Since 13 June of this year, a draft Australian/New Zealand Standard for battery storage systems has been open for public comment. After reading the draft standard Kingfisher Law was sufficiently concerned to make our own submission to Standards Australia. Below is what we wrote.
Over the last decade, the industry of grid-connected battery systems has been increasingly validated by the uptake in small-scale energy production. The draft standards suggest that there is an absence of suitable regulation for newer battery technologies. The draft standards explicitly recognise that they are not intended to discourage innovation. However, Kingfisher Law is concerned with the self-defeating nature of these draft standards because they increase the cost and administrative burden of uptake of new home-battery systems. Moreover, imposition of measures required by the draft standards would effectively ban this valuable technology from many urban areas of high-population Australian cities and will certainly deny access to this essential technology by residents in smaller homes and on smaller urban blocks. Only relatively wealthy households and businesses would have the resources to fund the additional installation cost imposed by the draft standards.
The technical standards take no account of the needs and aspirations of a large proportion of urban dwellers to gain choice, autonomy and control over their use of electricity. Furthermore, battery storage is a key element in households’ contribution to reduction of their greenhouse gas emissions and management of their energy costs.
If implemented, the draft standards will have the perverse outcome of disincentivising investment and the growth of the battery industry, because many potential consumers of battery goods and services will be locked out of the market. Examples of such standards include installation at least one metre from a neighbouring dwelling that includes a dividing fence (4.5.3(h)) and inside a purpose built room (4.5.3(e)).
At the core of the standards is the requirement that home-battery systems would be required to be housed in stand-alone kiosks to avoid the risk of combustion impacting homes unless significant expense was spent retrofitting homes to meet the fire safety standards for fire hazard level 2 batteries (lead acid and nickel alkaline). Fire hazard level 1 (lithium) batteries are not allowed in domestic dwellings and would always require stand-alone kiosks. Particularly, clause 4.5.3 of the draft standards suggests extremely stringent guidelines for fire hazard level 1 batteries that are difficult to comply with and would likely act as a disincentive to installation altogether.
Requiring kiosks would reduce the accessibility for properties by increasing the cost, space and time required to be invested in the purchase of a home-battery system. Ultimately, this would only go to slow the development of the battery storage industry, one that is already competing in a market skewed towards established fossil-fuel industry. There is no doubt that regulation surrounding home-battery systems is a necessary step to ensure the longevity of the industry, however what is also required is the creation of regulations that do not stifle the much-needed industry as it climbs a trajectory of growth.
We recommend that:
(a) The draft standards not be implemented in their current form.
(b) Standards for battery storage in residential premises be redrafted to take into account the rights of Australian individuals, families and households to generate, store and manage their own electrical power in the interests of reducing greenhouse gas emissions and managing their energy costs.
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