New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke

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New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
New Energy
Quarterly                                                  WINTER 2021

The Rise of Dispatchable Renewables

                                      New Energy Quarterly – Winter 2021 – A
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Welcome to New Energy                                                                                                                Contents
Welcome to the first edition of New                             everything” is the result. Once something is powered by              Editorial                                                                                  02
                                                                electricity, it is a relatively incremental step to connect /
Energy Quarterly – a reflection on                              communicate / control via electricity – and the “internet of         Watt’s happened                                                                            06
developments and trends in new                                  things” is the result.
                                                                                                                                     Watt’s new                                                                                 06
energy markets over the last 3 months                           The rise of dispatchable renewables
                                                                                                                                     Watt’s next                                                                                07
(including updates on our observations).                        Ever increasing electrification requires more and more
We will also pull out the crystal ball and                      electricity to be produced at the time when it is required.          The Dawn of Dispatchabe Renewables                                                         06
                                                                The inflexibility of when large scale renewable energy is
make some predictions for the future.                           created and when power is required has placed a natural              Committee inquiry into the need and potential for dispatchable
                                                                limit on the amount of electricity we can “rely” upon being          generation and storage capability in Australia                                             08
What is “New Energy”?                                           generated from renewable energy – the sun is not always
But first, what do we mean by “new energy”. New Energy          shining nor the wind blowing when electricity is required,           Dispatchable renewables – how bright is the future?                                        10
is the label we give the production and/or storage of           not every town has a geothermal spring to capture heat,
power in “nontraditional” ways. Power (light, heat or           and not every city has a river to turn a water wheel.                Let’s tax the COVID vaccine…                                                               12
motion) has traditionally been produced at scale by the         Humanity bypassed this “intermittency and scale” problem             Negative prices – what you gon’ do when they come for you…                                 14
combustion of finite (non-renewable) resources or stores        by generating electricity from non-renewable resources
of energy.                                                      in traditional ways – burning carbon-based material to               Battery industry given renewed charge                                                      16
Through technological advancement humanity has and              convert its calorific value into electrical energy.
will continue to invent more efficient ways to capture                                                                               Redesign of the NEM beginning to take shape                                                17
                                                                However, burning finite resources has natural, physical
and use renewable sources of energy at larger and               and economic limitations - physical in that there is only so         Big Boost for Batteries in the Redesigned NEM                                              18
larger scale. This search for efficiency and scale defines      much of a finite resource, and economic in that the cost of
new energy.                                                     extracting and burning the resource must be less than the            Slowly Slowly for Very Fast Batteries – but Regulations still Playing Catch-up             20
It is important to note that using renewable sources of         value of the electricity generated, particularly if the local
energy is not new – the burning of wood is as old as            and global externalities of burning carbon-based materials           The Integrated Resource Provider is born…                                                  22
civilization itself, the harnessing of wind to traverse the     are considered.
oceans can be traced back millennia while wind has                                                                                   The Integrated Resource Provider, VPPs and the DC coupled future                           24
                                                                Both, but in particular economic considerations, have
also been used to create motion / mechanical energy to          presented just another problem that humanity is solving              The Integrated Resource Provider – A Window to the Future                                  26
pump water and crush grain for hundreds of years, gravity       through technological advancement, this time in the form
(arguably the source of all energy) has been used to create     of the efficient storage of electrical energy at scale to be         Consultation Paper on the Design and Structure of Long Term Energy Service
power (in the form of motion) since the middle ages.            available (dispatchable) when required.                              Agreements Awarded Under the Electricity Infrastructure Roadmap                            28
Now we give these sources of energy different names
– biomass, waste-to-energy, wind farms, hydro, etc.             The efficient large scale storage of electricity created
                                                                from renewable resources solves the “intermittency and               Hamilton Locke New Energy Team                                                             30
Humanity was a little slow to converting solar energy to
power, but plants have been doing it (via photosynthesis)       scale” problem, making renewable energy “reliable”
                                                                                                                                     Key Contacts                                                                               31
since the dawn of time.                                         or “dispatchable” and therefore removing the ceiling
                                                                on the proportion of renewable energy which can
Everything that is new was old                                  power our electricity networks – hence the rise of
                                                                dispatchable renewables.
What differentiates old renewable sources of energy from
“new energy” is the capture and conversion of renewable         Over the last few months, we have focused on this
energy into power at ever increasing scale and efficiency.      seismic shift in the energy sector, and it is the theme of
                                                                this edition of New Energy Quarterly.
Ultimately New Energy is how humanity will create the
energy to power our society into the future. It recognises      So welcome to the New Energy Quarterly and
that human advancement is based upon a constant                 our focus theme for this quarter – the rise of
technological evolution – solving problems to improve our       dispatchable renewables. 
lives through the invention and application of ideas is at
the core of what makes us human.
There is no better example of constant technological
evolution than the ever expanding use of electrical energy.                                Matt Baumgurtel
From supercomputing and the internet, to transportation,                                   Partner – Head of
robotics and nanotechnology, we are in the electrical age                                  New Energy
and will be for some time.
Increased utility, flexibly and efficiency in the use of
electricity has facilitated the application of electricity to
more and more areas of our lives - the “electrification of
                                                                                            New Energy Quarterly – Winter 2021 – B                                                                                     New
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New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Editorial                                                                                                                                                                                                             Authors:
                                                                                                                                                                                                                      Matt Baumgurtel and David O’Carroll

The current landscape                                      We have also seen that the regulatory landscape is                    Regulation has struggled to keep up with the pace              Similarly, the proposed congestion management model
The fundamental structure of the National Electricity      undergoing significant change. The latest National                    of technological advancement and falling equipment             (or COGATI 2.0) is an abstract economic modelling
Market (NEM), and electricity networks around the          Electricity Rules changes to introduce new spot-market                and construction costs. National Electricity Rules             thinktank thought-bubble experiment looking for a
world is changing. Increased penetration of intermittent   arrangements for fast frequency response supports                     amendments and revisions continue to incrementally             problem. The practical frailties and counterproductive
renewable generation is placing increasing demands on      dispatchable generation.                                              respond to the evolving market, however, these                 signalling to the investment of congestion taxing
aging thermal (particularly coal fired) generators, most                                                                         revisions are ad hoc, bespoke changes often                    resulted in the first iteration being dismissed. Reviving
                                                           The proposed introduction of a new registration
of which are well past their initial design life and are                                                                         implemented to address a specific gap or respond to a          the COGATI ghost under the guise of the promotion
                                                           category, the Integrated Resource Provider and
nearing the end of their useful (i.e. reliable) life.                                                                            particular set of circumstances (and often sponsored by        of Renewable Energy Zones denies the reality that the
                                                           Integrated Resource Unit classification will simplify the
                                                                                                                                 stakeholders with a vested interest in the change).            future is a decentralized generation system.
For electricity networks to function in a stable and       registration and operation of energy storage systems.
secure manner, intermittent or viable generation                                                                                 It is widely acknowledged that a structural rewrite is         The future NEM requires better and more transmission
                                                           Allowing for the aggregation and participation of small-
needs to be balanced by dispatchable (on demand)                                                                                 required to implement a regulatory system (both a set          infrastructure – unsurprising given the lack of
                                                           scale batteries in the wholesale market will unlock
generation. Traditionally this was done by baseload                                                                              of rules and the regulators that enforce them) which           investment in transmission over the last 30 years.
                                                           revenue streams for behind the meter generation
coal fired generation supplemented by open cycle gas                                                                             is fit for purpose for this decade, the next generation        Someone should work out where more electricity
                                                           and storage assets, and open a new market in the
turbines and traditional hydroelectricity. This need for                                                                         of technology, and beyond. Redesigning the NEM is a            transmission infrastructure is needed and develop a
                                                           aggregation of the capability of these assets.
“balancing” or “firming” generation places a technical                                                                           monumental challenge – building a regulatory system            plan to build it in an integrated way addressing the
limit on the amount of intermittent or viable generation   These rule changes are consistent with AEMO’s                         on shifting technology sands with powerful vested              greatest need first. An integrated system plan is what
in the network.                                            objectives of ensuring system security and market                     interests at every turn will require huge amounts of           we need – hang on, didn’t we do that? Why don’t we
                                                           efficiency. However, these changes are ultimately at                  fortitude and a heavy dose of political buy in across          just get on with building the ISP 2020?
At the same time, in the NEM we are seeing significant     the margin.                                                           State, Federal and political party lines. We may look
reductions in the reliability of coal fired generators,                                                                                                                                         A new NEM is crucial to unlocking the massive
                                                                                                                                 back and mark the statements this month from the new
primarily due to their age and failure to be properly                                                                                                                                           private investment eager to invest in energy
                                                           The future                                                            head of AEMO, Daniel Westerman, that the grid needs
                                                                                                                                                                                                storage and dispatchable renewables. Legislative
maintained over many years.                                                                                                      to be able to run 100% renewables by 2025, as the
                                                           The continued retirement of coal generators will                                                                                     support, regulatory certainty, and a transmission
So, in a landscape where the amount of intermittent        continue to create opportunities for new dispatchable                 beginning of the seismic structural change required.
                                                                                                                                                                                                system fit for a distributed energy future is critical
renewable generation in the network is reaching its        renewable generation and standalone energy storage                    Engaging all stakeholders in this process will be crucial      to the smooth transition to the inevitable future of
technical limit and once reliable balancing generation     (i.e. projects that store electricity generated by others).           to achieving a NEM which is fit for purpose for the long       baseload renewables…
is faulting, human ingenuity is solving the problem –                                                                            term. What the “new NEM” needs to look like is quite
                                                           The opportunity for standalone energy storage is
energy storage – by removing the need to balance                                                                                 clear and building broad consensus around how to
                                                           directly proportionate to the requirement for generation
generation by making renewable energy available on                                                                               achieve it will be important. However, it will be more
                                                           to balance existing and new intermittent generation,
demand (i.e. dispatchable).                                                                                                      important to resist the influence of vested interests to
                                                           and hence is heavily dependent on the retirement of
The integration of energy storage in renewable             coal generation. Hence there is a natural limit to the                delay and resist structural change.
generation projects is creating enormous opportunities.    amount of standalone energy storage required.                         The ESB’s option paper released in April and the
Renewable energy projects that were previously                                                                                   public statements from the ESB upon the delivery of
                                                           Dispatchable renewable generation will fill the
non‑economic due to curtailment, Marginal Loss Factor                                                                            its final advice to the Energy National Cabinet Reform
                                                           gap left by existing coal generation – the almost
(MLF), grid capacity, or market price risk are now                                                                               Committee are consistent with a redesign of the NEM.
                                                           weekly announcement of another “mega” project in
feasible when coupled with energy storage allowing
                                                           development which integrates renewable generation,                    However, media reports in relation to the final advice
for time of energy dispatch to be flexible and not
                                                           energy storage (and potentially hydrogen production) is               and statements from the Federal Energy Minister                  Matt Baumgurtel                     David O’Carroll
determined by the time of generation.
                                                           testament to this.                                                    suggest the progression of the broad reforms required            Partner – Head of                 Associate - Energy,
The steady advances in energy storage technology and                                                                             have been put aside in favour of the short-term                    New Energy                       Infrastructure and
                                                           These mega projects are possible because of
reductions in cost are now enabling renewable energy                                                                             propping up of old failing technology via a capacity                                                    Resources
                                                           continued equipment and construction cost reductions
generators to produce a product that their customers                                                                             payment mechanism. Such a mechanism ignores the
                                                           and are fueled by the huge amounts of low cost capital
want – electricity at the time of day they need it.                                                                              inherent and ever-increasing unreliability of old coal-fire
                                                           seeking to invest in clean energy, often driven by ESG
Large scale energy storage technology is also playing      mandates and attracted to the macro fundamentals                      generators. It steals from the future by living in the past.
a key role in supporting grid stability – providing the    of energy markets and long-term stable cash flows. In                 Electricity capacity markets are inherently inefficient
network balancing previously delivered by coal fired and   addition, governments around the world are stimulating                and are being abandoned around the world. A capacity
open cycle gas generation. Grid-stabilizing batteries      their covid affected economies by investing staggering                market would be a significant step backwards for the
are providing a whole raft of support functions such as    amounts in their electricity and energy markets,                      NEM, not the giant leap forward required to develop a
frequency control ancillary services (FCAS) and network    essentially resetting them for the next millennia.                    NEM fit for the future.
support and control ancillary services (NSCAS).            Hydrogen produced from renewable energy will be a
                                                           huge part of this future - from covid lemons to green
                                                           hydrogen lemonade!

                                                                                     New
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                                                                                                Quarterly –– Winter 2021 –– 02
                                                                                                             Winter 2021    02                                                                                             New
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                                                                                                                                                                                                                                                         2021 – 03– 03
                                                                                                                                                                                                                                                            2021
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Watt’s happened?                                                                                                                 Watt’s new?

                                                                                                                                 World

             Veno Panicker spoke at the 2021                            Matt Baumgurtel featured on Boardroom                            NSW government to invest additional                          The newly appointed CEO of AEMO has
             Integrated Project Engineering Congress on                 Media’s Around the Markets Segment                               $380 million in funding for renewable                        announced that he wants Australia’s main
             “Avoiding a repeat of post GFC mistakes in                                                                                  energy zones in NSW as part of                               grids to be able to handle periods of 100%
                                                                        discussing “Energy as a service”
             major infrastructure projects”                                                                                              2021‑22 budget                                               renewable energy penetration by 2025. This
                                                                                                                                                                                                      ambitious target will require a multi-faceted
                                                                        Matt Baumgurtel featured in Inframation                          House Standing Committee on                                  approach including stabilising the increasing
             Matt Baumgurtel featured in which-50
                                                                        discussing the reality of the Australian                         Environment and Energy holds first                           penetration of solar and wind with dispatchable
             Minicast on “The emerging world of energy
                                                                        renewables M&A market                                            hearing on 23 June 2021 for its inquiry                      technologies (eg big batteries) to plug gaps in
             as a service”
                                                                                                                                         into dispatchable generation and storage                     peak-usage periods
                                                                                                                                         capability in Australia                                      AEMC draft determination in relation to the
Watt’s new?                                                                                                                              SA Government inviting national and                          integration of energy storage into the NEM
                                                                                                                                                                                                      - the single largest reform to the NEM since
                                                                                                                                         international expressions of interest to
                                                                                                                                                                                                      the NEM was created over 20 years ago. We
                                                                                                                                         develop land at Port Bonython in the Upper
                                                                                                                                                                                                      unpack the implication in our 3 part series here
Hamilton Locke                                                                                      Halo Group                           Spencer Gulf, one of SA’s most prospective
                                                                                                                                         hydrogen export hubs                                         The Energy Security Board released its Post
                                                                                                                                                                                                      2025 Market Design advice to Government
 New starters                                                                                                                            Interesting times await regarding the                        on 28 July 2021. The leaked advice outlines a
                                                                                                                                         upcoming AGL demerger – owners                               number of reforms which are likely to stymie
                                                                                                                                         of renewable energy assets will be                           deployment of renewable energy projects and
                                                                                                                                         encouraged to test the market after                          energy storage projects.
                                                                                                                                         the valuation and acquisition of Tilt
                                                                                                                                         Renewables. It is reasonable to consider
                                                                                                                                         that NewAGL (AGL Australia) may be
                                                                                                                                         an attractive take-over target for the
 David O’Caroll           Mark Schnider           AFR recognises                                    Halo Group                           right buyer
 Associate                Partner                                        Hamilton Locke
 Energy, Infrastructure   Litigation and          Hamilton Locke as                                 Acquires Leading
 and Resources            Restructuring           Australia’s fastest    Launches                   Regulatory and
 Sydney                   Brisbane                growing legal          Brisbane Office            Compliance Firm,
                                                  partnership            Hamilton Locke             The Fold Legal
                                                                         is pleased to
                                                    read more            announce the
                                                                         launch of our
                                                                                                      read more
                                                                                                                                    Watt’s next?
                                                                         Brisbane office, as
                                                                         featured in Lawyers                                                   Connecting Green Hydrogen APAC Conference on 11-13 October, 2021:
 Adam Jeffrey             Alex Ninis                                     Weekly, with                                                          Matt Baumgurtel will be moderating the panel ‘Green Hydrogen: Accelerate Production
 Partner                  Partner                                        corporate partner,                                                    and Use of Renewable Hydrogen’ and will be speaking on the panel ‘Exploring
 Banking and Finance      Intellectual Property
 Sydney                   and Technology                                 Peter Williams                                                        Opportunities for Hydrogen Export & Industry Supply’
                          Melbourne                                      and insolvency
                                                                         and litigation                                                        5th Solar Energy Future Australia Conference 2021 on 11-13 October, 2021 in
                                                                         partner, Mark                                                         Melbourne: Matt Baumgurtel will be speaking on the panel ‘Key Considerations
                                                                         Schneider joining                                                     when going into a Corporate PPA in Australia’
                                                                         as foundation              AFR features HALO
                                                  Matt Baumgurtel
                                                                         partners of our            Group’s intention to                       The upcoming Summer months are likely to see even more negative pricing events.
                                                  appointed to
                                                                         Brisbane presence.         list on the ASX                            Following AEMC’s recent determination on negative pricing, generators await
                                                  Market Advisory
 Peter Williams           Sandra Taran            Panel of Business                                                                            how AEMO will use its new power in the coming months. See our analysis and
                                                                           read more                  read more
 Partner                  Special Counsel                                                                                                      predictions here
 Corporate                Corporate
                                                  Renewables Centre
 Brisbane                 Sydney                  Australia
                                                    read more                                                                                  Renewable hydrogen (in particular green hydrogen) as the focus of our next quarterly

                                                                                                                                               Ammonia Energy Conference 2021 on 25 - 27 August 2021:
                                                                                                                                               Matt Baumgurtel will be speaking on innovation and R&D in the ammonia value chain
 Hannah Jones
 Senior Associate
 Corporate M&A and
 Private Equity
 Sydney

                                                                                     New
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                                                                                         Energy Quarterly
                                                                                                Quarterly –– Winter 2021 –– 04
                                                                                                             Winter 2021    04                                                                                     New
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New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Authors:
The Dawn of                                                                                                                                                                                               Matt Baumgurtel and David O’Carroll
                                                                                                                                                                                                          First published:
Dispatchable Renewables                                                                                                                                                                                   25 March 2021

   Dispatchable renewable electricity generation     The integration of energy storage into solar                        Pull factors                                                a lot more confidence to contract for a much larger
   has the ability to support a secure, reliable     farms is no longer a public relations tool.                         But this is only the “push factor”, the “pull factor” is    percentage of their total load, conceivably up to 100%.
   and affordable electricity system with a higher   Developers are implementing large scale                             even more critical. Offtakers are looking for firmed        This leads to the obvious question from both electricity
   share of renewable energy. Dispatchable           energy storage into project design to manage                        green power. The types of offtakers in question are the     consumers and generators – why can’t the generator
   generation essentially refers to sources of       curtailment and marginal loss factor risk. The                      big US technology firms, who are heavily committed          be the supplier (retailer) of electricity? – and hence we
   electricity that can be dispatched on demand      ability to shift large amounts of generation from                   to reducing their emissions and increasingly active in      are seeing the birth of the “miniGentailer”.
   at the request of power grid operators or the     the middle of the day to peak load times later                      writing Australian power purchase agreements. When          Energy storage is also supercharging the “sub 5MWac”
   plant owner according to the needs of the         in the day re-writes the wind, and particularly                     presented with a choice of renewables offtake firmed        market (those projects which have a connection
   market. However, without government help,         solar, business case.                                               from the grid or energy storage charged from known          capacity below 5MWac). The oversizing of the MWdc
   or a balance sheet, it is less obvious where                                                                          renewable generation (ie behind the meter BESS),
                                                     Projects which were marginal or non-economic                                                                                    capacity and incorporation of BESS to store the
   developers or investors might shoehorn                                                                                they are choosing the green firmed option despite the
                                                     because of curtailment, MLF, grid capacity, or                                                                                  “excess” energy allows projects to be sized to match
   storage into their renewables business.                                                                               significant price difference.
                                                     market price risk are completely transformed                                                                                    the more modest annual MHh consumption of some
   But there is a way forward.
                                                     when the time of energy dispatch is flexible and                    There appears to be a strong impetus to be the first        corporates. These projects can be constructed and
                                                     not linked to the time of generation. This is the                   truly 100% green energy user, not merely buying wind        generating within a matter of weeks (12 weeks is
                                                     dawn of dispatchable renewables.                                    or solar MWhs equal to consumption on an annual             common) with the single offtaker often being given
                                                                                                                         basis which ignores when that energy is consumed.           naming rights adding to the appeal. These projects are
                                                                                                                         While nothing has been announced on this yet, we have       often progressed on a portfolio basis (5 – 10 separate
                                                                                                                         seen term sheets which reflect this.                        sites) to create economies of scale in equipment
                                                                                                                                                                                     procurement, construction, and financing.
                                                                                                                         New offtaker market                                         As coal fired generators retire and are replaced with
                                                                                                                         The rise of dispatchable renewables is also expected to     cheaper renewable energy and Australia moves to
                                                                                                                         open up a whole new offtaker market.                        a low carbon future the resolution of the ‘energy
                                                                                                                                                                                     trilemma’ – energy which is affordable, sustainable and
                                                                                                                         Corporates, governments and even community groups           reliable – will be critical to a smooth, just and efficient
                                                                                                                         with smaller inflexible load profiles will be able to buy   low carbon transition.
                                                                                                                         renewable energy directly from generators with the
                                                                                                                         confidence that the time (and hence price) when the         While all roads lead to dispatchable renewables,
                                                                                                                         electricity is dispatched into the grid matches the         partnering with advisors with depth and breadth of
                                                                                                                         time they are consuming electricity from the grid. This     renewables market experience who provide innovative
                                                                                                                         “load following generation” removes the inherent risk       commercial legal solutions will be critical to navigating a
                                                                                                                         of entering into a financial contract (PPA) referenced to   constantly evolving environment. 
                                                                                                                         electricity prices at the time of generation in the hope
                                                                                                                         that profits from that contract will offset the cost of
                                                                                                                         electricity they consume at a different time of day.
                                                                                                                         At its simplest, advances in energy storage technology        read more
                                                                                                                         and reductions in cost are allowing renewable energy
                                                                                                                         generators to produce a product that their customers
                                                                                                                         want – electricity at the time of day they need it.
                                                                                                                         Ultimately this will give these electricity consumers

                                                                               New Energy Quarterly – Winter 2021 – 06                                                                                         New Energy Quarterly – Winter 2021 – 07
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Committee inquiry into the need and                                                 Authors:
potential for dispatchable generation                                               Matt Baumgurtel and David O’Carroll
                                                                                    First published:
and storage capability in Australia                                                 08 April 2021

     Update: On 23 June 2021, the Committee held the first public hearing for its inquiry into dispatchable energy
     generation and storage capability in Australia. It heard from AEMO and from the Department of Infrastructure,
     Science, Energy and Resources about the policy framework and settings for Australia’s dispatchable
     energy future.
     At the time of writing, a report of the hearing has not yet been published. We look forward to its publication
     and will issue an update as soon as this becomes available.

Following on from our recent article on the need for and       We at Hamilton Locke are engaged with our clients
rise of dispatchable renewable electricity generation in       in relation to this inquiry and we will be assisting in
Australia (see: The Dawn of Dispatchable Renewables),          preparing submissions to the Committee in the coming
we are pleased to see that on 24 March 2021, the               weeks. We are also very interested to hear from
House Standing Committee on the Environment                    other stakeholders in the sector on any of the items
and Energy has resolved to inquire into the current            raised above. Please get in touch with our Energy,
circumstances, and the future need and potential for           Infrastructure and Resources lead, Matt Baumgurtel,
dispatchable energy generation and storage capability          should you wish to discuss. 
in Australia.
The Committee is accepting written submissions,                   read more
addressing one or more of the terms of reference to be
received by Friday 7 May 2021. The terms of reference
listed are:

a. current and future needs;

b. issues related to system integration, connection,
   and grid transmission requirements;

c. existing, new and emerging technologies;

d. comparative efficiency, cost, timeliness of
   development and delivery, and other features of
   various technologies;

e. applications to various scales and forms of end-use
   such as households, industry, and transport;

f.   Australia’s research and innovation development
     framework and policies;

g. opportunities for Australia to grow and export
   dispatchable zero-emission power; and

h. other relevant matters, including reference to
   international examples.

                                                                                         New Energy Quarterly – Winter 2021 – 08   New Energy Quarterly – Winter 2021 – 09
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Authors:
Dispatchable renewables – how                                                       Matt Baumgurtel and David O’Carroll
                                                                                    First published:
bright is the future?                                                               08 April 2021

                                                                                                                                  In the solar space, the falling costs of essential          solar farms as path finder projects the multi-billion
   Update: We note the news that AGL Energy will                                                                                  equipment such as panels, tracking systems and smart        dollar Australian solar market would arguably not exist
   be partnering with Australian solar technology                                                                                 inverters are resulting in generators adding more panels    (see “Insights from the First Wave of Large-Scale Solar
   firm RayGen to deploy concentrating solar and                                                                                  to produce more power in times of lower sunlight and        Projects in Australia” (ARENA report, January 2020)).
   energy storage technologies at Liddell. The                                                                                    curtailing their output during peak times. Coupled with
   project will be a further example of renewable                                                                                 this, the cost of batteries is also decreasing rapidly as   To be reliable and secure, a high
   energy supplies being paired with long-                                                                                        the global and Australian supply scales up.                 penetration renewable power system
   term energy storage facilities, by building a
   3MW/50Mwh ‘solar hydro’ facility alongside a                                                                                   A variety of technological options should provide           will need to make use of a blend of
   4MW concentrating solar PV project, providing                                                                                  solutions for different demand profiles and can             dispatchable and VRE technologies with
   up to 17-hours of dispatchable storage.                                                                                        contribute to minimizing the overall system cost.           a mix of different technologies, durations
                                                                                                                                  Ultimately, policy decisions on electricity market design
   Furthermore, we welcome the recent report
                                                                                                                                  will decide which degree of dispatchability is required
                                                                                                                                                                                              and locations.
   by the Clean Energy Council (Battery Storage:
   The New, Clean Peaker) which finds that large-                                                                                 and rewarded. As the system value for short and long        In the current landscape, CEFC’s Dispatchable Power
   scale battery storage is now a better choice                                                                                   term storage is not the same, revenues from these           Program which is designed to complement grant
   than gas for electricity peaking services, based                                                                               segments might also be different and yet, technologies      funding offers for emerging technologies is available
   on cost, flexibility, services to the network and                                                                              to serve both segments will be needed and as such,          to support contracted, partially-contracted and
   emissions. The CEC states that, whilst the future                                                                              should be supported.                                        uncontracted projects and it is expected that large-
   applications of batteries have almost unlimited
   potential, gas projects come with several inherent                                                                                                                                         scale battery projects will meet CEFC’s investment
                                                                                                                                  Reliability                                                 criteria eligible for finance, with such projects being
   risks, such as the price of gas, which has a
   significant impact on the economic feasibility of
                                                               Security                                                           The main market objective is and will continue to be        assessed on a case-by-case basis. In NSW, the $75
   gas-fired peaking services. In contrast, batteries          If the fundamental opportunity for renewables is their             overall reliability, ie providing electrical power when     million NSW Emerging Energy program has allocated
   have higher availability due to the requirement for         abundance and relatively widespread occurrence, the                it is most needed. This is the issue that will require      funding into capital projects and pre-investment
   less maintenance and can offer guaranteed fixed             challenge is applying these to meet demand given their             the greatest long-term planning and investment.             studies streams to support activities that accelerate
   power and energy for over 20 years. The CEC’s               variable nature over the long-term. This for the most              Some dispatchable generators are more flexible (ie          the development of on-demand, electricity projects
   analysis shows that “battery storage is the true            part means the availability of large-scale electricity             faster in response) than others. Consistent renewable       and as of the date of this article, grants have been
   bridge to a clean energy future and can become              storage. Battery storage systems are emerging as                   energy sources such as bioenergy and geothermal             awarded to five capital projects with a combined
   the new flexible peaker to accelerate Australia’s           one of the key solutions to effectively integrate high             are inherently dispatchable, while VRE inputs such as       capacity of 220MW and nine investigative projects
   transition to sustainable energy”.                          shares of solar and wind renewables in power systems               solar or wind energy can be converted to dispatchable       with the potential to deliver 2,700MW. We at Hamilton
   Finally, we note the recent announcement by                 worldwide. In Australia, battery storage for renewable             generation when combined with a form of energy              Locke are actively assisting our clients in relation to
   Daniel Westerman, the new CEO of AEMO,                      energy is increasingly being used in a variety of                  storage (such as batteries, pumped hydro or hydrogen).      these programs.
   settling an ambitious target for Australia to               designs, sizing and locations for the main purposes
   lead the rest of the world with a grid ready to                                                                                To be reliable and secure, a high penetration renewable     Equally critical – and which will assist in unlocking
                                                               of load shifting and supporting the stability of the grid.         power system will need to make use of a blend of
   handle 100 per cent of renewables by 2025.                                                                                                                                                 the tidal wave of private investment eager to invest in
                                                               Batteries are also now being included more and more                dispatchable and VRE technologies with a mix of
   To do this, it is clear that not only will stronger                                                                                                                                        energy storage - is legislative support and regulatory
                                                               in project planning as mitigation against future storage           different technologies, durations and locations.
   transmission infrastructure be required, but so to                                                                                                                                         certainty both in terms of the orderly retirement of
   will dispatchable technologies (ie big batteries)           costs, penalties or to account for future legislative or
                                                                                                                                  As referenced above, it is therefore important that         existing coal generation and the market in which
   so that the intermittency of solar and wind                 market requirements.
                                                                                                                                  energy policy is technology neutral and the services        dispatchable renewables will operate over the
   generation can be stabilized to provide electricity                                                                                                                                        long term.
   to the grid when required.                                  Cost                                                               that are required to support system reliability and
                                                               A fundamental question when considering whether the                security are appropriately defined and valued.              Looking ahead, the retirement of coal generators will
                                                               long-term goal of net zero emissions will be achievable                                                                        inevitably require alternative energy supply technologies
In the first article in this series (see link), we discussed   is whether the technology needed for dispatchable                  Other factors                                               to fill the gap left behind. Effective dispatchable
the need for and rise of dispatchable renewable                generation will be cheap enough. If so, in theory                  Government policy and incentives will largely dictate       renewable electricity generation is currently mooted as
electricity generation in Australia, highlighting that         enough of it can be added to the grid to absorb just               the growth and uptake in alternative means of               one of the key solutions to this as renewables become
in recent years there has been a marked shift from             about any fluctuations.                                            electricity generation and storage. As recently as last     more controllable and affordable. While the ultimate
baseload coal balanced by open cycle gas turbines                                                                                 week, we noted the House Standing Committee on              solution will likely require a holistic approach using
and hydro, to increasing levels of variable renewable          In general, costs are likely to continue to fall for all           the Environment and Energy’s inquiry into the current       multiple energy sources and technologies, having a
energy generation (VRE) balanced by dispatchable               renewable energy technologies in correlation with their            circumstances and future need and potential for             high volume of renewable energy in the system that
renewable generation.                                          growth in global deployment. This should improve                   dispatchable energy generation and storage capability       is dispatchable on demand would appear to be an
                                                               the competitive position of dispatchable renewables                in Australia (see link to bulletin).                        essential part of this approach. The future is likely
But this transition is and will not be without its             compared to other forms of energy such as gas.
challenges and the oft cited “energy trilemma” of having                                                                                                                                      dominated by dispatchable renewables. 
                                                               Readily achievable growth rates (around 25% per year)              Support in the form of grant funding will be critical in
an energy system that is secure, affordable and reliable       in dispatchable renewables could keep pace with coal               the formative stages of this market, as it was in the
still rings true. Here, we consider these challenges and                                                                          early years of large scale solar. Absent ARENA and            read more
                                                               retirements and enable an orderly transition to a large
some of the proposed solutions and opportunities.              share of renewable energy.                                         CEFC funding of early Moree, Nygan and Broken Hill

                                                                                        New Energy Quarterly – Winter 2021 – 10                                                                                        New Energy Quarterly – Winter 2021 – 11
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Authors:
                                                                                     Veno Panicker and Andrew Elias
                                                                                     First published:
Let’s tax the COVID vaccine…                                                         14 April 2021

                                                                                                                                    With such a significant uptake by Australian households
   Update: On 12 August, AEMC delivered its final decision on the rule change. Owners of rooftop solar homes                        of rooftop solar PV systems, it would be logical to
   may be able to export their excess power without facing additional charges under a “basic export service”,                       then consider implementing sound policies that look
   but can expect to pay their electricity retailers for paid plans to avoid curtailment and to access the best feed-               to ensure that projects commence to expand the
   in-tariffs. The fall out from the introduction of the Solar Tax remains to be seen, however, it is clear that it will            existing electricity grid infrastructure to withstand the
   continue to cause controversy across the industry.                                                                               exponential increase in supply of electricity.
                                                                                                                                    There’s just a couple of problems:
                                                                                                                                    1. the electricity networks are considered to be
Who will pay to upgrade the grid?                               We will refer to this two-way pricing system as a                      natural monopolies and unlike other industries,
The need to upgrade if not over-haul much of the                ‘Solar Tax’ throughout this article.                                   the electricity networks do not compete and
electricity network across Australia is not a new                                                                                      drive to lower costs and invest in adequate
                                                                So how does AEMC propose the Solar Tax
problem – and is a problem measured in billions.                                                                                       infrastructure; and
                                                                be calculated?
                                                                                                                                    2. there is a lack of political will in both sides of
We reported on 12 April 2021 on the Australian                                                                                         government to implement sound policies for the
Energy Market Commission’s (AEMC)                               How will the Solar Tax be calculated?
                                                                                                                                       development and renewal of infrastructure and in
announcement to review plans to upgrade electricity             AEMC has justified this draft determination on the                     most cases, projects that are government funded
networks – a decision which will be a barrier to                basis that currently, the energy sector is suffering a                 are late, over budget and poorly managed.
operators financing their network projects.                     ‘traffic jam’ problem with large volumes of excess
                                                                electricity being exported to electricity grids.                    To drill the point home, this is analogous to government
A recent draft determination from AEMC floated the                                                                                  approving 1,000 units in a low-density suburb without
equivalent of a charge for home owners that export              AEMC’s draft determination provided three different                 approving any policies for the upgrading of roads in that
to the grid during busy periods – to assist in funding          methods when modelling the impact of the Solar                      suburb, inevitably leading to traffic congestion… then
the grid upgrade.                                               Tax2:                                                               taxing each person living in that suburb a tax for using
In effect, this is a tax for consumers that have                • a flat export charge - $0.00-0.02/kWh;                            their cars during busy periods of the day.
invested in roof top solar for their homes. We                  • a time-of-use (TOU) export charge - $0.00-0.02/
                                                                                                                                    If this is absurd, then why don’t we consider the
consider this the energy equivalent of a tax on the                kWh; and
                                                                                                                                    existing Solar Tax absurd?
COVID vaccine.                                                  • a max export capacity - $2.93-29.31/kW.
We understand that the grid needs funding in the                Submissions were made on the effectiveness                          Way forward
billions to meet future demand – this is not a cost             of the three pricing methods by various industry                    The energy market is constantly changing, improving
which should be borne by those home owners that                 players including MEU, ARENA and the Clean                          and innovating at a rapid pace and as a result there
have already invested in solar panels to minimise               Energy Council. So what was the basis for AEMC’s                    is no real ‘quick fix’ to the problems faced. The
their energy costs.                                             Solar Tax?                                                          Government at Federal and/or state levels must lead by
Of concern for the industry as a whole, such a                  A long-term solution or a band-aid to patch a more                  example and implement sound policies to incentivise
tax is reflective of a government seeking to offset             systemic problem in the energy sector?                              the upgrade and expansion of infrastructure in the
costs to anyone they can palm it too. The reality                                                                                   energy market, particularly electricity grids.
                                                                Underlying what appears to be a ‘quick’ and ‘cheap’
is government at Federal and State levels have                  solution to this problem is a more systemic issue                   At best this ‘Solar Tax’ is poor policy which will cost
dropped the ball for decades in the management                  rooted by the failures of successive governments to                 home owners and make very little impact to the
and upkeep of the grid.                                         ensure adequate infrastructure and electricity grids                upgrade of the grid – a problem orders of magnitude
                                                                to store the increasing electricity supply by mum and               greater than such a tax will yield.
What is the Solar Tax?                                          dad solar panel owners.                                             What’s next – a tax on the COVID Vaccine? It makes
On 25 March 2021, AEMC issued a draft                                                                                               about as much sense. 
                                                                In the early 2000s, the Australian Government
determination outlining its strategy to deal with
                                                                introduced a renewable program which provided
the integration of small-scale solar energy into the
                                                                rebates to Australian households who acquired solar                   read more
electricity grid.
                                                                photovoltaic (PV) energy systems.
To break this down further, AEMC floated the idea
                                                                This program was very effective and successful with
that electricity grids should offer what’s called a ‘two-
                                                                over 20% of Australian households having rooftop
way pricing system’. The two-way pricing system
                                                                solar PV systems, which is a rate that is among the
operates so that solar and battery owners1:
                                                                highest in the world3. Households which produced
1. are rewarded for exporting power to the grid                 excess solar energy would then typically receive
   when it is needed; and                                       a credit for the excess solar energy which is then
2. are charged for exporting power to the grid when             exported back to the electricity grid. The credit
   it is busy.                                                  amount will vary between each electricity retailer.

                                                                                          New Energy Quarterly – Winter 2021 – 12                                                               New Energy Quarterly – Winter 2021 – 13
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Authors:
Negative prices – what you gon’ do                                                        Matt Baumgurtel and David O’Carroll

when they come for you…
                                                                                          First published:
                                                                                          08 April 2021

A recent determination of the Australian Energy              As a result of the change, a semi-scheduled                         What’s next?
Market Commission (AEMC) amending the National               generator will be deemed to have complied with
Electricity Rules may have negative consequences for         a dispatch level if it only varies from the dispatch                Revisions to PPAs currently being negotiated are
solar and wind generators who have Power Purchase            level as a result of energy source availability, and in             being vigorously debated by offtakers and generators.
Agreements (PPAs) that don’t settle when prices              the case of a semi‑dispatch interval, if it does not                It is unlikely that offtakers will accept negative price
are negative.                                                exceed the dispatch level, regardless of the energy                 exposure and hence it will likely be up to the generators
                                                             source availability.                                                to manage the risk the best they can, and price the
Semi-scheduled generators such as wind and solar                                                                                 residual risk into the PPA price. However, with negative
farms, now face increased exposure to negative price         The rule change is aimed at curbing the practices of                prices likely to become more common before they
risk as they will not be permitted to simply turn down       some semi-scheduled generators deviating significantly              become less common, renewable generators who can
generation when the spot price falls below zero.             from their dispatch targets instructed by AEMO                      best mitigate and manage this risk will have a significant
                                                             by curtailing export in response to negative price                  competitive advantage.
The rule change effectively limits a semi-scheduled
                                                             fluctuations, i.e. managing the negative price risk.
generator’s ability to not export electricity during times                                                                       Parties currently negotiating PPAs are carefully
of negative spot prices, i.e. adjust their output without    AEMC considered that negative price curtailment by                  watching and waiting to see how this rule change
an updated dispatch instruction from the Australian          semi-scheduled generators without rebidding or waiting              will be administered by AEMO – creating yet more
Energy Market Operator (AEMO) or without                     for an updated dispatch target materially impacts                   uncertainty and hence delay in closing agreements and
a valid rebid.                                               AEMO’s ability to maintain power system security.                   progressing project investment, financing, construction
                                                             That may be true, however requiring semi-scheduled                  and ultimately new renewable energy generation.
Many wind and solar PPAs provide that the financial
                                                             generators to essentially operate as scheduled
“swap” of a fixed electricity price for the floating spot                                                                        With almost monthly announcements of coal generator
                                                             generators imposes a large revenue risk on renewable
price only occur (or settle) when the spot price is                                                                              retirements being brought forward, and the frailty of
                                                             generators – a risk that they (and their financiers) could
positive, i.e. above $0. This agreement was often                                                                                ageing coal generators on show every time they fail
                                                             not have reasonably anticipated.
required by offtakers as a way to manage their financial                                                                         in hot weather, perhaps regulators should focus on
exposure under the PPA. The positions essentially sets       The amendments action one of the Energy Security                    encouraging cheap reliable, predictable, renewable
a maximum downside per MWh the offtaker must pay             Board’s (ESB) recommendations for interim security                  electricity generation firmed by energy storage
the generator.                                               measures which are designed to improve system                       technology – this is what is going to keep the lights on
                                                             security and market efficiency. The intention is that               in 5 years, and after all that is the whole point right? 
Many generators accepted the “negative price risk”
                                                             these will also assist in improving AEMO’s price and
on the basis that they would not be paid under the
                                                             dispatch forecast accuracy. These are admirable goals,                read more
PPA for generation when the spot price was negative,
                                                             however, imposing additional revenue risk on renewable
however they assumed they could reduce generation
                                                             generators which could not have been anticipated at
at these times so they would not be exposed to the
                                                             the time the project was committed, together with the
negative price.
                                                             constant uncertainty of MLF, curtailment etc create yet
The rule change now requires semi-scheduled                  more regulatory uncertainty for investors.
generators to comply with the MW dispatch level
specified by AEMO during all dispatch intervals and          What now?
observe a cap in generation during semi-dispatch             Generators need to start preparing now for what they
intervals. Under previous arrangements, there was            will do when negative prices next arise. For instance,
no explicit restrictions on semi-scheduled generators        generators should consider whether their existing
deviating below the nominated dispatch levels in order       dispatch procedures remain fit for purpose, particularly
to reduce their exposure to negative prices.                 automatic dispatch systems that automatically
                                                             reduce generation in response to a forecast negative
                                                             price period.
The rule change is aimed at curbing                          We know generators are also carefully considering the
the practices of some semi-scheduled                         change in law provisions of their PPAs. Provisions that
generators deviating significantly from                      were included to deal with COGATI, the NEG, or the
                                                             myriad of other policy thought bubbles from regulators
their dispatch targets instructed by                         and government over the last 5 years are now being
AEMO by curtailing export in response                        considered in the context of this latest rule change.
                                                             The challenge in most change of law provisions will be
to negative price fluctuations, i.e.                         that this rule change does not affect the project per se,
managing the negative price risk.                            rather it affects the business model of the project.

                                                                                       New Energy Quarterly – Winter 2021 – 14                                                                New Energy Quarterly – Winter 2021 – 15
New Energy Quarterly The Rise of Dispatchable Renewables - Hamilton Locke
Authors:                                                                                                                     Authors:
Battery industry given                                                         Matt Baumgurtel and David O’Carroll            Redesign of the NEM                                                           Matt Baumgurtel and David O’Carroll
                                                                               First published:                                                                                                             First published:
renewed charge                                                                 04 May 2021                                    beginning to take shape                                                       06 May 2021

The battery storage industry in renewables has
been given a major shot in the arm by the recent
announcement of the Australian Energy Market
Commission (AEMC) of rule changes that will
incentivise renewable generators who use technology
that dispatches electricity quickly to respond to
changes in grid frequency.
The draft ruling published on 22 April 2021 proposes
the introduction of new market ancillary services in the
NEM to allow the Australian Energy Market Operator
(AEMO) to procure fast frequency response to help
control grid frequency following sudden and unplanned
generation or power system outages. The aim of these
services will be to lower the overall cost of frequency
control ancillary services (FCAS) relative to expected
future costs.
This has come about as a result of a rule change
request proposed by Infigen Energy to introduce
spot‑market arrangements for fast frequency response
to help efficiently manage system frequency. These                                                                                                                                       2. backing up power system security by ensuring
new FCAS will be similar to existing services but would                                                                          Update: Energy Ministers met on 11 June                    measures are in place to manage more variable
operate much more quickly to address the high rates of                                                                           2021 as part of the Energy National Cabinet                renewable energy without AEMO intervention;
change of frequency in the system, which have come                                                                               Reform Committee. They noted the Energy                 3. unlocking benefits for all energy consumers of
in part due to the increasing uptake of inverter-based                                                                           Security Board’s (ESB) work to deliver the                 recent changes including solar PV, batteries and
generation in the NEM such as wind and solar PV and        The announcement of the draft ruling is in keeping                    Post-2025 Market Design program, with                      smart appliances; and
demand-side resources.                                     with AEMO’s desire to ensure system security, ie                      final recommendations to be delivered in the            4. opening the grid to cheaper large-scale renewables
                                                           the availability of dispatchable electricity generation               following months.                                          by putting generation and transmission together to
The introduction of these “very fast” FCAS would                                                                                                                                            minimize the costs of transformation.
respond to changes in frequency in less than two           to respond to fluctuations in the grid. As we have                    We also note that there has been increasing
                                                           highlighted in previous articles on the topic (see here               criticism of the ESB’s NEM reforms by key
seconds, rather than six seconds, which is the                                                                                                                                           One of the notable options put forward is to require
                                                           and here), the ability of battery storage technologies                industry players (such as leading renewable
current fastest market. The intention is that this will                                                                                                                                  electricity retailers – both big and small – to pay the
                                                           to respond at relatively lightning speeds to meet grid                energy developer, Neoen) as being ‘rushed’ and
make the system more economically efficient by                                                                                                                                           owners of dispatchable generators to guarantee future
                                                           demand, the continued increase globally in their use                  ‘unquantified.’ As flagged in our original article
reducing the overall costs of managing power system                                                                                                                                      capacity to support the grid in times of peak demand.
                                                                                                                                 as an area of key concern, criticisms have largely
frequency compared to current arrangements or other        and the steady decrease in costs are all factors which                                                                        This would include buying electricity from old coal
                                                                                                                                 focused on the proposed new mechanism – the
                                                           the AEMC has recognised in promoting this form of                                                                             generators, essentially providing them with a steady
arrangements to produce different types of frequency                                                                             physical retailer reliability obligation (PRRO) - for
                                                           technology through the proposed rule changes.                                                                                 revenue stream into the future which would incentivise
response. The draft ruling also envisages that these                                                                             propping up the revenue of old coal generators.
                                                                                                                                                                                         them to remain open. If this option is to be adopted
new spot markets will drive innovation in the provision    The introduction of these new ancillary services is to                                                                        and implemented, one would question how this is going
of various combinations of essential system services       be welcomed as it equates to regulatory support for                                                                           to assist with Australia’s climate change commitments.
from different technologies.                               dispatchable renewable electricity generation which is             On 30 April 2021, the Energy Security Board (ESB)          Indeed, it is hard to see how this option would be
                                                           targeted to play a fundamental role in replacing retiring          released a shortlist of options for the redesign of the    anything other than regressive.
It is also proposed that arrangements for these new                                                                           National Electricity Market (NEM).
services would be the same as those for existing           coal generators over the coming years. Fast frequency                                                                         A final round of consultation with stakeholders is
services, including arrangements for registration,         response will be essential in keeping the grid stable as           Following consultation with industry and government,       taking place – with submissions closing on 9 June
scheduling, dispatch, pricing, settlement and              we move towards a high volume of renewable electricity             the options under consideration have been narrowed         2021 - prior to the ESB providing advice to the Energy
                                                           in the grid.                                                      since the release of the ESB’s “post 2025 market           National Cabinet Reform Committee by mid-2021. The
cost allocation.
                                                                                                                              redesign directions paper” published in January 2021.      full picture of the new NEM will likely then become a
                                                                                                                              The ESB has stated that the options provided are to        lot clearer. 
                                                             read more                                                        address four critical areas:
                                                                                                                              1. preparing for old coal retirement by facilitating         read more
                                                                                                                                  the timely entry of new generation, storage and
                                                                                                                                  firming capacity and an orderly retirement of ageing
                                                                                                                                  thermal generation;

                                                                                    New Energy Quarterly – Winter 2021 – 16                                                                                      New Energy Quarterly – Winter 2021 – 17
Big Boost for Batteries in
                                                                                  Authors:
the Redesigned NEM                                                                Matt Baumgurtel and David O’Carroll

AEMC’s recent proposed rules changes are designed            These additional services are all the more necessary
to facilitate and financially incentivise battery storage    as the transition takes place from a system with
system owners in the National Electricity Market (NEM).      centralised coal and gas-fired thermal generation to
But will these reforms have the desired effect?              a system with a diverse portfolio of inverter based
                                                             energy sources. With this transition, there will be
As highlighted in our recent bulletin on the topic, the
                                                             much less inertia in the system which was previously
first of these reforms comes via a draft plan designed
                                                             provided by large spinning coal-fired generators. At
to better integrate energy storage technologies in the
                                                             lower levels of operating inertia, faster and/or more
NEM and to make it easier for small batteries to earn
                                                             frequency control services will be required to stabilise
extra income and to reduce the logistic hurdles large
                                                             the system frequency within the existing system
batteries have in participating in the NEM.
                                                             operating standards.
Included in this is the introduction of a new registration
                                                             The introduction of FFR services is to be welcomed for
category, the Integrated Resource Provider (IRP),
                                                             system security but should also incentivise an uptake
which will allow storage and hybrids to register and
                                                             in dispatchable technology ownership by providing an
participate in a single registration category rather
                                                             income stream for batteries, aggregators and hybrid
than under two separate categories. The intention is
                                                             businesses and other fast responders that are able to
that market participants with batteries will no longer
                                                             rapidly respond to fluctuations in grid frequency. Not
need to register twice to draw energy from the grid
                                                             only will the new ancillary services provide certainty to
and send it out and that additional revenues will be
                                                             the market that sufficient resources are available, but
unlocked for home and business battery owners by
                                                             they will also provide clear price and investment signals
participating in new aggregation services provided by
                                                             to new resources.
new aggregator businesses.
                                                             As always, the proof will be in the pudding but in
AEMC has also amended the framework to recover
                                                             principle these reforms are a big step in the right
non-energy costs based on a participant’s consumed
                                                             direction and should foster innovation by promoting
and sent out energy, irrespective of the participant
                                                             technologies that will keep the future electricity
category in which it is registered. Consumed and
                                                             system secure as the energy system transitions
sent out energy will be measured separately for all
                                                             to one with a high concentration of variable
market participants and not netted at the connection
                                                             renewable technologies. 
point. Non-energy cost recovery would be based on a
participant’s gross energy flows, i.e. gross consumed
energy (ACE) or exported energy (ASOE) during
relevant intervals, rather than the category a participant
is registered in. According to AEMC this change
supports the principle that the costs of providing these
services to support the power system should be funded
by those who benefit from them.
Commencing in October 2023, the other major AEMC
reform will create new markets for Fast Frequency
Response (FFR) to financially reward ultra-fast energy
providers who deliver energy to the grid in just one
to two seconds to stabilise system frequency. This
will operate similar to the existing arrangements
for frequency control ancillary services, providing
an additional frequency control option with the aim
of reducing the overall cost of managing power
system frequency.

                                                                                      New Energy Quarterly – Winter 2021 – 18   New Energy Quarterly – Winter 2021 – 19
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