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ETU submission to the COAG Consultation


In September 2016, the Electrical Trades Union (ETU) provided this 11 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.

The submission only bears a date “September 2016”, so we have assumed it was made on 20th September like most of the others.

The ETU was one of the respondents who flagged insufficient time in the consultation period.  They note:

“The 4-6 week consultation period that has been allowed is manifestly inadequate and does not allow for proper stakeholder input, particularly from a small, not for profit membership based organisation such as ours. “

We agree – though we understand why the timing was as such.  In contrast, the progressive “product discovery” method we are using provides for:
1)  A much longer period through which interested stakeholders can participate;
2)  Opportunity to participate progressively, (i.e. such that an interested stakeholder can progressively update their perspective, and their input, as our project progresses – and is progressively revealed on this BatteryStorage.info special-purpose website);
3)  Our method also provides for a much broader range of input, as relevant stakeholders progressively become aware of our process, become interested in it, and choose to participate.

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, the ETU provides these specific comments:

Reason 1 = To assist First Responders  In the ETU submission, they state that:

“-> Any potential register be exclusively for emergency services operational purposes only, and accessible only by emergency services personnel;
-> More consultation with emergency service providers be undertaken;”

however they go on to state:

“We are not yet fully convinced that that an energy storage register is required or that in the event it did exist, that it would deliver the desired benefits. …

We do not accept the cases put forward in consultation paper around emergency management response, which is discussed in more detail later in this submission, and we do not believe that a proper analysis of the advantages and disadvantages can be can be conducted without inclusion of the issues around privacy

We’re including some information here about how we will be respecting privacy with respect to data contributed.

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 We infer, from the comment quoted above, that the ETU does not perceive a need for the register to be used for potential 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 We infer, from the comment quoted above, that the ETU does not perceive a need for the register to be used for 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. We infer, from the ETU’s submission, that they do not see how an Energy Storage Register would provide real benefit (i.e. outweighing its cost) in relation to electricity systems operations and planning.

Reasons given include:
1)  That interval meter data will provide most of the information required; and
2)  That network companies can achieve some of the benefits sought (in terms of electrical stability) through mandated up-front connection standards – similar to those being used more recently for solar PV.

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 conclusion to the ETU submission:

“We strenuously object to any industry led or based register as the potential for misuse of data and privacy breaches are too great, as previously expressed in this submission. There are no real benefits for consumers associated with an industry led approach”

On this site we will be progressively describing how our Energy Storage Register is being developed, delivering benefits in each of these areas whilst respecting privacy considerations.