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The COAG Consultation Process

The COAG Energy Council* is mid-way through a consultation process seeking to understand what should be done about a register, how and when.

Timeline of the process

It’s difficult to find, so for your benefit we have linked the relevant page on the COAG Energy Council website here.

As time permits (and more news comes to hand), we will update the status of the consultation in the table below:

19th Aug 2016 COAG Energy Council issued this consultation paper (also noted in this article here on the site)
20th Sept 2016 Submissions closed on the consultation paper only 4 weeks afterwards, with the COAG Energy Council’s list of submissions published here.

We’ve prepared quick analysis of each of the submissions (25 in total) and have linked them here:
1)  AGL’s submission
2)  AusGrid’s submission
3)  Australian Energy Council submission
4)  AEMC submission
5)  AEMO submission
6)  AESA submission
7)  ANU Energy Change Institute submission
8)  CEC submission
9)  ClimateWorks and Seed Advisory submission
10)   ETU submission
11)  Endeavour Energy submission
12)  Energex submission
13)  EnergyAustralia submission
14)  Energy Consumers Australia
15)  Energy Networks Australia submission
16)  Energy Storage Council submission
17)  Engie submission
18)  Ergon Energy submission
19)  Ethnic Communities Council of NSW submission
20)  King & Wood Mallesons submission
21) Origin Energy submission
22)  Red-Lumo submission
23)  Reposit Power submission
24)  Dr Penelope Crossley (at University of Sydney) submission
25)  Public Interest Advocacy Centre submission

Note the comment we made here about the consultation being run out of the Energy Council – and the effect this might have had on the range of submissions received.

Here’s a general link to all the articles posted, referencing the COAG Consultation process.

14th Dec 2016 COAG Energy Council was to discuss the submissions at its December meeting.  No mention was made of this in this meeting communique.
1st Feb 2017 In this Communique from the COAG Energy Council on 1st February, they note:

“Ministers agreed in principle to develop a national energy storage register subject to a cost-benefit analysis.”

The Communique goes on to note:

The EMTPT officials will present the results of the cost-benefit analysis and provide policy recommendations to the Energy Council for consideration at its meeting in mid-2017.

March/April In March/April we have provided some input to the EMTPT’s chosen consultants to assist them in the completion of their cost-benefit analysis.

In particular, we would like to emphasise the following two points:

#1 – making it “Mandatory” would not be a panacea; and

#2 – under a “beneficiary pays” model, it’s likely that the benefit-to-cost ratio will be maximised.

Contact us (tel +61 7 3368 4064)  if you would like to be involved.

22nd May 2017 On 22 May 2017, the Energy Council released the draft Cost/Benefit Analysis findings (a draft report from the consultant, and a consultation paper).

The EMTPT officials are seeking stakeholders’ feedback on the questions outlined in the consultation paper – with submissions due by Friday 9th June 2017.

This page on the Energy Council website provides more context – with the details being here:
1)  Consultant’s report (Jacobs)
2)  Consultation Paper.

June 2017 In total, 14 submissions on draft Cost/Benefit Analysis were published on the Energy Council website here.

We may, if time permits, link in comments, as we did with the prior stage of the consultation process above.  If so, comments will be linked with respect to each of the respondents:
1)  Submission by AGL;
2)  Submission by AusGrid;
3)  Submission by AEC;
4)  Submission by CitiPower/Powercor;
5)  Submission by CEC;
6)  Submission by ENA;
7)  Submission by Energy Safe Victoria;
8)  Submission by Energy Storage Council
9)  Submission by Energy Queensland (Ergon and Energex);
10)  Submission by EWON;
11)  Submission by Greensync;
12)  Submission by Snowy Hydro (Red/Lumo retail businesses);
13)  Submission by S&C Electric Company;
14)  Submission by The Customer Advocate

30 June 2017 On 30th June 2017, the consultants (Jacobs) provided to the Energy Council this Final Cost-Benefit Analysis report.

In particular, I note the following in the Executive Summary:

” The assessment excludes consideration and assessment of funding options for collection of data, development and operation of the database, and consideration of cost recovery options (e.g. options for membership fees). It is understood
that the distribution of costs and benefits will inform future consideration of cost sharing or funding approaches”

We also note that they only really consider two options for a mandatory ESR:
Option 1 = administered by AEMO (in collaboration with DNSPs).
Option 2 = administered by the Clean Energy Regulator.

3rd August 2017 On 3rd August 2017, the COAG Energy Council provided a notice of decision that AEMO should administer a national register for Distributed Energy Resources (including both solar PV and batteries).
Requested by the end of August 2017 In the Energy Council’s notice of decision of 3rd August, it requested AEMC to publish a Rule Change Proposal before by the end of August 2017.

When this has been published, we will reference it here.

end of 2018 In the Energy Council’s notice of decision of 3rd August, it requests that the Energy Storage Register is in place by the end of 2018.


How we are working in with the COAG Process

COAG Energy Council knows that we are developing the Energy Storage Register, in parallel with their process.

By using our Agile development method (progressively developing, with much input from stakeholders as we go) we believe we are more likely to deliver a Storage Register that is lower cost and broader value to stakeholders of the battery storage (and broader energy) sector, than if we waited till the end of the COAG Process.

It’s also likely that we will have a Storage Register delivering value sooner:

As an example of the artefacts that are falling out of the development process:

1)   industry stakeholders began gaining value from our BatteryFinder™ Widget from its launch in October 2016

2)  there are also a growing number of case studies being collated on this site.

– and there are more resources that will be sequentially released in the weeks and months ahead.

We look forward to continuing to work with COAG in the development of this Energy Storage Register.