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AGL Energy provides submission to COAG Consultation


On 20th September 2016, AGL Energy 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, AGL cautioned that:

“energy storage ‘behind the meter’ is still in its infancy and believe that unnecessary regulatory burden at this early stage may impact the development of this new market”

however notwithstanding this, the AGL submission notes several ways in which an ESR might be of value.  In our summary page here we proposed 4 key reasons why an Energy Storage Register could be required.  Interestingly, AGL Energy also nominates a 5th reason, as summarised here:

 

Reason 1 = To assist First Responders  AGL seems to recognise this particular need in the following statement:

“while emergency response agencies and other safety authorities would benefit from more granular data on individual installs to address customer and public safety issues”

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 The same reference above could also be read to infer AGL Energy support for the development of an ESR to help with future 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 Similarly, AGL Energy does not explicitly reference the need for an ESR to assist with Life-Cycle Management, but perhaps they see this as part of the general “customer and public safety issues” referenced above.

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. In the AGL Energy submission, they note that:

“AEMO may require aggregated information to assist in the planning and operation of the NEM”

It is with interest we note that this statement:
1)  Seems to imply AEMO will require aggregated information only; and
2)  Does not speak to other energy sector participants need for data from the ESR (for instance, with the DNSPs).

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 AGL Energy flagged the following:

“Similarly, other market observers could simply be interested, at a basic level, in how the market for energy storage (at the grid, behind-the-meter and off-grid) 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 AGL’s sense of the reasons supporting an Energy Storage Register; and
2)  To understand the various cautions that they note – and other things of note with respect to this process.