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Liability for specific scenarios

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16 March 2023

Contents

Battery Storage Systems

There are 2 principles in the Renewable Energy (Electricity) Act 2000 (the Act) that are relevant when considering Renewable Energy Target (RET) liability for battery storage systems.

  • Liability applies to electricity acquired from a network operator or directly acquired from a generator.
  • Liability for electricity should not be double counted.

The Clean Energy regulator takes the following position regarding liability for battery storage systems:

  • If a battery storage system is connected to a transmission network managed by AEMO or the Northern Territory Electricity System and Market Operator (NTESMO), RET liability applies only to auxiliaries and other electricity used in the operation of the storage system. Liability does not apply to the amount of electricity that is later acquired by AEMO or NTESMO. In general, this means that the owner of the battery storage system is liable for the amount of electricity imported from the network, less the amount of electricity exported back to the network.
  • Where a battery is installed on a remote network, where the network capacity is 100 MW or more, the battery owner is liable for the entire amount of electricity acquired to charge the battery, because the electricity will not later be acquired by AEMO or NTESMO.
  • If a battery storage system with a capacity of 5 MW or more is connected to a distribution network, the owner of the battery storage system is liable for any electricity that is not later acquired by AEMO or NTESMO.
  • If a battery storage system with a capacity of less than 5 MW is connected to a distribution network, the owner of the battery storage system is not liable under the RET for any electricity imported from the network. In these cases, the electricity has already been acquired by an electricity retailer and the electricity retailer is liable for those acquisitions.

Battery storage system owners must ensure that appropriate metering exists and records are maintained. This guidance can also be used for most other energy storage technologies including pumped hydro energy storage. For further information, please contact us.

Power Station Auxiliaries

For power stations that acquire electricity, there are circumstances where they may not be liable to report that electricity. Electricity imported directly by power stations from the grid is not considered a relevant acquisition if the following conditions are met:

  1. the electricity is used only to run the power station, and
  2. the power station does not import more electricity than they export to the grid over an assessment year.

If an electricity retailer is acquiring electricity and supplying it to a power station (i.e., a power station not owned by the electricity retailer) for auxiliary use, the electricity retailer is still required to report that electricity as a relevant acquisition.

Where an entity imports electricity for multiple purposes, any electricity not used by the power station exclusively is a relevant acquisition of electricity and must be reported.


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