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AEC submission to COAG Consultation


On 20th September 2016, the Australian Energy Council (AEC) provided this 3 page submission to the COAG consultation process asking about both:
1)  The need for a central register of installed battery storage facilities; and
2)  A process by which it might be developed and maintained.

In its submission, AEC notes that an ESR “might be useful” but that:

“it is important to get the right balance of costs and benefits 

In our summary page here we proposed 4 key reasons why an Energy Storage Register could be required.  Interestingly, the AEC flag a 5th reason – as AGL had also done:

Reason 1 = To assist First Responders  The AEC notes the following caution about the value of an ESR with respect to First Responders:

“… we are concerned that the data that could be collected may not be the most suitable/informative for the emergency response.”

Where they are provided, we link to other articles referencing assistance to first responders as a reason for the Energy Storage Register.

Reason 2 = To assist in any potential future product recalls In our reading of the AEC submission, it did not seem to make specific comment about the value of the ESR in the area of Product Recalls.

Where they are provided, we link to other articles referencing potential future product recalls as a reason for the Energy Storage Register.

Reason 3 = To assist with life-cycle management In our reading of the AEC submission, it did not seem to make specific comment about the value of the ESR in the area of Life-Cycle Management.

Where they are provided, we link to other articles referencing life-cycle management as a reason for the Energy Storage Register.

Reason 4 = To assist with electricity system operations and planning. With respect to electricity system operations and planning, the AEC notes that a central focus on AEMO’s needs in the consultation paper.  In this respect the AEC notes:

“However the question is whether a register is either necessary or sufficient for AEMO’s purposes.”

Where they are provided, we link to other articles referencing electricity system operations and planning intelligence as a reason for the Energy Storage Register.

Reason 5 = General market intelligence. It was not one of the 4 key reasons we listed here for the Energy Storage Register, but AEC flagged that:

“there are a range of stakeholders that have differing interests on energy storage data, including market analysts and/or observers who are interested in further understanding how the market is developing”

We’ll call this general area of value Market Intelligence.

Where they are provided, we link to other articles referencing market intelligence as a reason for the Energy Storage Register.

We would encourage you to review the full submission (linked above) in order that:
1)  You can confirm that we have not misinterpreted AEC’s sense of the need for benefits to outweigh costs in the development of an Energy Storage Register; and
2)  To understand more of the concerns the AEC expresses in terms of reducing the reporting burden.