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ECA submission to the COAG Consultation

Energy Consumers Australia provided this undated 10 page submission to the COAG consultation process .

In their submission, the ECA provide a broader perspective, noting that:

“In an environment of change one of the most useful policy tools is data. This is recognized in the Energy Council’s National Energy Productivity Plan as Measure Number 24: Improve the exchange of market data

Data capture is the first step in any meaningful approach to improving the exchange of data.

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, COMPANY provides these specific comments:

Reason 1 = To assist First Responders 

The following specific comment was made, with respect to First Responders:

“Not all storage systems create an issue for emergency response, however, as most distributed resources are likely to utilize chemical rather than physical storage techniques, most may. As has become highlighted with recent smart phone product recalls, there are fire risks associated with silicon ion technology – risks which emergency authorities are still developing protocols to manage.

Signage and standards are appropriate measures for emergency response, but a centrally available resource that provides details captured at installation is also needed to enable 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

The ECA provides specific context surrounding future product recalls:

“Related to the emergency response issue is the safety issue of product recall.  Once again the smart phone case demonstrates the risk from faulty battery componentry.  Recall in the phone case is relatively simple because all devices self-register on mobile carrier networks when used (their IEMI number is captured by the network).

The case of a recent washing machine recall presents a different outcome. As at March 2016 only 74 percent of 144,451 machines, first recalled in 2013, with a major waterproofing fault have been remedied.  

The implication is that a 74% return rate (especially over such a long period) may be insufficient, if the fault was severe enough.

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 ECA does not see that the ESR should be focused on life cycle management:

“The register is not a complete battery product stewardship system that starts at manufacture or importation. It should not seek to provide product stewardship functionality to trace batteries post removal, though the register will need to be updated at system removal. This action could be used as a transaction to notify a separate disposal system that the battery is now in the waste/resource reuse chain.

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 ECA there are numerous mentions to this particular benefit path – the following are some samples:

“AEMO’s requirements for information on storage systems for power system planning and operation are valid. …


“AEMO is not the only potential user though … where high levels of deployment which may require attention to maintain power quality, safety and reliability.


“Operational data such as voltage and frequency trip settings reside in the associated inverter and not in the battery itself

hence they conclude:

“maximum use of the register for power system planning and operation would come from managing it as a complete resource of Distributed Energy Resources including generation (PV), storage, inverters and any demand response facilities

This is not dissimilar from the position noted by AEMO (in their submission, and this paper from March 2017).  We are working towards this objective.

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

In addition to the above big 4 reasons, the ECA also concurs with what some others have flagged as Reason #5:

Reason 5 = To assist, more broadly, with Market Intelligence

The following specific comment was made, with respect to First Responders:

“Businesses throughout the supply chain could utilize the data in planning, including identifying areas where there is low storage deployment creating opportunities for community level solutions …

Where they are provided, we link to other articles referencing  its potential value to Market Intelligence as a reason for the Energy Storage Register.

We also note that the ECA has recommended:

“Access should be available to anyone who can demonstrate a reasonable application within the three purposes of the register above, with an express provision that the data is not to be used for targeted marketing purposes.

The attachment provides more details worth reviewing.  We note, for instance, the general preference expressed by the ECA for the AEMO to host the register.