Source
https://www.farmgen.co.nz — original source (opens in a new tab; the file is not redistributed)
Farmgen Solar — EA rebate / “definition of small business” submission (REG_026)
Advocacy source — operator field data submitted to move a regulatory threshold
This is Farmgen Solar’s stakeholder submission to the Electricity Authority’s “definition of small business” consultation — the eligibility limb of the same Task Force 2A rebate reform enacted in REG_005. Farmgen argues the proposed 45 kVA connection / 45 kW DG thresholds wrongly exclude dairy and irrigation farms, and lobbies to raise them. Every number below is Farmgen’s own, advanced to win that argument.
data_quality: verifiedrecords that the numbers were read verbatim from the primary document, not that they are independently audited. Use as operator field claims, weighted accordingly.
Summary
Farmgen Solar Limited (Managing Director Matt Luscombe) deploys ground-mount solar + battery systems across dairy, horticulture, rural SMEs and irrigation, and states it analyses over 100 operating farms annually. Its submission to the EA’s rebate/“small business” consultation contends the proposed 45 kVA / 45 kW DG eligibility thresholds exclude the rural customers with the strongest distributed-energy business case. In making that case it discloses a body of farm-scale solar+BESS field economics — self-consumption fractions, payback periods, typical system configurations, and load shapes — that is directly relevant to the NI energy model’s treatment of a productive-load (farm) community as distinct from a residential one. This is the operator referred by an interviewee (Interview VIII [INT_008]) under RT_266.
Key claims
- claim: "Farmgen states it 'analyses over 100 operating farms annually and deploys ground-mount solar + battery infrastructure across dairy, horticulture, rural SMEs, and irrigation.' The submission's figures are drawn from this >100-farm dataset. (Establishes the evidence base and its self-reported scale.)"
source_location: "p.4, 'Farmgen analyses over 100 operating farms annually…'; also Executive Summary p.3"
- claim: "Farm-scale solar+BESS payback is roughly TWICE as good as residential: 'Payback periods of 3.5–6 years vs 10–15 years for residential.' Farmgen attributes this to rural loads being 10–20× domestic loads, long operating hours, and tight alignment with solar output."
source_location: "p.4, §2 'Rural loads are 10–20× domestic loads, giving ~2× stronger solar economics'"
- claim: "Solar self-consumption on farms: '50–75% solar self-consumption without batteries' and '80–100% self-consumption with moderate batteries (100–215 kWh).' (High self-consumption is the driver of the farm payback advantage; contrast residential where self-consumption is far lower.)"
source_location: "p.4, §2 bullets"
- claim: "The natural rural DG configuration is a '50 kW inverter paired with 75-90 kWp of solar and 100–215 kWh of storage.' Farmgen's sales data shows '50 kW systems outsell 25 kW systems by approx. 10:1' — so farm-scale DG naturally sits in the 50 kW–100 kW band."
source_location: "p.4, §3 'Farm-scale DG naturally falls in the 50 kW–100 kW band'; restated p.6 Q5"
- claim: "Rural businesses have 'superior access to green capital (4–6% sustainability-linked loans),' which Farmgen argues makes 'rural DER the cheapest form of electrification in New Zealand.' (A financing-cost input — cheaper WACC than the community-scale 7–9% in CR_024.)"
source_location: "p.4, end of §2"
- claim: "Dairy load shape (across >100 farms): 'Morning peak: 20–50 kW (5–9 am)' and 'Evening peak: 20–50 kW (3–8 pm)', 'consistent year-round and aligns perfectly with national system peaks.'"
source_location: "p.4, §1 'Dairy farms produce the largest mass-market coincident peak load'"
- claim: "Dairy connection sizes 'often 63–100 kVA'; irrigation connections '100–200 kVA'. These sit above the proposed 45 kVA eligibility threshold — Farmgen's core exclusion argument."
source_location: "p.6, Q4 response"
- claim: "Irrigation loads: 'Medium irrigation systems draw 80–150 kW; large pivots draw 150–250 kW.' Typical irrigation DG systems 'involve 50–200 kW DG capacity and solar arrays of 100–250 kWp with export limiting.' Irrigation is 'the primary cause of rural feeder upgrades, voltage issues, transformer overloading, and protection changes.'"
source_location: "p.5, 'Why Irrigation Must Be Included' §1 and §4"
- claim: "Irrigation lines-charge burden: 'irrigation customers often pay 40–60% of their electricity bill in lines charges—due to long feeders, low density, and heavy summer peaks.' (Quantifies the remoteness/cost-to-serve premium NI models as the network cost of a remote rural site.)"
source_location: "p.5, 'Why Irrigation Must Be Included' §2"
- claim: "Farmgen characterises irrigation as SHIFTABLE and NOT continuous: irrigation cycles are 'seasonal, block-based rather than continuous, discretionary within day-time windows, strongly aligned with mid-day high solar output', and 'Farmgen has not observed a single site running continuously 24/7 for an entire month.' With solar+BESS, irrigation can 'avoid morning/evening peaks and reduce feeder load by 50–200 kW.' ⚠ This CONTRADICTS int_008 (an interviewee: his frost/irrigation pump 'runs 24/7, not daytime-shifted') — see NI relevance."
source_location: "p.5, 'Why Irrigation Must Be Included' §3"
- claim: "The consultation's proposed eligibility thresholds under challenge are '45 kVA connection capacity and 45 kW DG limit'; the existing small-business definition is '<40 MWh'. Farmgen recommends raising the connection threshold to 69–100 kVA, the DG limit to at least 100 kW, allowing export-limited arrays to 150–250 kWp, and defining mass-market by bargaining power rather than kVA size. (Records the regulatory context — not Farmgen's own field data.)"
source_location: "Executive Summary p.3; Farmgen Recommendations p.5; Q1/Q4/Q5 pp.6"Neobiome Intelligence relevance
This is a productive-load (farm) counterpart to the residential solar/battery economics already in the model. The wiki’s PV+battery cost and self-consumption figures (CR_008, CR_024, OT_070, URL_010/011) are residential/community-scale. Farmgen supplies the farm segment, where the economics are structurally different:
| Parameter | Residential/community (existing wiki) | Farm-scale (Farmgen, this source) |
|---|---|---|
| Solar payback | 10–15 yr (residential) | 3.5–6 yr |
| Self-consumption (no battery) | low (12–44%, OT_061) | 50–75% |
| Self-consumption (with battery) | — | 80–100% (100–215 kWh) |
| Typical DG config | 3–7 kWp | 50 kW inverter + 75–90 kWp + 100–215 kWh |
| Financing (WACC) | 7–9% community (CR_024) | 4–6% sustainability-linked |
The mechanism Farmgen names — high self-consumption from a large, long-hours daytime-coincident load — is exactly why a community with a productive/agricultural load should be modelled with better solar economics than a residential-only community. This corroborates the NI thesis that on-site productive load improves self-sufficiency economics, and gives a farm-segment payback anchor (3.5–6 yr) to sit alongside the community-microgrid LCOE benchmarks.
⚠ Direct conflict with int_008 (an interviewee) on irrigation duty cycle: a calculation-relevant contradiction
Farmgen states irrigation is shiftable, block-based, day-time-windowed, and “never observed running 24/7 for a month” (p.5). An interviewee (Interview VIII [INT_008]), who referred Farmgen, told the opposite in interview: his irrigation/frost pump runs 24/7, not daytime-shifted — a challenge that reverted an earlier model calibration (pump = 24/7 base load, not solar-matched). The two are not necessarily incompatible: An interviewee runs a cherry orchard with frost protection (an involuntary, weather-triggered, night-heavy load), whereas Farmgen’s dataset is dominated by dairy and pasture/pivot irrigation (a schedulable, day-shiftable load). But the disagreement is load-bearing for the engine: whether an agricultural load is treated as solar-matchable (Farmgen) or as an inflexible base load (an interviewee) changes the battery-sizing and self-consumption result. Do not adopt Farmgen’s “irrigation is shiftable” as a general rule — it holds for dairy/pivot irrigation, not for frost protection. Flag as a segment-dependent assumption.
How to weight these figures
Every number is Farmgen’s own, submitted to raise a regulatory threshold in its commercial favour — advocacy field data, not audited or peer-reviewed. Treat the payback (3.5–6 yr), self-consumption (80–100%), and financing (4–6%) figures as operator claims requiring independent corroboration before they drive an NI output. The value here is (a) directional (farm economics ≫ residential), (b) a plausible config anchor (50 kW / 75–90 kWp / 100–215 kWh), and (c) the network cost-to-serve signal (irrigation lines charges 40–60% of bill), which supports NI’s remoteness-premium logic.
Research targets
Documents to retrieve
- RT_266 remains OPEN (partially advanced). This source identifies the operator (Farmgen Solar / Matt Luscombe) and supplies field data, but the RT’s two other limbs are unmet: (1) the automatic farmer solar site-analysis tool (the direct NI-engine comparator) is described nowhere here and still needs retrieval/demo; (2) a primary interview with Farmgen (the founder offered to broker) has not occurred. Keep RT_266 open, annotate as advanced → REG_026.
Research gaps
- RT_366 (new, gap): independent/audited NZ farm-scale (dairy + pivot irrigation) solar+BESS payback and self-consumption benchmark, to corroborate Farmgen’s self-reported 3.5–6 yr payback and 80–100% self-consumption before either is used in an NI calculation. Farmgen’s figures are advocacy-grade; no peer-reviewed or metered farm-scale NZ counterpart is yet in the corpus (the closest, Totarabank/Great Barrier LIT_031/032, are residential-community scale).
Notes
Primary — Farmgen Solar’s own EA consultation submission, read verbatim (7-page PDF: cover email + 5-page submission). data_quality: verified on the read, not on the empirical reliability of the figures (see the warning callout). Author is Matt Luscombe, Managing Director, Farmgen (“Matt Luskin” in RT_266 / int_008 is a spelling of the same person). Submitted 24 Nov 2025 to TaskForce@ea.govt.nz; cc Geoff Neal and Jamie Litt (FarmGen). The document responds to the “definition of small business” limb of the EA rebate reform whose decision paper is REG_005 — cross-linked. Referral chain: An interviewee (Interview VIII [INT_008]) → RT_266.
⚠ Not recorded here: Farmgen’s national extrapolation from its dairy load shape (an estimate that ~11,000 dairy farms give ~300 MW of coincident mass-market peak load, around 15% of New Zealand’s total system peak, stated in the Executive Summary p.3) is omitted as an un-auditable advocacy extrapolation. The measured field data is retained: morning peak 20–50 kW (5–9 am), evening peak 20–50 kW (3–8 pm), consistent year-round, aligns with national system peaks.
⚠ Currency: a live consultation submission (Nov 2025); the EA’s final thresholds may differ from the 45 kVA / 45 kW DG proposal Farmgen contests. Re-confirm the enacted eligibility definition before relying on the threshold numbers.
Connections
Links to
Sources (1): REG_005
Referenced by
EDT domains (1): D01: Renewable Energy & Storage Systems