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Clean Energy Council makes submission to COAG Consultation


On 20th September 2016, the Clean Energy Council (CEC) provided this 9 page submission plus this accompanying attachment 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, the CEC includes both support, and also a note of caution:

“The CEC welcomes the establishment of a battery storage register. However, the design and implementation of the register must be carefully considered to ensure it delivers value for the range of stakeholders and institutions focused on battery storage, while being practical and not overly burdensome. “

We agree that value for money is a very important measure of success.  That’s why we are using this method in developing the Energy Storage Register.

 

In our summary page here we list the 4 key reasons we identified (up front) as to why an Energy Storage Register could be required – to which other reasons have been added as they have come to light to us (or been pointed out to us directly).

In its submission, the CEC focused mostly on the need to also implement, in parallel, high (design, installation and performance) standards for battery storage systems.  The CEC sees that these standards need to be linked to a robust accreditation scheme.

With respect to these 4 key reasons, the CEC provides these specific comments:

Reason 1 = To assist First Responders  In the last paragraph of its covering letter, the CEC mentions the needs of emergency services risk management.  Later, they go on to note:

“The different risks and hazards associated with energy storage system pose a risk to first responders in the emergency services. Due to the different energy storage system chemistries the appropriate methods of response varies. Therefore it is invaluable for emergency services to have access to an accurate and up-to-date register of energy storage system details. “

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 the last paragraph of its covering letter, the CEC mentions the needs of product recall procedures.

They also go on to note:

“A significant benefit of registering energy storage installations is if there is a product recall issued. Following a recall, only 39% of the recalled products are returned or actioned. In the case of an energy storage system, there is a significant risk to the community if product was recalled but left in service.”

The CEC also goes on to quote from Dr Penelope Crossley (who has also made a submission to COAG Energy Council).

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 the last paragraph of its covering letter, the CEC mentions the needs of product stewardship.

They also go on to note:

“The CEC feels registration of energy storage systems for end-of-life processing is vital. Inappropriate disposal of energy storage systems could lead to serious environmental and health hazards. “

Further, we’d also like to highlight the CEC use of a CSIRO reference to incident reporting quoted below (one of the few references to this that we noted in the submissions to the COAG consultation).

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. The CEC does not mention the need for electricity systems operations and planning in the cover letter of its submission.

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

In the body of its submission, the CEC does go into quite a bit of detail (both the submission and the attachment are well worth reading).

A few particular points:

1)  The CEC quotes from this report prepared in 2015 by the CSIRO in support of the Energy Storage Register.  They note that it was one of the key recommendations of the CSIRO:

“Key Recommendation No.5: Establish a set of best practices specific to the battery storage industry, including development and upkeep of an installation, maintenance and incident reporting database for energy storage systems in Australia.

The report includes more detail:

Section 2.6.1 Recommendation for records of energy storage. The Australian domestic and small commercial battery storage industry is an emerging market, and there appears to be no common framework or best practice. Therefore, it is recommended that the battery storage (and solar PV) industry develop a best-practice initiative for their industry, to report energy storage installations and incidents”

2)  In their accompanying document, the CEC documents its thinking on battery tracking as at January 2016.  This document we have reviewed along with many other reference materials that we have come across (and continue to come across), to ensure that the Energy Storage Register we are developing will deliver the best value for money for the broader industry.