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Level 4
54 Wellington Street
Collingwood
VIC 3066
30 August 2023
Dear Capacity Investment Scheme Team
RE: CIS Consultation Paper Feedback
BNRG Leeson Pty Ltd (BNRG Leeson) is a joint venture between BNRG, a multi-national developer and operator of
renewable energy projects, based in Dublin, Ireland, and the Leeson Group, an Australian owned, Melbourne based
renewable energy company that has developed several large-scale solar farms in Victoria. BNRG Leeson is
committed to developing 300MW of co-located solar and battery storage assets in Australia over the next 3 years,
split between utility projects and sub 5MW sites.
BNRG Leeson strongly supports the Capacity Investment Scheme (CIS), and the proposed tender arrangements, as
an effective method of supporting much-needed investment in new firming capacity.
Specifically, BNRG Leeson views the CIS as an effective and efficient means to plug the revenue gap that currently
exists for smaller grid-scale distribution-connected storage systems, which bring grid stability benefits over a wider
geographical spread and where most needed at the distribution level. In addition, these projects can deliver these
benefits much sooner and with less disruption to rural communities than their larger transmission -connected
counterparts.
To ensure that these types of projects qualify for the CIS and that the benefits they deliver are appropriately
recognised and valued in the CIS tender process, we provide the following feedback and suggestions:
1. Minimum duration should be no greater than 2-hours. In our view 2-hour batteries are by far the most
cost-effective method of delivering the short-medium term objectives of the CIS. The CIS may consider
increasing duration requirements if and when requirements are necessary (to achieve longer term
goals) and by which stage those technologies will have matured and costs declined (as expected).
2. DC and AC-coupled renewable generation and storage projects qualify for the CIS.
3. Distribution-connected assets should be prioritised, potentially through adopting a selection
methodology that attributes both quantitative and the qualitative benefits of distribution-connected
storage projects.
4. Projects that are exempt from the requirement to register with AEMO as a Generator under section
11(1) of the National Electricity Law and clause 2.2.1 of the National Electricity Rules, on the basis of
the standing exemption in favour of generating systems with a nameplate rating of less than 5MW,
qualify for the CIS, on condition the project will register as an ancillary service unit with AEMO,
enabling them to participate in FCAS contingency markets pursuant the Integrating Energy Storage
Systems (IESS) Rule change that will come into effect from 3 June 2024.
5. Projects that secure connection to the grid under 5.3.4A of the National Electricity Rules qualify for the
CIS.
BNRG Leeson Pty Ltd ABN: 15 630 599 003
6. To encourage developers of smaller systems to aggregate their projects, and to assist
in managing the workload of your assessment team, we suggest you consider adding a
minimum of 9MWh of storage capacity per project and 36MWh of storage capacity
per submission/proposal.
7. To ensure the principle of additionality is achieved, projects that achieved financial
close prior to 4 August 2023, should not be eligible to participate in the forthcoming
Vic/SA tender process.
If you have any questions or would like to discuss any of the matters raised in this submission,
please do not hesitate to contact me.
Kind Regards,
Mike Wilson
Head of Energy Markets
T + 61 400 123 320
www.bnrg.ie
mwilson@bnrg.ie
BNRG Leeson Pty Ltd ABN: 15 630 599 003
