This submission responded to the Australian Energy Market Commission’s (AEMC) discussion paper, Integration of Energy Storage – Regulatory Implications (the discussion paper). The submission covered three key subjects. Firstly, the submission expressed the concern that the monopoly power of electricity networks could stifle the development of an innovative and dynamic energy service sector. Secondly, the submission expressed the concern about the effectiveness of ring-fencing arrangements for subsidiaries of networks. Where these arrangements cannot be effectively implemented, PIAC asserted the view that outcomes for consumers would be inferior to those that could be achieved through a blanket prohibition on any form of network ownership of storage assets. Finally, the submission put forward arguments about introducing the prohibition on network ownership of storage assets immediately, rather than adopting a ‘wait and see’ approach. In addition, the submission also acknowledged the efforts of the AEMC to engage with consumer representatives on this issue.
