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Reposit Power submission to COAG consultation


On 20th September,  Reposit Power provided this 2 page submission to the COAG consultation process .

In their submission, they express reservations about a register:

“Reposit believes in a transparent and efficient electricity market – but not a 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).

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

Reason 1 = To assist First Responders 

Reposit expresses some scepticism about the value of a register for First Responders:

“First, the discussion paper has a presumption of risk to consumers and emergency personnel. It should be properly established what the risk rating really is, and how this is best mitigated before imposition of regulation. For example, the Australian Building Codes Board recently made a statement that there had never been a reported battery fire despite a large installation base (UPS systems for example have been widely used for decades)

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.

With respect to electricity systems operation and planning, the comment is made:

” There is therefore no need to register individual batteries where they are market interactive. In any case AEMO is seeking to register aggregated capacity via it’s Demand Side Participation rule change and Reposit suggests it is left to 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.

The attachment provides more details worth reviewing.