In their submission, they do not provide support for a register on the basis that:
1) They note that they do not understand of the needs of First Responders, so can not say that a register would be necessary; but
2) They do not see it necessary for electricity systems operations and planning.
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, Origin provides these specific comments:
|Reason 1 = To assist First Responders||
No specific mention was made with respect to First Responders:
“Origin believes that further work ought to be undertaken to clarify what information is needed by emergency service workers and how this information may be best conveyed to them. Safety is paramount at Origin and we respect the role of emergency service workers in responding to threats and emergencies. We do not consider ourselves to be in a position to comment on whether a register is the best way of sharing this information to emergency service workers. As part of assessing whether a register is necessary it may is also worthwhile considering other notification solutions that jurisdictions may have. This could include more robust regulations concerning safety and hazard signage and a customer’s premise, and ensuring that people reporting an emergency are asked about these risks.“
We agree with the statement that we need to first understand the information required by First Responders – this is why we have been liaising with them in order to understand their requirements. A necessity for us, under the “beneficiary pays” approach we’re using.
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.||
Origin explained why they did not support an ESR for electricity systems operation and planning:
“Origin does not believe that the energy market extends to activities behind-the-meter and we do not support the provision of this data for a national register. We do not believe that behind-the-meter data is necessary for AEMO to achieve its forecasting role, and that DNSPs do not need a register as they will collect installation data in their own areas whenever systems are connected“
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 will keep Origin informed with our progress on the ESR.