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King & Wood Mallesons submission to COAG consultation


On 20th September 2016, King & Wood Mallesons (KWM) provided this 21 page submission to the COAG consultation process .  In their submission, they provide support:

“We submit that a register is needed

We also note the recommendation that:

AEMO (in collaboration with the Information Exchange Committee) may be best placed to cost effectively manage the collection and dissemination of energy storage data to all interested persons.”

and that KWM sees a broader project:

“… to scale its existing Chapter 7 of the NER technological platform for real time 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, KWM provides these specific comments:

Reason 1 = To assist First Responders 

We particularly note this reference to First Responders:

“The introduction of a national database which provides emergency response services with real time and regularly updated data on battery storage is the logical next step.

Coupled with battery specific guidelines and installation safety standards, battery storage can in our view be effectively managed from a safety and emergency perspective.

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

The only specific reference to life-cycle management that we saw in the submission was the following:

“This would provide information as to the technical and safety specifications related to battery installation, life span and decommissioning.

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.

The KWM submission goes into significant detail on what are perceived as potential benefits with respect to electricity systems operation and planning – both with respect to meta data, and also to the possible extension to real time data.

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 is very detailed, and provides much useful information.