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AEMC submission to COAG Consultation


On 20th September 2016, the Australian Energy Market Commission (AEMC) provided this 5 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.

As a caveat on its submission, the AEMC notes that:

“ultimately, we do not directly consider issues involving safety or emergency response in energy markets. The regulation of electrical safety and emergency response matters falls within the remit of jurisdictional departments or jurisdictional safety regulators in each state and territory “

We’ve already noted how operating the consultation through the COAG Energy Council might have had an unintended effect of narrowing consideration of the benefits of an ESR.

In their submission, the AEMC also references the work they have been doing in looking at the integration of storage into Australia’s energy market:

As an aside, we note that the they provide this project page on their website.  On that site they link to both:
1)  The AEMC final report on Regulatory Implications from 3rd December 2015; and
2)  A CSIRO trends  report from September 2015

In our summary page here we proposed 4 key reasons why an Energy Storage Register could be required:

Reason 1 = To assist First Responders  The AEMC notes that it is not within its remit to comment about this first need.

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 The AEMC notes that it is not within its remit to comment about this second need.

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 The AEMC notes that it is not within its remit to comment about this third need.

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. In the AEMC submission, they focus on this particular need.  They note that:

“In our view, there is an assumption that sits underneath the questions that have been posed in the consultation paper regarding the need for an energy storage register. Specifically, to the extent AEMO needs information on such devices in order to manage power system security it has been unable to, or cannot, gather or otherwise access such information that may be necessary.”

Again, we note the focus on AEMO (so led because of the discussion paper) and not, for instance, with respect to the DNSP’s need for similar information.

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 AEMC does provide the following useful comment:

“Inevitably, considering these questions, for each identified reason, will result in differing outcomes and so differing objectives.  Differing objectives may drive differing designs for any register”

In the development method we are using to build our Energy Storage Register, we are seeking to have conversations with as many stakeholders as possible (those integrally involved in the energy sector, along with those for whom battery storage is only of incidental interest).  From this we believe will come an ESR that delivers the greatest benefit to the broadest number of stakeholders.

We would encourage you to review the AEMC’s full submission (linked above).