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Submission to the AER Draft on Ring-fencing Guideline Electricity Transmission – Version 4


Energy Consumers Australia

As the dispatchable storage market is in its early stages of development with several technical, commercial, social and regulatory barriers to overcome, it makes sense to consider how network service providers (NSPs) can play a valuable role to help further develop this niche. Given the need for storage and the advantages NSPs offer – including land, low interest finance, information and skilled operations and maintenance staff – it is sensible to provide a reasonable pathway for NSPs to own and operate batteries and access the full suite of potential market revenues while waiting for the market to further develop as long as networks provide greater information about the potential for storage throughout their service area. We recommend that the AER adopts, as one of the conditions in TNSPs’ battery waiver considerations, the provision of accurate, consistent, timely and methodologically demonstrated evidence on adequate site locations for batteries throughout a NSPs service area (i.e., including, but not limited to the location of the proposed storage investment) in ways that add value for all consumers and potentially defer or avoid other network expenditure.

Providing such information will enable the energy storage market to expand beyond NSPs and drive further cost reductions in the provision of network services in the future. Moreover, the detailed analysis that is required to determine the best storage opportunities has many additional benefits to networks and the broader industry. It would identify opportunities for other non-network solutions and would require an improvement in hosting capacity analysis, which is an urgent need in the sector. In other words, increasing network’s skills and capabilities in this type of analysis is likely to offer benefits beyond the immediate one of levelling the storage playing field.

Read our full submission here

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