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. Indeed, there are now a number of large-scale solar farms investments in Australia including the 155MW Broken Hill and Nyngan solar farms, developed by AGL Energy Limited; see AGL Energy Limited, Broken Hill (accessed 4 November 2017) . Also, the 148MW Ross River solar farm, developed by ESCO Pacific; see Ross River Solar Farm, Ross River Solar Farm (accessed 4 November 2017) < http://rossriversolarfarm.com.au/>.

116^ See AGL Energy Limited, Renewable Energy (accessed 4 November 2017) ; see also AGL Energy Limited, Powering Australian Renewables Fund (accessed 4 November 2017) <https://www.agl.com.au/about-agl/what-we-stand-for/sustainability/powering-australian-renewables-fund>.

117^ For example, Hydro Tasmania has a long and successful track record of developing renewable projects either through joint ventures, such as the Roaring 40s, or via direct investment; see generally Hydro Tasmania, Agreement on End to Roaring 40s Joint Venture (accessed 4 November 2017) <https://www.hydro.com.au/about-us/news/2011-04/agreement-end-roaring-40s-joint-venture>; Hydro Tasmania, Musselroe Wind Farm (4 November 2017) .

118^ Origin Energy Limited, ‘Origin Adds 530MW of Renewable Energy to its Portfolio, Sets New Benchmark for Renewable PPA Pricing’ (Media Release, 8 May 2017) 1 < https://www.originenergy.com.au/about/investors-media/media-centre/origin-adds-530mw-of-renewable-energy-to-its-portfolio.html>; see also Energy Australia, ‘New PPA Signed as Renewables Program Underpins 500MW of Capacity’ (Media Release, 20 July 2017) .

119^ This is excluding potential financing available from the Clean Energy Finance Corporation (‘CEFC’), which will be considered in detail in Part IV(C) below.

120^ For example, the credit ratings of the private sector transmission networks are as follows: Ausnet Services, A- (S&P) (Ausnet Services, Half Year 2018 Results (15 November 2017) 34); ElectraNet, BBB+ (S&P) (ElectraNet, Ownership and Governance (accessed 27 December 2017) ); TransGrid, Baa2 (Moody’s) (Spark Infrastructure, Investor Day with TransGrid – TransGrid Management Briefing (1 December 2016) 31).

121^ Cheuk Wing Lee and Jin Zhong, ‘Top Down Strategy for Renewable Energy Investment: Conceptual Framework and Implementation’ (2014) 68 Renewable Energy 761, 770. Also, the CCA acknowledged the importance of PPA arrangements in obtaining debt financing, see CCA RET Review, above n 84, 31.

122^ A high level review of the CPM is undertaken in Part V below.

123^ Coalition Government, The Coalition's Direct Action Plan (accessed 17 December 2017) .

124^ Australian Government, Department of the Environment and Energy, Emissions Reduction Fund (accessed 17 December 2017) < http://www.environment.gov.au/climate-change/government/emissions-reduction-fund>.

125^ Carbon offsets are defined as the ‘reductions in emissions … relative to a counterfactual reference case, which can be used to compensate for emissions from another source’; see generally, Andrew Macintosh and Lauren Waugh, ‘An Introduction to the Carbon Farming Initiative: Key Principles and Concepts’ (2012) 29 Environmental and Planning Law Journal 439, 440-50, for a detailed review of the theory of offsets and the key principles of the CFI. Under the CPM, emissions from agriculture, forestry, land use were not included in the scheme due to the diffuse nature of the sector and the high administration costs associated with those sectors. Thus, the CFI was developed to assist with decarbonising these sectors; see also Jonathan Verschuuren, ‘Towards Regulatory Design for Reducing Emissions from Agriculture: Lessons from Australia’s Carbon Farming Initiative’ (2017) 7 Climate Law 1, 14.

126^ Gunningham and Bowman, ‘Energy Regulation’, above n 81, 23.

127^ For details regarding the modification of the CFI scheme to implement the ERF, see generally, Martijn Wilder and Matthais Thompson, ‘Falling Behind: Consequences of Australia’s New Approach to Climate Policy’ (December 2014) Australian Environment Review 295; see also Verschuuren, above n 125, 14-35.

128^ CFI Act ss 27(4A)(a)-(c) for the ‘additionality requirements’. For further discussion on risks associated with a relaxation of additionality criteria, see Karen Bubna-Litic and Natalie Stoianoff, ‘Carbon Pricing and Renewable Energy Innovation: A comparison of Australia, British and Canadian Carbon Pricing Policies’ (2014) 31 Environmental and Planning Law Journal 368, 381; see also Macintosh and Waugh, above n 125, 450-451.

129^ CFI Act ss 106(4), 114(7A), 123A.

130^ CFI Act s 20G(3); see also, Australian Government, Department of the Environment, Emissions Reduction Fund Green Paper (December 2013) 29