Yes, speculation - because the details have never been provided.
However the original ABC article from March 24 linked from the ABC article from August 11 suggests that bigger PV systems (looking at you, @grahroll ) will get hit harder than smaller PV systems. So that suggests that this is not a flat export charge used to fund electricity network improvements. It is of course possible that the ABC is not correct, given that the details have never been provided (and for a change coming into effect in 2025 that is somewhat understandable).
Whether this is implemented by actual negative FITs for selected periods of time or an across the board reduction in FITs … the effect is the same i.e. negative FIT notionally or actually.
The big difference between those two is whether you can avoid the penalty and avoid the “problems” for the electricity network by “going off grid” (/ export limiting) for selected periods of time.
Actual negative FITs for selected periods of time would be more “market driven” i.e. start to bring domestic generators into the dynamic pricing market.
The August 11 article also says:
They will not be able to impose flat fees, and charges will only be imposed when there is congestion on the grid.
Interpret that if you can.
Said article also says:
Power providers will be able to develop a range of packages for consumers to choose from, but they must include a “free basic service”, the AEMC said.
But Mr Barr said many people would find they would be financially better off choosing a paid option, because of the likely returns.
“If you don’t want to pay for exports, you don’t have to,” Mr Barr said.
So that suggests that AEMC has hospital-handpassed the blowback to retail providers and leave it to retail providers to shaft customers.
I think “free basic service” does not mean “free” at all. I think it means “a service that would be exempt from penalties for exporting” but no doubt clawing that penalty back elsewhere in the plan. So it seems as if there will also be an element of “confusopoly” and “information asymmetry”.
You may be right that there is an export limit setting somewhere, or there will be. However there’s a software Big Red Button marked “Go Off Grid” and who doesn’t love a Big Red Button?