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ENA submission to COAG consultation


On 20th September 2016, the Energy Networks Association (ENA) provided this 8 page submission to the COAG consultation process .  In their submission, they provide support:

“Energy Networks support the need for an energy storage register in Australia, which is likely to be required for a diverse range of uses including emergency response, management of any environmental risks (such as inappropriate disposal of batteries), network planning, and operations; and National Electricity Market planning and operations. It would be economically efficient for that register information to be collected in a nationally consistent format, and ideally in a single nationally accessible platform”

They note:

“Energy networks wish to assist constructively in any COAG Energy Council initiative which supports the development of transparent, accessible information on storage and other forms of Distributed Energy Resources (DER), in an efficient manner. “

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, ENA provides these specific comments:

Reason 1 = To assist First Responders 

As per the headline quote above, the ENA supports the development of an ESR for use by First Responders.

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

No specific mention was made with respect to usage for 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

As per the headline quote above, the ENA supports the development of an ESR for use in life cycle management – including end-of-life disposal.

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.

As per the headline quote above, the ENA supports the development of an ESR for use in electricity systems operation and planning (both for network companies, and for the AEMO).

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

We note the following comment:

“Our members report that current information collection powers and processes in relation to distributed energy may require strengthening. For instance, some network businesses report the presence of unregistered embedded generation, which is only visible due to the export profile at the connection “

This is expanded on:

“Analysis of meter data (both digital and analogue) by several DNSPs is indicating that:
» in some areas up to 50 per cent of batteries connected to the distribution network may not be being registered with the DNSP; and
» in some networks over 5000 distributed generation facilities (presumably rooftop solar PV units) appear to be connected, but not registered with the DNSP, and are only ‘visible’ due to the export energy profile at the connection point. “

This, we believe, is an example of why mandating data entry as mandatory is not a panacea, as we have noted here.