards and CEC Guidelines, so it is important to respect, protect and value accreditation.
The CEC technical team is available to answer any questions installers may have in relation to Australian Standards and the CEC Guidelines. Each member of the team holds accreditation and has an intimate understanding of the complexities and difficulties installers face. Questions on STC eligibility can be directed to the CER. Information can also be found on the CEC and CER websites.
Leanne Nichols is a risk and governance coordinator at the Clean Energy Council.