We appreciate the opportunity to comment on the Australian Energy Regulator’s (AER) Updating the Ring-fencing Guidelines for Stand Alone Power Systems and Energy Storage Devices Issues Paper.

Like the AER we see the potential for emerging technologies and new business models to deliver better outcomes for consumers, at a significantly lower cost, in a very different energy system than we have today. In this context Stand Alone Power Systems (SAPS) and Energy Storage Devices (ESD) are important innovations that in the future will operate at a range of scales, and in the case of ESD both in front of and behind the meter.

In our submission, which we have developed jointly with Strategen, we explore the initial challenges of ring-fencing in a market undergoing transition. Due to the time constraints involved in submitting to deadline, we hope to have the opportunity to expand further in the period leading up to the publication of a Draft Guideline in March 2021.

A principles-based, rather than a prescriptive, approach to ring-fencing will provide a means for emerging technologies to be properly evaluated as they mature and experience is gained across
diverse applications. Read the final report here and our covering letter here.