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Williams, Jessica --- "Incentivising Private-Investment In Utility-Scale Battery Storage In The National Electricity Market" [2021] UNSWLawJlStuS 44; (2021) UNSWLJ Student Series No 21-44


INCENTIVISING PRIVATE-INVESTMENT IN UTILITY-SCALE BATTERY STORAGE IN THE NATIONAL ELECTRICITY MARKET

JESSICA WILLIAMS[1]

I INTRODUCTION

Adequate and resilient infrastructure for energy storage is crucial to success in the renewable energy transition. As Australia edges closer to 100% renewable energy, the need for synergy between technological advances, policies, and regulations, is increasingly evident to promote a competitive and profitable market for battery storage. This essay will demonstrate that Australia’s current policies are inadequate to promote long-term private investment in utility-scale battery storage. Discussion will then turn to how Australia can better incentivise private investment and uptake of utility-scale batteries by comparison to the approach taken in comprable markets internationally.

II ENERGY STORAGE IS ESSENTIAL

Global warming and large-scale pollution have led the international community to attempt to abate carbon emissions as recommended by the Intergovernmental Panel on Climate Change.[2] Culminating in 173 nations, including Australia, ratifying the Paris Agreement.[3] This threat of climate-change is compelling a shift away from centralised fossil fuel electricity generation and towards dispersed, renewable energy-based model involving technologies such as solar and wind.[4] The growth is rapid, and even despite supply chain disruptions due to COVID-19, renewable energy continues to rise at about 1% per year.[5]

The intermittency of renewable energy sources poses a major technical issue in integrating renewables into the grid.[6] Grids require continuous balance between supply and demand and despite infinite abundance of wind and solar, it is not continuous.[7] To avoid imbalance, leading to diminishing power quality and curtailment of energy, storage must be developed to compensate for times when renewable resources are not available.[8]

III WHY BATTERY STORAGE?

Lithium-ion technologies have been the greatest breakthrough in electrochemical energy storage, as they offer a compromise between market readiness, cost, lifetime, and energy density.[9] This allows them to be used as a flexible, reliable, and efficient way of storing energy for later use.[10] Immediately-dispatchable storage serves numerous benefits including matching demand and peak reduction, providing network congestion relief and infrastructure deferral, rapid frequency, and voltage. All of these subvert the possibility of blackouts.[11] They can respond quickly and exactly to changes in demand for energy which is essential to stabilise the grid amidst intermittent generation.[12] Additionally, batteries are relatively quick to install, versatile and can be deployed in a wide range of locations, on different scales.[13] This makes batteries a crucial enabler in reaching up to 100% of renewable energy.[14]

Historically, cost-effectiveness has been a major problem for bulk-battery storage systems. However, recent reductions in price has resulted in an uptake of such facilities.[15] Bloomberg New Energy Finance’s 2020 Report predicts that current lithium-ion pricing of approximately US$137 per kWh will drop as low as US$100 per kWh by 2023.[16] These declining costs presents a valuable opportunity for batteries to enter the market. However, most of the battery systems operating or planned in Australia require government subsidy or assistance.[17]

IV CURRENT INCENTIVES

Australia’s National Electricity Market (NEM is the longest interconnected power system in the world.[18] It services the eastern and southern states [19] and accounts for approximately 80% Australia’s total electricity consumption.[20] Since the inception of the NEM in 1998,[21] a range of state and federal level incentives have been introduced to incentivise development. As outlined below, incentives and polices are inconsistent between a state/ territory and federal level.

A Current Renewable Energy Targets

1 Federal

The federal Renewable Energy Target (‘RET’) sought to achieve of 33,000 GWh of additional electricity from renewable sources by 2020.[22] The RET is divided into schemes the Large-Scale Renewable Energy Target (‘LRET’) and the Small-Scale Renewable Energy Target (‘SRET’).[23] The LRET is relevant to Utility-scale storage. Under the LRET, owners create renewable energy certificates for each megawatt hour of power generated. These are purchased by consumers per their obligations. [24] The RET does not reference storage of any kind. At the federal level, there is no target post-2030.[25] The federal government has expressed that net zero by 2050 is ‘achievable’ but has not made a formal commitment.[26]

2 State

Without an integrated national climate policy, states and territories lead through individual targets and frameworks. Despite differences, it is notable that all have committed to net zero emissions by 2050 or earlier.[27]

Tasmania, South Australia, and the ACT have the most ambitious targets across the NEM. Notably, Tasmania has legislated a world-leading target of 200% by 2040,[28] made possible due to favourable terrain and existing hydropower storage.[29] Tasmania is on-track to be 100% self-sufficient by 2022,[30] and is the only state with a target greater than 100% by 2030.[31] South Australia has a target of 100% net renewable energy generation by 2030.[32] The Climate Action Plan also indicates South Australia’s vision to produce 500% renewable energy by 2050.[33] The ACT has set and achieved its target of net 100% renewable energy by 2020.[34] Victoria and Queensland both have a renewable energy target of 50% of energy from renewables by 2030.[35],[36]

NSW has legislated the largest renewable energy commitment in over a decade, pledging to build 2-gigawatts of storage and 12-gigawatts renewables by 2030.[37] The Electricity Infrastructure Investment Act safeguard includes legislative objectives for generation, long-duration storage and firming infrastructure, including a process for the consumer trustee to construct each type of infrastructure and award ‘long-term energy supply agreements’.[38] This provides certainty to investors regarding revenue, and is projected to attract $32billion in private investment.[39]

B Grant Funding and Investment

1 Federal

The Australian Renewable Energy Agency (ARENA) and the Clean Energy Finance Corporation (‘CEFC’) work ‘hand in glove’ to drive investment in renewables and innovation.[40] ARENA primarily makes grants and the CEFC, loans and investments.[41]

Since establishment in 2011,[42] ARENA has aimed to address barriers to uptake of renewables, assist energy technologies meet the needs of users and advance the development of renewable technology.[43] It has invested AUD$1.77 billion in renewable energy in Australia,[44] of this AUD190 million has been invested in storage technology, [45] including approximately AUD35 million coming from battery or hybrid technologies.[46] For every investment ARENA made into battery storage, it attracted over five times that amount in additional, mainly private investment.[47]

The CEFC invests AUD$10 billion on behalf of the Australian Government to catalyse private-sector investment and accelerate the transformation towards a competitive ‘carbon-constrained’ economy.[48] Notably, it has invested, AUD160 million into construction of Victorian Big Battery[49] and $94 million into the Kennedy Energy Park.[50]

2 State

Some state governments provide grant funding to encourage uptake for emerging technologies, including storage.

The NSW Emerging Energy Program provides grant funding to support pioneering, large-scale storage, and electricity projects in NSW. There is AUD$75 million of grant funding available.[51] There are two funding streams: capital projects and pre-investment studies.[52] Grants have been awarded to five capital projects including three large-scale lithium batteries, totalling ~AUD$47.5 million for a total capacity of 214MW.[53] Grant funding has been awarded to nine investigative projects,[54] totalling ~AUD$10.1million, with the potential to deliver 2,700MW of electricity and leverage AUD$2.7 billion in private investment.[55] Successful applicants can also apply to the CEFC’s Dispatchable Power Program for funding.[56] The first round of CEFC funding is specifically targeted at utility-scale battery and $125 million has been earmarked for these projects.[57] Fixed-rate CEFC financing is also available, enhancing the potential bankability of projects.[58]

South Australia’s AUD$50 million Grid Scale Storage Fund aims to accelerate roll out of grid-scale infrastructure to address intermittency in the South Australia’s power supply.[59] The project aims to validate the versatility of batteries and provide a pathway for reform.[60] Additionally, the Renewable Technology Fund provided AUD$150 million through grants, loans and investment to projects aiming to support the reliability and security of the electricity network.[61] The tender specifically called for proposals for renewable energy firming and Bulk Energy Storage, especially that will provide synchronous inertia, on-demand electricity, improve system security and reliability, competition, and further development.[62] This fund intended to catalyse private sector investment.[63]

Victoria’s Renewable Energy Action Plan invests AUD$146 million to support sector growth, empower communities and consumers and modernise the energy system.[64] The government committed $25 million to energy, with 40 MW minimum battery storage to provide a capacity of at least 100 MWh,[65] to encourage private investment.[66]

C Reverse Auctions

Reverse auctions are a crucial part of the ACT and Victoria’s plan to achieve their renewable energy targets.[67] Only the ACT has been successful in supporting storage systems.[68] Successful bidders of the fifth renewables reverse auction will build large-scale battery storage systems to support the grid.[69]

V CHALLENGES FOR UTILITY-SCALE BATTERY STORAGE

Private sector adoption of energy storage has been limited due to high capital requirements and barriers to financing.[70] It is important to remove unnecessary barriers and increase certainty in forecasting cashflows in order to increase private investment, market and regulatory reform,

A Design of the NEM

Rapid transition to distributed renewable energy generation has increased the demands on the NEM that challenge the original design that envisages unidirectional energy flows.[71] This has led to proposals to reform the market to deliver a long-term, fit-for-purpose market framework for a renewable-focused market future.[72] The need is compounded by the fact that the share of renewables in the National Electricity Market exceeded 30% for the first time in 2020, with a record 7-gigawatts new capacity installed throughout Australia.[73]

B Emphasis on Grant Funding

Subsidies and grants are a useful tool to encourage the initial uptake of new technologies in the market, especially when they are not commercially viable.[74] However, large-scale batteries have developed rapidly, costs are dropping and trial projects, such as the Ballarat Energy Storage System, demonstrated the ability to trade in the wholesale markets and provide network stability. [75] Although grant funding is effective, it is costly and does not allow a broad range of participants. The planned construction of the first non-government supported battery in 2022 in Deer Park, Victoria,[76] suggests that the market is increasingly commercial. Although subsidies and grants have been essential to implementation of the technology, other incentives that lower the barriers to entry, could be more cost efficient.[77] As the market for battery storage becomes more commercially viable establishing an active market could be better affected by lowering batteries to entry.[78]

C Uncertainty from lack of National Policies

As acknowledged by AMEC, [79] policy discontinuity, poor design and a lack of an integrated climate and energy framework has negatively affected investment continuity in the NEM, as it is unclear which technologies likely have a future in the market.[80] The lack of an overarching national energy policy post-2020 has led the States and Territories to adopt individual roadmaps and policies, causing inconsistency in what should be an integrated system.[81] The issue was exacerbated by the Prime Minister Abbott breaking his pre-election commitment and reducing the RET in 2015 by approximately 20% in 2015.[82] This injected significant uncertainty into the market and halted investment.[83]

D Bankability

Private sector investment requires certainty and stability in forecasting cashflows to support investment decisions; otherwise, investment is unachievable. Unlike renewable energy projects that generate revenue based on output, storage projects are limited to wholesale price trading and provision of ancillary services.[84] Currently, potential investors are unsure whether there will be sufficient revenue to recover upfront costs, let alone make a profit, making it challenging to secure financing.[85]

1 Wholesale Price Trading

Forecasting revenue for storage systems is challenging, as supply and demand in the network is constantly changing. This makes it almost impossible to predict short-run future pricing based on previous data, therefore hard for companies to program batteries to profit off the variability in energy prices. This makes it challenging to make a profit via arbitrage.[86]

The reduction of settlement periods to 5-minutes from this October will benefit fast-response technologies like batteries as it is implicit that fast response technology will elicit a faster response to changes in the market.[87] A more granular mechanism would likely enable batteries to better profit from price spikes and drops, enabling batteries to more readily engage in trading.[88] Notwithstanding the difficulty in identifying high-price events given that the causes are varied, the ability to engage in trading strategies is limited by storage capacity, the dispatch rate, transmission infrastructure and system degradation.[89]

Grid-scale batteries are a primary example of how the current National Electricity Rules are not suitable in the rapidly changing electricity environment. Batteries have the power to both export and import energy, and is dispatchable, therefore able to provide grid stability service (including FCAS). AMEC’s draft determination the addition of a new market participant category, the ‘Integrated Resource Provider’ (‘IRP’) fully captures market participants with bi-directional energy flows.[90] These changes, in light of the ESB post-2025 market design would accommodate new business models, bi-directional flows in which both demand and generation participants respond to price based on cost preferences.[91]

2 Ancillary Services

Batteries are undercompensated for the value they provide to the market. For example, battery storage benefits the surrounding network area by reducing the possibility of curtailment and easing the pressure on network infrastructure, thereby improving loss factors and congestion.[92] However, it is not possible for one project to ‘charge’ another for the benefits provided without an agreement in place.[93]

Additionally, providers of ancillary services in the NEM can profit off providing the services. There are three markets providing Frequency Control (‘FCAS’), Network Support and Control and System Restart services, each with their own pricing mechanism.[94] Lithium-ion batteries are well placed to participate in FCAS, as they can discharge suddenly to aid voltage and frequency controls.[95] However, this poses several challenges. Firstly, as the ancillary market can require the battery to charge or discharge out of line with optimal trading. Secondly, the market is shallow and as additional providers enter, profitability will quickly reduce.[96] Thirdly, overuse of batteries could lead to performance erosion and additional maintenance costs.[97] Batteries are currently not compensated for this potential loss.

However, AMEC’s new fast frequency response market ancillary service, introduces two new market ancillary services in the NEM complemented by additional reporting requirements.[98] The final rule will introduce two new market ancillary services; the ‘very fast raise service’ and ‘very fast lower service’. These will assist in controlling system frequency and consequently the security of the electricity system.[99] These fast frequency response services will operate more rapidly that existing services, thereby reducing the overall expense in managing power system frequency relative to the present. This will assist the innovation in faster responding technologies.

E Regulatory Barriers

Storage deployment presents a unique challenge in markets as the system is operated in a hybrid between the cost-of-service and reliance on markets. Batteries can be classified as either generation, transmission, or distribution.[100] Participants in the NEM face numerous costs, including NEM participant fees and charges. Currently, as battery storage is being treated as both load and generation under the NER, this is inconsistent with charges incurred by other market participants.[101]

VI RECOMMENDATIONS FOR REFORM

Considering the challenges above, there are several market and regulatory changes that can be made to incentivise private investment in storage. These are outlined below with strong reference to the approach in the United States and European Union. Both are leaders in renewable energy storage and share a similar legal structure as several jurisdictions with their own laws are unified by a central market and overarching body of laws.

A Tax Incentives

The viability of battery storage systems is increasing as costs continue to decrease, the products become more efficient, and there is greater regulatory support. However, whilst costs are continuing to fall, financial incentives are important until the costs begin to fall.[102] The United States adopted the approach of using tax credits and accelerated depreciation to encourage investment in storage. The Federal Investment Tax Credit (‘FTC’) is a 20% energy tax credit for private investment in grid-connected energy storage.[103] To be eligible, the system must be charged from the grid no more than 25% of the time.[104] There have been efforts to broaden the program to stand-alone batteries, gaining support from the federal government in the introduction of the Energy Storage Tax Incentive and Deployment Act 2021, which would extend the incentive to batteries provided with a capacity of at least 5kWh.[105]

The ITC is accessible in conjunction with the modified accelerated cost recovery system (‘MACRS’) depreciation deduction where the installed storage system is owned privately.[106] The MACRS class life of an energy storage system is 5 or 7-year, depending on the percentage of total stored energy supplied by renewable sources.[107] This scheme has been found to be a significant driver of private investment.[108]

Australia should initially adopt a tax credit system to continue to drive uptake of energy storage. This policy is valuable even though price declines in lithium-ion battery storage have already made it a price competitive alternative. Adopting these incentives would likely encourage massive energy storage growth, especially coupled with storage mandates.[109] As tax incentives are effectively a grant, and as discussed above, this is not ideal in the long-term, this would be temporarily adopted to accelerate rate of adoption of the technology.

To encourage early adoption, the ITCs should begin at 30% and progressively decline to 0% in 2050. 30 percent, in all likelihood, is overcompensation, however this approach was adopted successfully in the US to encourage adoption of solar installations. Accelerated depreciation reduces tax liability and accelerates rate of return for the investment which would likely reduce project risk and the cost of financing.

B Legislative Mandates: The role of Renewable Portfolio Standards and Energy Storage Targets

1 Renewable Portfolio Standards

Renewable portfolio standards (‘RPSs’) are regulatory mandates requiring a specific quantity of renewable energy generation. Although historically RPS’ have focused on generation, the structure of the RPS as a quantity-based instrument be utilised to drive storage.

RPS laws are used in 29 states across the US.[110] It is estimated that of the 120GW of renewable capacity built since 2000 in the US, almost 56% was at least partially driven by such policies.[111] However, there is wide variation between the states. Similarly, the United Kingdom’s Renewable Obligation,[112] is like a renewable portfolio standard as it requires electricity suppliers in the United Kingdom to source an increasing proportion from renewable sources. The effectiveness of the obligation is evident in the steady rise in renewable electricity produced from 1.8% to over 25% since 2002.[113]

An attractive variant on the RPS has been the addition of the clean peak standard. This recognises that electricity demand varies over the course of day, causing prices to peak at times of greatest electricity use, in response to high demand.[114] In 2018, a clean peak standard was established in Massachusetts.[115] This target is designed to provide incentives to clean energy technologies that can supply electricity or reduce demand during peak periods. This indirectly incentivises the uptake of battery storage.

2 Storage Targets

Due to the increase in variable energy sources (i.e. solar and wind), it has become clear that more storage is necessary to ensure it is available when needed and to avoid curtailment of energy when supply exceeds demand.[116]In response, California was early to adopt an energy storage target to encourage development.[117] In 2013, the Californian Public Utilities Commission (‘CPUC’) adopted a 1,335 megawatt (MW) procurement mandate for electricity storage by 2020. The projects have to be operational by no later than the end of 2024.[118] This mandate was first of its kind worldwide, and goes beyond traditional storage incentives to mandate utilities to install prescribed capacities. Interestingly, the CPUC made large-scale hydro projects ineligible, ensuring that the target is met through smaller developments. This fosters the emerging technologies and creates opportunities for developers and contributors of new storage solutions.[119]

Concerns were initially raised regarding the costs of selected projects, and the cost recovery. This was resolved by allowing flexibility in the types of storage projects procured and in the procurement timeframe. To make sure that the prices remain affordable, the utilities must justify projects to the CUPC, with a strong focus on cost-effectiveness in determining which project to adopt. California also provides strong research and development support to energy storage (approximately $100 million a year), these are crucial to the ongoing development and scaling o technologies.

3 What approach is most suitable for the NEM?

Similar to California, Australia would benefit from adopting an ‘energy security target’ to send a market signal to investors that the storage technology is a worthwhile investment, reducing uncertainty brought by changing policies. For consistency it would be optimal to adopt a centralised approach along the NEM, either by creating a federal target or uniform policies across the eastern states. Penalty provisions could be beneficial to maintain investor confidence in the effectiveness of the storage.[120] These targets should be mandatory and long-term to encourage investment.[121] This is reasonable if not conservative given the approach of the states. All generators of renewable technologies including batteries should be included and the policies should remain for the long-term to encourage investment.[122] Australia could also look to adopt a ‘clean peak standard’ like the Massachusetts model, to promote investment in energy storage, especially those connected to wind and solar farms.

C Ancillary Market Reforms

Batteries are not fully compensated for the benefits they provide to the market. Reforms to the ancillary market, adequately reflecting the value provided to the market would encourage private investment.

Large-scale battery storage would be facilitated by reforms to the ancillary market rewarding batteries for providing regulation services and their performance in the market. Novel approaches have been adopted across the UK, US, and Germany. The UK National Grid’s Enhanced Frequency Response Tender sought suppliers to provide sub-second rapid response frequency reserves. Eight battery storage contracts were entered into for 4-year contracts with eight battery storage facilities for prices between GBP 7 and 11.97/MW/h.[123] The tender to procure enhanced frequency response was oversubscribed 7 times the required capacity, with 1.2GW of battery capacity.[124] In Germany, the grid operators and European power exchange have established a transparent market system for flexibility providers who would like to participate in the congestion management process.[125]

The US Federal Electricity Regulatory Commission’s Order 755, directed that frequency regulation services were to be compensated based on performance.[126] Consequently the PJM interconnection created two different signals, a conventional and fast signal, to give more responsive technologies the advantage over conventional technology.[127] The US’s Midcontinent Independent System Operator’s ramping product, is procured on a mixture of day-ahead and real-time basis.[128] All dispatchable resources in the territory can participate. Resources providing the ramping services are compensated for the opportunity cost, based on the other products in the market.[129]

The US’s approach is likely to be the most successful in Australia as it compensates for the opportunity cost, which has been a concern for battery owners in Australia. Additionally, like FERC 755, a performance-based reward system for ancillary services would benefit the fast-dispatch technology offered by batteries. The approach in the UK, whilst it was initially effective was only for a limited time frame, which would likely create investor uncertainty. Similarly, the German approach is voluntary, making it challenging to reliably service the ancillary markets.

The Energy Security Board (‘ESB’) recognised that the current energy-only price signals are no longer adequate to deliver the level of firm capacity in the NEM. Consequently, their 2025 proposals recommended that a capacity price mechanism be implemented.[130] This has two primary implications:

• Valuing capacity will enable the market participants to provide the required reliability by ensuring adequate resources are available in the market

• All resources, will be eligible for participation at the new capacity mechanism, and available when reliability is at risk

It is expected that the new mechanism would encourage renewable alternatives, including construction of batteries, as coal gradually phases out.[131]

D Improved Price Signalling

Locational Marginal Pricing would provide batteries with more granular information regarding concentrations of generation, load, constraints in the network and volatile prices.[132] This would provide clearer price signals, increasing investment in points in the grid where demand is underserviced.

US regions with high current or forecasted battery deployment tend to be regions that have instituted locational marginal pricing. For example, California implemented locational marginal pricing in 2009 and currently has the largest amount of utility-scale battery power of any region in the United States. However, it is notable that most of these regions have strong incentives in places for battery deployment.[133]

The EU has adopted Zonal pricing which is simpler and cheaper than nodal pricing. However, uptake of renewables leading to congestion in the EU has led to the suggestion of transition to real-time nodal pricing model. Unlike the US, that uses day-ahead pricing, this would be the first attempt to implement a real-time pricing model which raises challenging computational issues.[134] Despite the complexity, transition to a nodal model would be beneficial as it would facilitate system management with the hundreds of distributed sources.[135]

Shadow locational pricing collected by AMEC suggests that high price variation notes will exhibit persistent price variation signals than the regional reference node. [136] Therefore, despite increased complexity, full-nodal pricing would increase the number of price points, allowing private investors to place batteries in locations with high unserved demand. This would likely lead to better ancillary markets service and increase the ability to engage in arbitrage trading.[137]

E Regulatory Reform

Batteries are unique as they can be both generation and load,[138] this is incompatible with the original design of the NEM. As the technology is relatively new, many markets have unintentionally imposed regulatory barriers to the uptake of the technology. For example, in the UK, it was not until 2021 that a definition for battery storage was settled. Additionally, in May 2020, the UK confirmed that the double-charging balancing costs that has historically disadvantaged storage providers would be removed.[139] Similarly, in 2020, the United States made similar changes by broadening the definition of ‘generating facility’ to include storage devices, both stand-alone and co-located projects (FERC Order No. 841).[140]

To address similar issues in Australia, the AMEC proposal to add an additional category of ‘integrated resource provider’ should be adopted to avoid battery systems having to register in multiple categories.[141] In the short-term this is valuable as it removes batteries to storage systems participating in the market and create a more level playing field. In the long-term this contributes to the two-sided market being developed by ESB.[142]

F Grants for Emerging Technologies

Grant funding is vital when exploring the viability of new technologies and increase the likelihood of large-scale private investment. [143] Demonstration programs funded by government bodies (like ARENA) are critical to establish a track record of success in the technology, therefore encouraging private investment. Continuing to expand the horizon for batteries beyond the current technology is vital to find more efficient technologies. [144] For example, the United States’ Advanced Research Projects Agency-Energy Program and German Government’s energy transition program are currently working on the next generation of battery technologies, specifically focusing on non-lithium metals.[145]

Additionally, the California Energy Commission has invested over USD 130 million a year into the Electric Program Investment Charge Program to support novel projects that improve California’s grid.[146] This included, Hydrogen Modular Storage, long-duration energy storage,[147] and vanadium flow batteries.[148] Furthermore, California’s governor proposed a USD 350million support for long-duration energy storage in the budget revision, forecasting the need for greater long-term storage if the state was to get to 100% renewable.[149]

This suggests that grant funding is essential for the long-term development of the NEM but would best be directed towards emerging technologies, battery or otherwise. It is likely that as the market becomes more competitive, uptake of lithium-ion battery will occur naturally.

VII HOLISTIC APPROACH TO STORAGE

Despite focusing on utility-scale battery storage technologies, the future market will likely incorporate range of technologies that can quickly, flexibly, and reliably match demand.[150] This includes pumped hydro, currently the dominant energy storage method, which can store large amounts of electricity for long durations.[151]

There are several considerations regarding energy storage not discussed in this essay. These include: small-scale batteries and the incentives encouraging adoption of residential batteries, transmission and network upgrades would likely be required to ensure dispatch of energy.[152] Finally, end-of-life battery management and extraction of lithium.[153]

VIII CONCLUSION

Utility-scale batteries are important for Australia to manage the transition to renewable energy as they can be dispatched to address the intermittency of renewable generation. Although prices for lithium-ion battery storage are rapidly dropping, a mixture of mandated portfolio standards, tax incentives, market, and regulatory reforms could make the market more attractive for private investment. These policy changes are likely best integrated into the NEM, as fragmented and inconsistent policies could undermine investor confidence and further delay achieving renewable energy targets.

IX BIBLIOGRAPHY

A Articles/Books/Reports

Blomgren, George ‘The Development and Future of Lithium-Ion Batteries’ (2016) 164(1) Journal of the Electrochemcial Society 5019-5025; Jang Wook Choi and Doron Aurbach, ‘Promise and reality of post-lithium-ion batteries with high energy densities’ (2016) Nature Review Materials 1

Brorwski, Piotr, ‘Zonal and Nodal Models of Energy Market in European Union’ (2020) 13(16) Energies 4182

Faunce, Thomas, James Prest and Dawei Su, ‘On-grid batteries for large-scale energy storage: Challenges and opportunities for policy and technology’ (2018) 5(11) MRS Energy & Sustainability 1

Ferrey, Steven, ‘Efficiency in the regulatory crucible: Navigating 21st century smart technology and power’ (2012) 32(1) Journal of Energy & Environmental Law 1

Moore, Jason, and Bahman Shabani, ‘A Critical Study of Stationary Energy Storage Policies in Australia in an International Context: The Role of Hydrogen and Battery Technologies’, (2016) Energies 9(9), 674

Moorthy, Krishna, Nitin Patwa and Yash Gupta, ‘Breaking barriers in deployment of renewable energy’ (2019) 5(1) Heliyon 66

Pellow, Matthew, Hanjiro Ambrose and Dustin Mulvaney, ‘Research gaps in environmental life cycle assessments of lithium ion batteries for grid-scale stationary energy storage systems: End-of-life options and other issues’ (2020) 23 Sustainable Materials and Technologies 120

Raybould, Blaid, Wai Cheung and Chris Connor, ‘An investigation into UK government policy and legislation to renewable energy and greenhouse gas reduction commitments’ (2020) Clean Technologies and Environmental Policy 22

B Legislation

Accelerated Cost Recovery System 26 U.S. Code § 168

ARENA Act 2011 (Cth)

Electricity Infrastructure Investment Act 2020 (NSW)

Energy Storage Tax Incentive and Deployment Act of 2021 (S. 627)

Federal Electricity Commission

Public Utility Commission of Texas Substantive Rules

Renewable Energy (Jobs and Investment) Act 2017 (Vic)

Renewable Energy Electricity Act 2000 (Cth)

C Treaties

Paris Agreement to the United Nations Framework Convention on Climate Change, opened for signature 22 April 2016, C.N.63.2016 (entered into force on 21 April 2017).

D Other

‘As cost declines and regulatory support boost demand for battery storage, project finance emerges as a viable financing option’, Moody’s (Web Page, online at 20 March 2018) <https://www.moodys.com/research/Moodys-As-cost-declines-and-regulatory-support-boost-demand-for--PR_381076>

‘Australian Renewable Energy Agency Annual Report 2018-19’, Australian Government (Report, 2019) <https://www.transparency.gov.au/annual-reports/australian-renewable-energy-agency/reporting-year/2018-2019-68>.

‘Australian Renewable Energy Agency’, ARENA (Report, July 2021) <https://arena.gov.au/assets/2019/07/arena-at-a-glance.pdf>.

‘Battery Storage Systems Federal Tax Incentives’, Native Solar (Web Page) <https://nativesolar.com/battery-storage-systems-federal-tax-incentives/>

‘Depreciation of Solar Energy Property in MACRS’, Solar Energy Industries Association (Web Page) <https://www.seia.org/initiatives/depreciation-solar-energy-property-macrs>

‘Distributed Energy Resources Market Design Concept Proposal’, New York Independent System Operator (Report, December 2017) <www.nyiso.com/documents/20142/1391862/Distributed-Energy-Resources-2017-MarketDesign-Concept-Proposal.pdf/122a815f-b767-e67f-0a8f-323e5489c2b1>

‘Emerging Energy Program’, Energy NSW (Web Page) <https://www.energy.nsw.gov.au/renewables/clean-energy-initiatives/emerging-energy-program>

‘Energy Storage: Financing Speed Bumps and Opportunities’, PWC (Report) < https://www.pwc.com.au/infrastructure/pwc-energy-storage-financing-speed-humps.pdf>

‘Energy Storage: Opportunities and Challenges of Deployment in Australia’, Australian Academy of Technology and Engineering (Report) <https://www.atse.org.au/wp-content/uploads/2019/01/energy-storage-opportunities-challenges.pdf>

‘Energy Storage’, Clean Energy Council (Web Page) <https://www.cleanenergycouncil.org.au/resources/technologies/energy-storage>

‘Energy superpower plan to turbocharge Renewable Energy Zones and pumped hydro’, Energy NSW (Report, 9 November 2020) <https://energy.nsw.gov.au/energy-superpower-plan-turbocharge-renewable-energy-zones-and-pumped-hydro>

Finance program aims to boost battery storage’, Clean Energy Financing Corporation (Web Page)

‘Five Minute Settlement’, AEMC (Web Page) <https://www.aemc.gov.au/rule-changes/five-minute-settlement>

‘Global Energy Review 2020: Renewables’ , IEA, (Report) <https://www.iea.org/reports/global-energy-review-2020/renewables>

‘Grid Scale Storage Fund’, Government of South Australia Department for Energy and Mining (Web Page) <https://www.energymining.sa.gov.au/growth_and_low_carbon/grid_scale_storage_fund>

‘Grid vs Garage’, AECOM (Report, 13 December 2019) <https://arena.gov.au/assets/2020/04/arena-grid-vs-garage.pdf>

‘Guide to Ancillary Services in the National Electricity Market’, AEMO (Report, April 2015) <https://www.aemo.com.au/-/media/Files/PDF/Guideto-Ancillary-Services-in-the-National-Electricity-Market.ashx>

‘Hydropower / Pumped Hydro Energy Storage’, ARENA (Web Page) <https://arena.gov.au/renewable-energy/pumped-hydro-energy-storage>

‘Innovative Ancillary Services Innovation Landscape Brief’, International Renewable Energy Agency (Report, 2019) <https://www.irena.org/-/media/Files/IRENA/Agency/Publication/2019/Feb/IRENA_Innovative_ancillary_services_2019.pdf>.

‘Integrating Energy Storage Systems into the National Electricity Market’, Office of Best Practice Regulation (Web Page, 19 July 2021) <https://obpr.pmc.gov.au/published-impact-analyses-and-reports/integrating-energy-storage-systems-national-electricity>

‘Integrating energy storage systems into the NEM’, AEMC (Media Release, 15 July 2021) <https://www.aemc.gov.au/sites/default/files/documents/integrating_energy_storage_systems_into_the_nem_-_erc0280_-_information_sheet_-_draft_determination.pdf>

‘Integrating energy storage systems into the NEM’, AEMC (Web Page) <https://www.aemc.gov.au/rule-changes/integrating-energy-storage-systems-nem>

‘PJM Manual 28: Operating Agreement Accounting’, Market Settlement Development Department (Report, 2020) <www.pjm.com/-/media/documents/manuals/m28-redline.ashx>

‘Post 2025 Market Design for the National Electricity Market (NEM)’, Energy Security Board (Report, 22 March 2019) <https://energyministers.gov.au/publications/post-2025-market-design-national-electricity-market-nem>

‘Powering Progress: States Renewable Energy Race’, Climate Council (Web Page) <https://www.climatecouncil.org.au/resources/states-renewable-energy/>; Australian Capital Territory, Climate Change Strategy 2019-2025 (Report, 2019) < https://www.environment.act.gov.au/__data/assets/pdf_file/0003/1414641/ACT-Climate-Change-Strategy-2019-2025.pdf>

‘Projects’, ARENA (Web Page) <https://arena.gov.au/projects/?project-value-start=0&project-value-end=200000000&keywords=battery&page=2>

‘Queensland renewable energy – a state of opportunity’, Queensland Government (Report, 2019) <https://www.tiq.qld.gov.au/download/business-interest/invest/19007-MRE-TIQ-Renewables-brochure_v5.pdf>

‘Renewable Energy Action Plan’, Victoria State Government (Report, 2017) <https://www.energy.vic.gov.au/__data/assets/pdf_file/0027/74088/REAP-FA5-web.pdf>

‘Renewable Portfolio Standards’, National Renewable Energy Laboratory (Web Page) <https://www.nrel.gov/state-local-tribal/basics-portfolio-standards.html>

‘Renewable Superpower Scorecard’, WWF Australia (Report, 22 March 2021), <https://www.wwf.org.au/what-we-do/climate/renewables/renewable-superpower-scorecard#gs.8g090a>; Guy Barnett, Minister for Energy, ‘Renewable Energy Target Passes Parliament’ (Media Release, 19 November 2020) <http://www.premier.tas.gov.au/site_resources_2015/additional_releases/improving_the_playing_field_across_tasmania/forging_a_manufacturing_future/renewable_energy_target_passes_parliament>

‘Renewable Technology Fund Opportunities’, Australaian Tenders (Web page, online at 28 September 2017)

‘Renewables Obligation (RO)’, OFGEM (Web Page) <https://www.ofgem.gov.uk/environmental-and-social-schemes/renewables-obligation-ro>

‘South Australian Government Climate Change Action Plan 2021-2025’, Government of South Australia (Report, 2020) < https://www.environment.sa.gov.au/files/sharedassets/public/climate-change/climate-change-action-plan-2021-2025.pdf>

‘State renewable energy targets powering a cleaner Australia, but some are falling short’, Green Energy Markets (Web Page, 3 July 2019) <https://www.energymatters.com.au/renewable-news/state-rets-renewable-energy-targets/>

‘Tasmanian Renewable Energy Plan’, Tasmanian Government (Report, December 2020) < https://renewablestasmania.tas.gov.au/__data/assets/pdf_file/0008/275876/Tasmanian_Renewable_Energy_Action_Plan_December_2020.pdf>

‘Territory Trailblazer: how the Act became the renewable capital of Australia’, Climate Council (Report, 2016) <https://www.climatecouncil.org.au/uploads/95fce776143c514aec9663427f7122ac.pdf>

‘The Australian Renewable Energy Race: Which States are Winning or Losing?’, Climate Council (Report, 2014) < https://www.climatecouncil.org.au/resources/states-renewable-energy/>

‘The case for deep storage: Why the NEM needs Battery of the Nation’, Hydro Tasmania (Report, April 2020) < https://arena.gov.au/assets/2020/04/the-case-for-deep-storage-why-the-nem-needs-battery-of-the-nation.pdf>; ‘Tasmanian Renewable Energy Plan’, Tasmanian Government (Report, December 2020) < https://renewablestasmania.tas.gov.au/__data/assets/pdf_file/0008/275876/Tasmanian_Renewable_Energy_Action_Plan_December_2020.pdf>

‘The renewable power percentage’, Australian Government Clean Energy Regulator (Web Page, 3 March 2021) <http://www.cleanenergyregulator.gov.au/RET/Scheme-participants-and-industry/the-renewable-power-percentage#Calculating-the-renewable-power-percentage>

‘U.S. Renewables Portfolio Standards 2021 Status Update: Early Release’, Berkeley Lab Electricity Markets and Policy (Web Page) <https://emp.lbl.gov/publications/us-renewables-portfolio-standards-3>

‘US Energy Storage Monitor: Q2 2021 Executive Summary’, Energy Storage Association: Wood Mackenzie Power & Renewables (Web Page) <https://www.woodmac.com/research/products/power-and-renewables/us-energy-storage-monitor/>

‘USAID Energy Storage Decision Guide for Policymakers’, NREL (Report, July 2021) <https://www.nrel.gov/docs/fy21osti/78815.pdf>

‘Victoria’s renewable energy targets’, Victorian Government (Web page, 12 January 2021) < https://www.energy.vic.gov.au/renewable-energy/victorias-renewable-energy-targets>

‘VRET 2017 Reverse Auction Outcomes Questions and Answers’, Victoria Government (Report, 2017) <https://www.energy.vic.gov.au/__data/assets/pdf_file/0023/391172/VRET_FAQ.pdf>

‘When does the Renewable Energy Target End?’, Australian Government Clean Energy Regulator (Web Page) <http://www.cleanenergyregulator.gov.au/RET/Pages/About%20the%20Renewable%20Energy%20Target/When-does-the-Renewable-Energy-Target-end.aspx>

‘World’s biggest battery to get bigger’, Government of South Australia Department for Energy and Mining (Web Page) <https://www.energymining.sa.gov.au/latest_updates/worlds_biggest_battery_to_get_bigger>

ACT Government, ‘BIG batteries part of Canberra’s next renewable energy plan’ (Media Release, 8 September 2020) <https://www.cmtedd.act.gov.au/open_government/inform/act_government_media_releases/barr/2020/big-batteries-part-of-canberras-next-renewable-energy-plan>

Australia, Parliamentary Debates, Senate, 22 June 2021, 88

Bird, Sharon, ‘The Renewable Energy (Electricity) Amendment Bill 2015’ (Media Release, 2 June 2015) <https://www.sharonbird.com.au/renewable_energy_electricity_amendment_bill_2015>

BloombergNEF, ‘Battery Pack Prices Cited Below $100/kWh for the first time in 2020, While Market Average Sits at $137/kWh’, Bloomberg NEM (online at 16 December 2020) < https://about.bnef.com/blog/battery-pack-prices-cited-below-100-kwh-for-the-first-time-in-2020-while-market-average-sits-at-137-kwh/>

Broadbent, Jillian, ‘Renewable Energy Financing Models’ (CEDA Energy Series, Perth Convention, 13 November 2012) <https://www.cefc.com.au/media/28885/jillian_broadbent_ao_speech_to_ceda_13_11_12.pdf>

Clean Energy Finance Corporation, ‘CEFC backs 300 MW Victorian Big Battery to strengthen grid and support more renewable energy’ (Media Release, 25 February 2021) <https://www.cefc.com.au/media/media-release/cefc-backs-300-mw-victorian-big-battery-to-strengthen-grid-and-support-more-renewable-energy/>

Clean Energy Finance Corporation, ‘CEFC backs Kennedy Energy Park hybrid solar, wind and battery project’ (Media Release, 19 October 2017) <https://www.cefc.com.au/media/media-release/cefc-backs-kennedy-energy-park-hybrid-solar-wind-and-battery-project/>

Colthorpe, Andy, ‘Energy storage project proposals sought for South Australia’s AUS$150m renewables fund’, Energy Storage Fund (online at 30 August 2017) <https://www.energy-storage.news/energy-storage-project-proposals-sought-for-south-australias-aus150m-renewables-fund/>

Colthorpe, Andy, ‘Solving California’s energy puzzle: Vanadium, artificial intelligence and everything in-between’, Energy Storage News (online at 13 October 2020) <https://www.energy-storage.news/solving-californias-energy-puzzle-vanadium-artificial-intelligence-and-everything-in-between/>

Dalzell, Stephanie, ‘Scott Morrison refuses to commit to net zero carbon emissions by 2050’, ABC News (online at 20 September 2020) < https://www.abc.net.au/news/2020-09-20/scott-morrison-refuses-to-commit-net-zero-carbon-emissions-2050/12682714>

de Atholia, Timoth, Gordon Flannigan and Sharon Lai, ‘Renewable Energy Investment in Australia’, Reserve Bank of Australia (Report, 2019) <https://www.rba.gov.au/publications/bulletin/2020/mar/pdf/renewable-energy-investment-in-australia.pdf>

Derek Parker, ‘Grid batteries can offer a smoother path’, The Australian Financial Review (online at 13 May 2017) <https://www.afr.com/companies/energy/grid-batteries-can-offer-a-smoother-path-20170510-gw1gmd>

Glenday, James, ‘Scott Morrison inches Australia towards 2050 net zero emissions, but distances himself from 'inner city' types’, ABC News (online at 20 April 2021) <https://www.abc.net.au/news/2021-04-20/scott-morrison-australia-inner-city-net-zero-emissions-biden/100080402>

Hall, Siobhan, James Leech, ‘Nodal power pricing complex way to manage EU congestion: Compass’, S&P Global (online at 23 July 2019) <https://www.spglobal.com/platts/en/market-insights/latest-news/electric-power/072319-nodal-power-pricing-complex-way-to-manage-eu-congestion-compass>

Han, Qiao Nan, ‘Why Australia’s long term energy policy rests on battery storage’, PV Magazine (online at 18 January 2020) <https://www.pv-magazine-australia.com/2020/01/18/why-australias-long-term-energy-policy-rests-on-battery-storage/>

Hannan, Peter, ‘Big $300m battery to be built without government aid in market first’, The Sydney Morning Herald (online at 5 July 2021) <https://www.smh.com.au/business/markets/big-300m-battery-to-be-built-without-government-aid-in-market-first-20210705-p586z6.html>

Harris, Rob, ‘Australia leading world with record renewable take-up, new data finds’, Sydney Morning Herald (online at 2 Feb 2021) <https://www.smh.com.au/politics/federal/australia-leading-world-with-record-renewable-take-up-new-data-finds-20210201-p56yfu.html>

Irwin, Oliver and Nicholas Neuberger, ‘Battery Storage Vision in the UK’, Lexology (online at 6 May 2021) <https://www.lexology.com/library/detail.aspx?g=8cbd205e-0e4c-4dc4-9162-1c31c6e5aa62>

Johan, Orrie, Tom Meares and Russell Pendlebury, ‘Grid access reform could create detailed wholesale price signals for battery investment and operation in the NEM’, AEMC (Web Page) <https://www.aemc.gov.au/grid-access-reform-could-create-detailed-wholesale-price-signals-battery-investment-and-operation>

Juli Tomaras, ‘Renewable energy policy: retreat, renewal and revitalisation?’, Australian Parliament (Web Page) < https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/BriefingBook45p/RenewableEnergy>

Karaduman, Ömer, ‘Economics of Grid-Scale Energy Storage’ (Conference Paper, Department of Economics MIT, 1 January 2020).

Kitchen, Carl, ‘Lessons from the NEM: Missing policies and random interventions’, Energy Council (Blog Post, 12 September 2020) <https://www.energycouncil.com.au/analysis/lessons-from-the-nem-missing-policies-and-random-interventions/>

McConnell, Dylan, ‘Australia’s states have been forced to go it alone on renewable energy, but it’s a risky strategy’, The Conversation (online at 1 December 2020) <https://theconversation.com/australias-states-have-been-forced-to-go-it-alone-on-renewable-energy-but-its-a-risky-strategy-151086>

Murphy, Darren, ‘Australia: Renewable Energy Laws and Regulations’, ICLG, (Web Page) <https://iclg.com/practice-areas/renewable-energy-laws-and-regulations/australia>

Parker, Derek, ‘Grid batteries can offer a smoother path’, The Australian Financial Review (online at 13 May 2017) <https://www.afr.com/companies/energy/grid-batteries-can-offer-a-smoother-path-20170510-gw1gmd>

Parkinson, Giles, ‘South Australia set sights on stunning new target of 500 pct renewables’, Renew Economy (online at 16 December 2020) <https://reneweconomy.com.au/south-australia-set-sights-on-stunning-new-target-of-500-pct-renewables-97917/>

Sioshansi, Ramteen, Paul Denholm and Thomas Jenkin, ‘Market and Policy Barriers to Deployment of Energy Storage’ (2012) Economics of Energy & Environmental Policy 1(2), 47

Speirs, David, ‘South Australia’s Climate Change Action Plan launced’ (Media Release, 16 December 2020) <https://www.premier.sa.gov.au/news/media-releases/news/south-australias-climate-change-action-plan-launched>

The Intergovernmental Panel on Climate Change, ‘Climate change widespread, rapid, and intensifying’ (Press Release 2021/17/PR, 9 August 2021) < https://www.ipcc.ch/2021/08/09/ar6-wg1-20210809-pr/>

Thornton, Kane, ‘Is the NEM Facing its Darkest Hour?’, Clean Energy Council (online at 12 April 2018) <https://www.cleanenergycouncil.org.au/news/is-the-nem-facing-its-darkest-hour>

Wood, Tony, David Blowers and Kate Griffiths, ‘Power struggle: short-term responses in a climate of uncertainty’, Grattan Institute (Report, 2017) <https://grattan.edu.au/wp-content/uploads/2017/10/grattan-institute-discussion-paper.pdf>

Yang, Gary ‘It’s Big and Long-Lived, and it Won’t Catch Fire: The Vanadium Redox-flow Battery’, IEEE Spectrum Magazine (online at 26 October 2017) <https://spectrum.ieee.org/its-big-and-longlived-and-it-wont-catch-fire-the-vanadium-redoxflow-battery>


[1] Bachelor of Commerce (Finance)/ LL.B. student at UNSW. Thanks due to Paul Curnow for his guidance on earlier drafts of this essay and to Andrew and Lilly and for proofing the final copy.

[2] The Intergovernmental Panel on Climate Change, ‘Climate change widespread, rapid, and intensifying’ (Press Release 2021/17/PR, 9 August 2021) < https://www.ipcc.ch/2021/08/09/ar6-wg1-20210809-pr/>.

[3] Paris Agreement to the United Nations Framework Convention on Climate Change, opened for signature 22 April 2016, C.N.63.2016 (entered into force on 21 April 2017).

[4] Jason Moore and Bahman Shabani, ‘A Critical Study of Stationary Energy Storage Policies in Australia in an International Context: The Role of Hydrogen and Battery Technologies’, (2016) Energies 9(9), 674.

[5] ‘Global Energy Review 2020: Renewables’ , IEA, (Report) <https://www.iea.org/reports/global-energy-review-2020/renewables>.

[6] Krishna Moorthy, Nitin Patwa and Yash Gupta, ‘Breaking barriers in deployment of renewable energy’ (2019) 5(1) Heliyon 66.

[7] Ibid.

[8] Moore (n 3).

[9] George Blomgren, ‘The Development and Future of Lithium Ion Batteries’ (2016) 164(1) Journal of the Electrochemcial Society 5019-5025; Jang Wook Choi and Doron Aurbach, ‘Promise and reality of post-lithium-ion batteries with high energy densities’ (2016) Nature Review Materials 1, 1-16.

[10] ‘Energy Storage’, Clean Energy Council (Web Page) <https://www.cleanenergycouncil.org.au/resources/technologies/energy-storage>.

[11] Moore (n 3).

[12] Derek Parker, ‘Grid batteries can offer a smoother path’, The Australian Financial Review (online at 13 May 2017) <https://www.afr.com/companies/energy/grid-batteries-can-offer-a-smoother-path-20170510-gw1gmd>; Ömer Karaduman, ‘Economics of Grid-Scale Energy Storage’ (Conference Paper, Department of Economics MIT, 1 January 2020); Grid vs Garage’, AECOM (Report, 13 December 2019) <https://arena.gov.au/assets/2020/04/arena-grid-vs-garage.pdf>.

[13] BloombergNEF ‘Battery Pack Prices Cited Below $100/kWh for the first time in 2020, While Market Average Sits at $137/kWh’, Bloomberg NEM (online at 16 December 2020) < https://about.bnef.com/blog/battery-pack-prices-cited-below-100-kwh-for-the-first-time-in-2020-while-market-average-sits-at-137-kwh/>.

[14] Qiao Nan Han, ‘Why Australia’s long term energy policy rests on battery storage’, PV Magazine (online at 18 January 2020) <https://www.pv-magazine-australia.com/2020/01/18/why-australias-long-term-energy-policy-rests-on-battery-storage/>.

[15] Steven Ferrey, ‘Efficiency in the regulatory crucible: Navigating 21st century smart technology and power’ (2012) 32(1) Journal of Energy & Environmental Law 1, 1-4.

[16] BloombergNEF (n 14).

[17] Derek Parker, ‘Grid batteries can offer a smoother path’, The Australian Financial Review (online at 13 May 2017) <https://www.afr.com/companies/energy/grid-batteries-can-offer-a-smoother-path-20170510-gw1gmd>.

[18] Ibid.

[19] Ibid.

[20] Ibid.

[21]Australian Government Department of Industry, Science, Energy and Resources, ‘National Electricity Market’, Australian Government (Web Page) <https://www.energy.gov.au/government-priorities/energy-markets/national-electricity-market-nem>.

[22] Renewable Energy Electricity Act 2000 (Cth) s 40.

[23] Renewable Energy Electricity Act 2000 (Cth).

[24] ‘When does the Renewable Energy Target End?’, Australian Government Clean Energy Regulator (Web Page) <http://www.cleanenergyregulator.gov.au/RET/Pages/About%20the%20Renewable%20Energy%20Target/When-does-the-Renewable-Energy-Target-end.aspx> .

[25] Darren Murphy et al, ‘Australia: Renewable Energy Laws and Regulations’, ICLG, (Web Page) <https://iclg.com/practice-areas/renewable-energy-laws-and-regulations/australia>.

[26] Stephanie Dalzell, ‘Scott Morrison refuses to commit to net zero carbon emissions by 2050’, ABC News (online at 20 September 2020) < https://www.abc.net.au/news/2020-09-20/scott-morrison-refuses-to-commit-net-zero-carbon-emissions-2050/12682714>; James Glenday, ‘Scott Morrison inches Australia towards 2050 net zero emissions, but distances himself from 'inner city' types’, ABC News (online at 20 April 2021) <https://www.abc.net.au/news/2021-04-20/scott-morrison-australia-inner-city-net-zero-emissions-biden/100080402>.

[27] ‘Powering Progress: States Renewable Energy Race’, Climate Council (Web Page) <https://www.climatecouncil.org.au/resources/states-renewable-energy/>; Australian Capital Territory, Climate Change Strategy 2019-2025 (Report, 2019) < https://www.environment.act.gov.au/__data/assets/pdf_file/0003/1414641/ACT-Climate-Change-Strategy-2019-2025.pdf>.

[28] ‘ Tasmanian Renewable Energy Plan’, Tasmanian Government (Report, December 2020) < https://renewablestasmania.tas.gov.au/data/assets/pdf_file/0008/275876/Tasmanian_Renewable_Energy_Action_Plan_December_2020>.

[29] Ibid.

[30] ‘Renewable Superpower Scorecard’, WWF Australia (Report, 22 March 2021), <https://www.wwf.org.au/what-we-do/climate/renewables/renewable-superpower-scorecard#gs.8g090a>.

[31] ‘ Tasmanian Renewable Energy Plan’, Tasmanian Government (Report, December 2020) < https://renewablestasmania.tas.gov.au/__data/assets/pdf_file/0008/275876/Tasmanian_Renewable_Energy_Action_Plan_December_2020.pdf>.

[32] Giles Parkinson, ‘South Australia set sights on stunning new target of 500 pct renewables’, Renew Economy (online at 16 December 2020) <https://reneweconomy.com.au/south-australia-set-sights-on-stunning-new-target-of-500-pct-renewables-97917/>.

David Speirs, ‘South Australia’s Climate Change Action Plan launched’ (Media Release, 16 December 2020) <https://www.premier.sa.gov.au/news/media-releases/news/south-australias-climate-change-action-plan-launched>.

[33] ‘South Australian Government Climate Change Action Plan 2021-2025’, Government of South Australia (Report, 2020) < https://www.environment.sa.gov.au/files/sharedassets/public/climate-change/climate-change-action-plan-2021-2025.pdf>.

[34] ‘Territory Trailblazer: how the Act became the renewable capital of Australia’, Climate Council (Report, 2016) <https://www.climatecouncil.org.au/uploads/95fce776143c514aec9663427f7122ac.pdf>.

[35] ‘Victoria’s renewable energy targets’, Victorian Government (Web page, 12 January 2021) < https://www.energy.vic.gov.au/renewable-energy/victorias-renewable-energy-targets>.

[36] ‘Queensland renewable energy – a state of opportunity’, Queensland Government (Report, 2019) <https://www.tiq.qld.gov.au/download/business-interest/invest/19007-MRE-TIQ-Renewables-brochure_v5.pdf>.

[37] ‘Energy superpower plan to turbocharge Renewable Energy Zones and pumped hydro’, Energy NSW (Report, 9 November 2020) <https://energy.nsw.gov.au/energy-superpower-plan-turbocharge-renewable-energy-zones-and-pumped-hydro>.

[38] Electricity Infrastructure Investment Act 2020 (NSW) s 43.

[39] Dylan McConnell, ‘Australia’s states have been forced to go it alone on renewable energy, but it’s a risky strategy’, The Conversation (online at 1 December 2020) <https://theconversation.com/australias-states-have-been-forced-to-go-it-alone-on-renewable-energy-but-its-a-risky-strategy-151086>.

[40] Australia, Parliamentary Debates, Senate, 22 June 2021, 88.

[41] Jillian Broadbent, ‘Renewable Energy Financing Models’ (CEDA Energy Series, Perth Convention, 13 November 2012) <https://www.cefc.com.au/media/28885/jillian_broadbent_ao_speech_to_ceda_13_11_12.pdf>.

[42] ARENA Act 2011 (Cth).

[43] Juli Tomaras, ‘Renewable energy policy: retreat, renewal and revitalisation?’, Australian Parliament (Web Page) < https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/BriefingBook45p/RenewableEnergy>.

[44] ‘Australian Renewable Energy Agency’, ARENA (Report, July 2021) <https://arena.gov.au/assets/2019/07/arena-at-a-glance.pdf>.

[45] Ibid.

[46] ‘Projects’, ARENA (Web Page) <https://arena.gov.au/projects/?project-value-start=0&project-value-end=200000000&keywords=battery&page=2>.

[47] Ibid.

[48] Jason Moore and Bahman Shabani, ‘A Critical Study of Stationary Energy Storage Policies in Australia in an International Context: The Role of Hydrogen and Battery Technologies’, (2016) Energies 9(9), 674.

[49] Clean Energy Finance Corporation, ‘CEFC backs 300 MW Victorian Big Battery to strengthen grid and support more renewable energy’ (Media Release, 25 February 2021) <https://www.cefc.com.au/media/media-release/cefc-backs-300-mw-victorian-big-battery-to-strengthen-grid-and-support-more-renewable-energy/>.

[50] Clean Energy Finance Corporation, ‘CEFC backs Kennedy Energy Park hybrid solar, wind and battery project’ (Media Release, 19 October 2017) <https://www.cefc.com.au/media/media-release/cefc-backs-kennedy-energy-park-hybrid-solar-wind-and-battery-project/>.

[51]Finance program aims to boost battery storage’, Clean Energy Financing Corporation (Web Page) <https://www.cefc.com.au/case-studies/finance-program-aims-to-boost-battery-storage/>.

[52] Ibid

[53] Ibid.

[54] Ibid.

[55] Ibid.

[56] Ibid.

[57] Ibid.

[58] Finance program aims to boost battery storage’, Clean Energy Financing Corporation (Web Page) <https://www.cefc.com.au/case-studies/finance-program-aims-to-boost-battery-storage/>.

[59] ‘Grid Scale Storage Fund’, Government of South Australia Department for Energy and Mining (Web Page) <https://www.energymining.sa.gov.au/growth_and_low_carbon/grid_scale_storage_fund>.

[60] ‘World’s biggest battery to get bigger’, Government of South Australia Department for Energy and Mining (Web Page) <https://www.energymining.sa.gov.au/latest_updates/worlds_biggest_battery_to_get_bigger>.

[61] ‘Renewable Technology Fund Opportunities’, Australian Tenders (Web page, online at 28 September 2017) <https://www.australiantenders.com.au/tenders/326568/renewable-technology-fund-opportunities>.

[62] Ibid.

[63] Andy Colthorpe, ‘Energy storage project proposals sought for South Australia’s AUS$150m renewables fund’, Energy Storage Fund (online at 30 August 2017) <https://www.energy-storage.news/energy-storage-project-proposals-sought-for-south-australias-aus150m-renewables-fund/>.

[64] ‘Renewable Energy Action Plan’, Victoria State Government (Report, 2017) <https://www.energy.vic.gov.au/__data/assets/pdf_file/0027/74088/REAP-FA5-web.pdf>.

[65] Ibid.

[66] Ibid.

[67] Renewable Energy (Jobs and Investment) Act 2017 (Vic).

[68] ‘VRET 2017 Reverse Auction Outcomes Questions and Answers’, Victoria Government (Report, 2017) <https://www.energy.vic.gov.au/__data/assets/pdf_file/0023/391172/VRET_FAQ.pdf>.

[69] ACT Government, ‘BIG batteries part of Canberra’s next renewable energy plan’ (Media Release, 8 September 2020) <https://www.cmtedd.act.gov.au/open_government/inform/act_government_media_releases/barr/2020/big-batteries-part-of-canberras-next-renewable-energy-plan>.

[70] ‘Energy Storage: Financing Speed Bumps and Opportunities’, PWC (Report) < https://www.pwc.com.au/infrastructure/pwc-energy-storage-financing-speed-humps.pdf>.

[71] Ibid.

[72] ‘Post 2025 Market Design for the National Electricity Market (NEM)’, Energy Security Board (Report, 22 March 2019) <https://energyministers.gov.au/publications/post-2025-market-design-national-electricity-market-nem>.

[73] Rob Harris, ‘Australia leading world with record renewable take-up, new data finds’, Sydney Morning Herald (online at 2 Feb 2021) <https://www.smh.com.au/politics/federal/australia-leading-world-with-record-renewable-take-up-new-data-finds-20210201-p56yfu.html>.

[74] ‘As cost declines and regulatory support boost demand for battery storage, project finance emerges as a viable financing option’, Moody’s (Web Page, online at 20 March 2018) <https://www.moodys.com/research/Moodys-As-cost-declines-and-regulatory-support-boost-demand-for--PR_381076>.

[75] ‘Australian Renewable Energy Agency Annual Report 2018-19’, Australian Government (Report, 2019) <https://www.transparency.gov.au/annual-reports/australian-renewable-energy-agency/reporting-year/2018-2019-68>.

[76] Peter Hannan, ‘Big $300m battery to be built without government aid in market first’, The Sydney Morning Herald (online at 5 July 2021) <https://www.smh.com.au/business/markets/big-300m-battery-to-be-built-without-government-aid-in-market-first-20210705-p586z6.html>.

[77] Moodys (n 70).

[78] Ibid.

[79] AEMC (2016d, p. 10).

[80] Carl Kitchen, ‘Lessons from the NEM: Missing policies and random interventions’, Energy Council (Blog Post, 12 September 2020) <https://www.energycouncil.com.au/analysis/lessons-from-the-nem-missing-policies-and-random-interventions/>.

[81] Kane Thornton, ‘Is the NEM Facing its Darkest Hour?’, Clean Energy Council (online at 12 April 2018) <https://www.cleanenergycouncil.org.au/news/is-the-nem-facing-its-darkest-hour>.

[82] Sharon Bird, ‘The Renewable Energy (Electricity) Amendment Bill 2015’ (Media Release, 2 June 2015) <https://www.sharonbird.com.au/renewable_energy_electricity_amendment_bill_2015>.

[83] Timoth de Atholia, Gordon Flannigan and Sharon Lai, ‘Renewable Energy Investment in Australia’, Reserve Bank of Australia (Report, 2019) <https://www.rba.gov.au/publications/bulletin/2020/mar/pdf/renewable-energy-investment-in-australia.pdf>.

[84] ‘PWC (n 67).

[85] Tony Wood, David Blowers and Kate Griffiths, ‘Power struggle: short-term responses in a climate of uncertainty’, Grattan Institute (Report, 2017) <https://grattan.edu.au/wp-content/uploads/2017/10/grattan-institute-discussion-paper.pdf>.

[86] PWC (n 67).

[87] ‘Five Minute Settlement’, AEMC (Web Page) <https://www.aemc.gov.au/rule-changes/five-minute-settlement>.

[88] PWC (n 67).

[89] Ibid.

[90] AEMO, ‘National Electricity Amendment (Integrating Energy Storage Systems Into the NEM), Australian Energy Market Commission (Draft Rule Determination, 2021) <https://www.aemc.gov.au/sites/default/files/2021-07/integrating_energy_storage_systems_into_the_nem_-_erc0280_-_draft_determination.pdf>.

[91] Ibid.

[92] PwC (n 67)

[93] Ibid.

[94] ‘Guide to Ancillary Services in the National Electricity Market’, AEMO (Report, April 2015) <https://www.aemo.com.au/-/media/Files/PDF/Guideto-Ancillary-Services-in-the-National-Electricity-Market.ashx>.

[95] Ibid.

[96] PWC (n 67).

[97] Ibid.

[98] Infigen Energy, ‘National Electricity Amendment (Fast Frequency Response Market Ancillary Service) Rule 2021 (Final Report, 2021) <https://www.aemc.gov.au/sites/default/files/2021-07/Fast%20frequency%20response%20market%20ancillary%20service%20-%20Final%20Determination.pdf>.

[99] Ibid.

[100] Ramteen Sioshansi, Paul Denholm and Thomas Jenkin, ‘Market and Policy Barriers to Deployment of Energy Storage’ (2012) Economics of Energy & Environmental Policy 1(2), 47-64.

[101] ‘Integrating Energy Storage Systems into the National Electricity Market’, Office of Best Practice Regulation (Web Page, 19 July 2021) <https://obpr.pmc.gov.au/published-impact-analyses-and-reports/integrating-energy-storage-systems-national-electricity>.

[102] Moodys (n 71).

[103] Thomas Faunce, James Prest and Dawei Su, ‘On-grid batteries for large-scale energy storage: Challenges and opportunities for policy and technology’ (2018) 5(11) MRS Energy & Sustainability 1, 7.

[104] Ibid.

[105] Energy Storage Tax Incentive and Deployment Act of 2021 (S. 627) ss 25D, 48.

[106] Accelerated Cost Recovery System 26 U.S. Code § 168(g)(5).

[107] ‘Battery Storage Systems Federal Tax Incentives’, Native Solar (Web Page) <https://nativesolar.com/battery-storage-systems-federal-tax-incentives/>.

[108] ‘Depreciation of Solar Energy Property in MACRS’, Solar Energy Industries Association (Web Page) <https://www.seia.org/initiatives/depreciation-solar-energy-property-macrs>.

[109] ‘US Energy Storage Monitor: Q2 2021 Executive Summary’, Energy Storage Association: Wood Mackenzie Power & Renewables (Web Page) <https://www.woodmac.com/research/products/power-and-renewables/us-energy-storage-monitor/>.

[110] ‘U.S. Renewables Portfolio Standards 2021 Status Update: Early Release’, Berkeley Lab Electricity Markets and Policy (Web Page) <https://emp.lbl.gov/publications/us-renewables-portfolio-standards-3>.

[111] Ibid.

[112] ‘Renewables Obligation (RO)’, OFGEM (Web Page) <https://www.ofgem.gov.uk/environmental-and-social-schemes/renewables-obligation-ro>.

[113] Blaid Raybould, Wai Cheung and Chris Connor, ‘An investigation into UK government policy and legislation to renewable energy and greenhouse gas reduction commitments’ (2020) Clean Technologies and Environmental Policy 22, 3710387.

[114] Warren Leon, ‘Becoming more aggressive: States implement ambitious goals and standards’ Renewable Energy World, (Blog Post, 18 August 2020) < https://www.renewableenergyworld.com/blog/becoming-more-aggressive-states-implement-ambitious-goals-and-standards/#gref>.

[115] Massachusetts Department of Energy Resources, ‘Clean Peak Energy Standard’, Massachusetts Government (Webpage) <https://www.mass.gov/clean-peak-energy-standard>.

[116] Leon (n 114).

[117] DSIRE, ‘Energy Storage Procurement Target’, NC Clean Energy Technology Centre, (Webpage, 26 February 2020) <https://programs.dsireusa.org/system/program/detail/22112>; The Climate Group, ‘How California is Driving the Energy Storage Market through State Legislation’, The Climate Group (Report, 2017), <https://www.theclimategroup.org/sites/default/files/2020-11/under2_coalition_case_study_etp_california.pdf>.

[118] Ibid.

[119] Ibid.

[120] Public Utility Commission of Texas Substantive Rules ch 25(o).

[121] ‘Renewable Portfolio Standards’, National Renewable Energy Laboratory (Web Page) <https://www.nrel.gov/state-local-tribal/basics-portfolio-standards.html>.

[122] Ibid.

[123] ‘Innovative Ancillary Services Innovation Landscape Brief’, International Renewable Energy Agency (Report, 2019) <https://www.irena.org/-/media/Files/IRENA/Agency/Publication/2019/Feb/IRENA_Innovative_ancillary_services_2019.pdf>.

[124] Ibid.

[125] Ibid.

[126] Federal Electricity Commission, order 755.

[127] ‘PJM Manual 28: Operating Agreement Accounting’, Market Settlement Development Department (Report, 2020) <www.pjm.com/-/media/documents/manuals/m28-redline.ashx>.

[128] ‘Distributed Energy Resources Market Design Concept Proposal’, New York Independent System Operator (Report, December 2017) <www.nyiso.com/documents/20142/1391862/Distributed-Energy-Resources-2017-MarketDesign-Concept-Proposal.pdf/122a815f-b767-e67f-0a8f-323e5489c2b1>.

[129] Ibid.

[130] Energy Security Board, ‘Delivering Adequate Power Supplied Right now and into the Future’, Energy Security Board post-2025 (Report, 2021) < https://esb-post2025-market-design.aemc.gov.au/32572/1629954628-esb-final-report-explainer-adequate-power-supplies-rams-pathway.pdf>.

[131] Ibid.

[132] Piotr Brorwski, ‘Zonal and Nodal Models of Energy Market in European Union’ (2020) 13(16) Energies 4182.

[133] ‘PacifiCorp’s Nodal Pricing Model in the CAISO Day-Ahead Market’, California ISO (Report, 14 January 2021) <http://www.caiso.com/Documents/NodalPricingModelReport.pdf> .

[134] Siobhan Hall and James Leech, ‘Nodal power pricing complex way to manage EU congestion: Compass’, S&P Global (online at 23 July 2019) <https://www.spglobal.com/platts/en/market-insights/latest-news/electric-power/072319-nodal-power-pricing-complex-way-to-manage-eu-congestion-compass>.

[135] Orrie Johan, Tom Meares and Russell Pendlebury, ‘Grid access reform could create detailed wholesale price signals for battery investment and operation in the NEM’, AEMC (Web Page) <https://www.aemc.gov.au/grid-access-reform-could-create-detailed-wholesale-price-signals-battery-investment-and-operation>.

[136] Ibid.

[137] Ibid.

[138] ‘USAID Energy Storage Decision Guide for Policymakers’, NREL (Report, July 2021) <https://www.nrel.gov/docs/fy21osti/78815.pdf>

[139] Oliver Irwin and Nicholas Neuberger, ‘Battery Storage Vision in the UK’, Lexology (online at 6 May 2021) <https://www.lexology.com/library/detail.aspx?g=8cbd205e-0e4c-4dc4-9162-1c31c6e5aa62>.

[140] Ibid.

[141] ‘Integrating energy storage systems into the NEM’, AEMC (Media Release, 15 July 2021) <https://www.aemc.gov.au/sites/default/files/documents/integrating_energy_storage_systems_into_the_nem_-_erc0280_-_information_sheet_-_draft_determination.pdf>.

[142] ‘Integrating energy storage systems into the NEM’, AEMC (Web Page) <https://www.aemc.gov.au/rule-changes/integrating-energy-storage-systems-nem>.

[143] Gary Yang, ‘It’s Big and Long-Lived, and it Won’t Catch Fire: The Vanadium Redox-flow Battery’, IEEE Spectrum Magazine (online at 26 October 2017) <https://spectrum.ieee.org/its-big-and-longlived-and-it-wont-catch-fire-the-vanadium-redoxflow-battery>.

[144] Ibid.

[145] ‘Energy Storage: Opportunities and Challenges of Deployment in Australia’, Australian Academy of Technology and Engineering (Report) <https://www.atse.org.au/wp-content/uploads/2019/01/energy-storage-opportunities-challenges.pdf>.

[146] Colthorpe (n 60).

[147] Ibid.

[148] Andy Colthorpe, ‘Solving California’s energy puzzle: Vanadium, artificial intelligence and everything in-between’, Energy Storage News (online at 13 October 2020) <https://www.energy-storage.news/solving-californias-energy-puzzle-vanadium-artificial-intelligence-and-everything-in-between/>.

[149] Ibid.

[150] Faunce (n 96).

[151] ‘Hydropower / Pumped Hydro Energy Storage’, ARENA (Web Page) <https://arena.gov.au/renewable-energy/pumped-hydro-energy-storage>.

[152] Matthew Pellow, Hanjiro Ambrose and Dustin Mulvaney, ‘Research Gaps in Environmental Life Cycle Assessments of Lithium Ion Bbatteries for Grid-Scale Stationary Energy Storage Systems: End-of-Life Options and Other Issues’ (2020) 23 Sustainable Materials and Technologies 120.

[153] Ibid.


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