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Submission to the AER’s initiation notice for a ring-fencing class waiver for community batteries


Energy Consumers Australia

Energy Consumers Australia appreciates the opportunity to provide comments on the AER’s assessment for a distribution ring-fencing class waiver for projects funded under the Commonwealth Government’s Community Batteries for Household Solar Program (hereafter, the Program). It is essential that the Program and the AER class waiver enable other potential actors to enter the market, contribute to removing existing barriers to broader uptake, and promote innovation and competition in the sector. Cooperation, consistency, transparency and information sharing can enable a least-cost system that meets consumer needs, values and expectations.

In our view, however, without the proper considerations, a class waiver could give Distribution Network Service Providers (DNSPs) another advantage over third party storage developers, which potentially enables DNSPs to corner the market and reduce third party developers to the status of “bit players”, which would decrease competition in the market and increase costs to consumers. Therefore, while we support the AER’s class waiver proposal in principle as a short-to-medium-term regulatory measure, the basic criteria outlined in the initiation notice are not sufficient to actually enable a long-term transformation of the distributed storage market that benefits all consumers.

For the class waiver to genuinely support the Program’s success, we strongly recommend that the AER adopts the following waiver conditions, which are aligned with our broader position on the topic:

  1. DNSPs should be required to disclose information about network hosting capacity, constraints, and rooftop PV penetration throughout its service area annually to provide evidence about the best network locations for community batteries;
  2. DNSPs should allocate any Program funding they receive to reduce the Regulated Asset Base (RAB);
  3. All DNSPs should be required to support non-DNSP owned community battery projects and offer the same tariff structures for all community battery projects in their service area; and
  4. DNSPs should be required to prioritise the batteries’ potential to promote greater rooftop PV (and other consumer energy resources) penetration, and present robust evidence of local community engagement for each community battery proposal.

Read our full submission here

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