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Red Energy + Lumo Energy submission to COAG consultation


On 20th September, Red Energy / Lumo Energy provided this 3 page submission to the COAG consultation process .

In their submission, they provide somewhat measured support:

“We strongly support the registration of batteries where evidence suggests there is a critical need for information to be available

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, Red Energy provides these specific comments:

Reason 1 = To assist First Responders 

In their submission, the following comment is made about the need for an ESR for First Responders:

“Conversely, we are unclear how any proposed register would be utilised by emergency services in undertaking emergency response

They also flag:

“We do however consider that battery storage is not the only potentially dangerous good currently installed at a premises. LPG tanks, electric vehicles, and even asbestos are all commonly found however require no registration to ensure safe emergency response.

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

No specific mention was made with respect to usage 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.

Red Energy notes:

“Based on the information at hand, we believe there is a critical need for battery information to be available to the Australian Energy Market Operator (AEMO) for planning and system security.

.. but also:

“Prior to any determination on the scope of the register, we consider it essential that AEMO present quantifiable evidence as to why it requires this additional information and how it would be utilised for system operation. 

It may be that AEMO’s paper on distributed energy resources (March 2017) might satisfy this requirement.

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

The attachment provides more details worth reviewing.