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Engie submission to COAG consultation

On 20th September 2016, Engie provided this 6 page submission to the COAG consultation process .  In their submission, they express some concerns:

“ENGIE is generally supportive of efficient initiatives that improve the understanding of distributed energy resources (DER) …”

… but:

“ENGIE is concerned however, that a laborious pursuit of increasingly detailed information is likely to lead to inefficient and ineffective processes being imposed on industry, resulting in increased cost and complexity for no net benefit.”

We understand the concerns about the difficulties inherent in making such a register “work” such that benefits outweigh costs.   After all, we’ve been investing our own time and money in the development of the national Energy Storage Register for many months.

As we noted here, we believe that a “beneficiary pays” approach, such as what we are developing (as distinct from a “socialised cost” approach, which seems the implicit assumption at COAG) is one which makes it much more likely that this can be achieved.

Engie continues:

“The consultation paper makes the point that there is “currently no sufficient mechanism to register energy storage devices with relevant authorities”. This statement pre-supposes a problem and leaps straight to a solution – an energy storage register.

ENGIE believes that before any specific proposal is put forward or considered in detail, it is vital that a clear understanding of the issue or problem is first established. Until the specific problem is clearly defined and understood, it is very difficult to gauge the adequacy or otherwise of any proposed solution.

We agree with Engie’s statement, and so have invested (and continue to invest) considerable time and money in identifying and understanding all the (current, and potential emerging) problems an Energy Storage Register can solve.  This has included reviewing the Engie submission in some detail.

It’s strongly in our interests to do this, given that it is our own investment on the line.


Reason 1 = To assist First Responders 

With respect to assisting First Responders, the Engie paper notes:

“The consultation paper notes that lithium Ion batteries pose new risks and that emergency services currently have “limited knowledge as to appropriate methods and procedures that they should follow in the event of an incident”. Given that the risks are still being assessed, it seems premature to jump to a heavy handed regulatory response such as trying to capture every installation in a central register

The expected proliferation of battery devices in households into the future, including electric vehicles, is likely to lead to a situation where emergency services ultimately would be better off assuming that all households contain lithium-ion devices, rather than rely on a register that is unlikely to be completely accurate in any case

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

Engie provided these comments in the context of life cycle management:

“The consultation paper highlights a potential safety risk to installers that are required to modify or decommission older battery storage systems. The concern, as ENGIE understands it, is that technicians need to be able to identify the technical and safety specifications of each device that they are required to work on.

The Clean Energy Council have a proposal* to establish a live database tracking system for all storage installations, modifications and removals. The system would include information about the installations technology, identification numbers, circuit info and installation details.

(our comments on the CEC’s submission to COAG are here)

ENGIE believes that this proposal is not proportionate to the identified problem, and is unlikely to be successful in any case. The technical and safety specifications for various battery storages devices would be static data that could be accessed by technicians by reference to the device make and model and the original equipment manufacturer.

ENGIE expects that as these DER devices are developed further, many future installations are likely to be “plug and play”, and so reliance on installers filling in central registers of information will not be successful.

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.

With respect to electricity systems operation and planning, Engie notes:

“The consultation paper notes that the characteristics of loads are changing, but does not suggest that all load details should be included in the register. It is not clear in the consultation paper why load characteristic changes due to battery storage should be singled out for special treatment.

The consultation paper notes in section 2.1 that AEMO require a certain level of data about DER, including storage – but it is left unclear why the consultation paper then focuses on battery storage, and not the other forms of DER.

We understand the drive to capture information, more broadly, about distributed energy resources.

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 summary, we note the Engie concern about the impracticality of a central register.