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EnergyAustralia submission to COAG Consultation


On 20th September 2016, EnergyAustralia provided this brief (3 page) submission to the COAG consultation process .  In their submission, they ask for clarification about the reasons for the register – noting:

“At this time we do not consider that the rationale for creation of a register of energy storage systems has been clearly explained … We note that the paper is focussed on some of the preliminary design questions, however without better understanding the justifications behind proposed purpose and uses of the register we don’t believe that we can provide detailed comments on specific design requirements. “

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, EnergyAustralia notes its perception that the Consultation Paper flags what it sees as three possible justifications:

“These proposed purposes are emergency response, safety and industry integrity, and power system planning and operation.”

These three reasons resolve into the following four as follows:

Reason 1 = To assist First Responders 

This is what EnergyAustralia notes as:

     “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

Aspects of this requirement (along with #1 above) are to do with :

     “safety

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

Being able to use an ESR to manage the whole-of-life of installed batteries in the community is about:

     “industry integrity

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.

Finally, EnergyAustralia notes that a possible justification is provided for:

     “power system planning and operation

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 general desire, expressed in the submission, that COAG ensure that the benefits outweigh the costs before embarking down the path of creating a register.

We also notice concerns expressed about confidentiality of information, and access to data.