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Dr Penelope Crossley submission to COAG consultation


On 20th September 2016, Dr Penelope Crossley (of University of Sydney) provided this 19 page submission to the COAG consultation process.  In establishing her credibility, Dr Crossley (amongst other things) references this article ‘Is it time to establish a national register for stationary energy storage?’ in the March 2016 issue of the “Energy News” publication of the Australian Institute of Energy.

In her submission, they provide support:

“The lack of accurate data within the sector is problematic. It affects a wide range of areas including market design, system reliability and planning, fire risk management, and product recalls. It is argued that a number of these risks could be better managed, if reliable data was publicly available, possibly through a regulated national register for stationary energy storage”

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).

With respect to these 4 key reasons, Dr Crossley provides these specific comments:

Reason 1 = To assist First Responders 

Dr Crossley agrees that First Responders will benefit from access to an ESR, but re-iterates that the safety benefits will accrue to a broader set of workers:

“It is important that the EMTPT acknowledges that the risk posed by energy storage devices is not limited to emergency responders but may also pose a risk to certified installers, electricians, network employees etc. who may be required to work on the property housing the system. It would be more efficient for these employees to be able to access accurate data prior to their arrival at the property so that an appropriately trained/qualified person is sent to do the work.

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

Dr Crossley is keenly supportive of an ESR for facilitating effectiveness of future product recalls:

“‘Batteries have been the subject of a number of international recalls in recent years, with problems including electrical malfunction, fire risk, the risk of electric shocks and battery leakage. Historically, product recalls in Australia have had limited effectiveness, with only 39% of products recalled by the ACCC being returned.  However, where a product poses a risk of injury to a consumer, a quality that arguably many of the previous product recalls affecting batteries possess, the Minister has the power to order a compulsory recall.  The effectiveness of compulsory recalls is dependent on the traceability of goods so that affected consumers may be contacted.  Without a national register, affected consumers may not be aware of the existence of a recall, especially if their supplier or installer fails to keep proper records or goes out of business

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

With respect to life cycle management, Dr Crossley notes:

“If an storage device is listed on a national energy storage register, the end user can be contacted towards the end of the expected lifespan of the product and provided with options for lithium ion/lead acid and other battery recycling schemes that are available depending on the battery chemistry.  The knowledge that their energy storage device is also listed on a national energy storage register may also discourage people from dumping batteries at the end of life or inappropriately grouping lithium ion and lead acid batteries for crushing

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.

Comments are provided about the usage of an ESR for electricity systems operation and planning:

” For example, accurate data will enable better modelling of the amount of power required to “black start” the grid in the event of a catastrophic grid failure.

Anything else?

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

Dr Crossley also highlights other benefits that would accrue, including:

Reason 5 = To provide Market Intelligence – and so to increase competition

With respect to improving competition:

“A further benefit is that more accurate data on the scale of the uptake of storage and the development of the Australian market may also encourage new entrants to enter the market, thereby facilitating competition

Where they are provided, we link to other articles referencing the benefits of Market Intelligence as a reason for the Energy Storage Register.

The submission is worth reviewing.