Submission to AER re Ergon Energy Application for ring-fencing waiver

This submission was made to the Australian Energy Regulator (AER), in response to Ergon Energy’s application for a waiver of ring-fencging requirements in relation to up to 20 grid utility storage system (GUSS) units. The GUSS units are grid connected energy storage facilities (large-scale batteries) that Ergon intends to build to provide energy services to remote areas of its network. PIAC opposed the application, on the grounds that the ring-fencing provisions were in place to protect consumers and must, therefore, be enforced. This is consistent with PIAC’s stated policy position that wherever possible, monopoly energy businesses should be required to procure energy storage services with operating expenditure, rather than by building and owning infrastructure.