




13 June 1995

Mr Ross Cartey
Office of the Regulator-General
1st Floor, 35 Spring Street
MELBOURNE    VIC     3000


Dear Mr Cartey,

re: Breamlea 60 kW Windgenerator

Further to our previous letter and in response to your letter of 23 May, 
the Alternative Technology Association (ATA) submits the following:

       The windgenerator was purchased from Generation Victoria on 29 
       September 1994. It was grid-connected when bought, and the ATA assumes 
       that Generation Victoria was operating it and its grid-interconnection 
       legally up to and including that date. Whether Generation Victoria or 
       its predecessor(s) had a licence or an exemption for a licence at any 
       stage prior to 29th September 1994 is not known.

       The ATA purchased the windgenerator with firm plans to leave it at its 
       present site and for it to remain grid-connected. Indeed it cannot 
       function in any way (in any location) without grid connection.

       Windpower for electricity production has a promising potential along 
       extensive areas of the Victorian coastline. Considering that present 
       Victorian electricity production utilising mostly brown coal is the 
       most polluting electric power in Australia, especially in terms of 
       greenhouse gas emissions, the ATA takes the view that the Office of 
       the Regulator-General should do nothing that discourages windpower 
       production, even on a scale as small as ours, despite the apparent 
       excess capacity of conventional plant at present.

       Market forces should ultimately determine whether a significant 
       proportion of Victoria's power can be meaningfully sourced from wind 
       turbines. There is certainly a huge potential, especially in Western 
       Victoria, where our preliminary studies indicate that up to 250-500 MW 
       capacity could potentially be installed. This would go a very 
       considerable way towards fulfilling Victoria's share of Australia's 
       commitment to greenhouse gas reduction. It should also be welcomed by 
       the local electricity distribution utility as a highly marketable 
       "green" technology, with significant commercial benefits in terms of 
       supplying peak summer loads, embedded close to end-users, and without 
       the costs of transmission losses from the Latrobe Valley 300 km distant. 
       Indeed our research to date shows a significant positive correlation of 
       availability of windpower with peak system demand. This has profound 
       implications for the immediate deployment and economic operation of
       strategically situated wind turbines. Sensitive placement and 
       aesthetic considerations should reassure local communities that there 
       is a place for windpower "in their backyard", and indeed may provide a 
       focus for eco-tourism to their region.

       VPX (Pool) Implications: Under present pool rules it is difficult to 
       imagine that even a large wind farm of say 50 MW could be a pool 
       participant. This is a consequence of the embedded, intermittent 
       nature of windpower precluding guarantee of supply at any particular 
       time. This however does not exclude windpower from making a significant 
       contribution to overall electricity production, as windpower entities 
       are free to negotiate with distribution companies, and ultimately 
       (possibly) end-users for the sale of their product. Windpower producers 
       should be free to negotiate contracts which track half-hourly SMP 
       variations over certain specified price ranges, and this would seem to 
       us not to distort the market in any way, even if windpower was 
       supplying say 10% of total system demand.

       Electrical installation/ Safety Considerations: It is the understanding 
       of the ATA that all large-scale electricity generation in the state 
       has been essentially self-regulating for decades in terms of electrical 
       design, construction and operation. Obviously in the hands of experts 
       in the field, this has worked well. Similarly, we envisage that any 
       entity embarking on a significant capital venture such as a wind 
       generator would  employ competent qualified electrical engineers and 
       electricians to design and install such capital equipment. Regarding 
       the operation of windgenerators, this is largely an automated pro-
       cedure governed by prevailing winds and a microprocessor program. 
       It would seem reasonable that the microprocessor algorithm should be 
       submitted to the local distribution company for approval by their 
       technical staff prior to commissioning of the machine. The ORG could 
       if necessary, be notified that grid interconnection criteria for a 
       particular windgenerator had been so approved. Maintenance staff 
       would also require adequate training appropriate to their duties, 
       and have clear safety guidelines encompassing all safety recommend-
       ations of the windgenerator manufacturer, Victorian workplace 
       legislation, and commonsense rules concerning appropriate responses 
       to gales, thunderstorms or major mechanical failure of the wind
       generator.

       Licencing: The ATA is keen to foster the emergence of a windpower 
       industry for this state. Market forces and self-regulation, along 
       the sort of lines set out above would seem to provide adequate 
       minimal framework to allow this, without an expensive and detailed 
       regulatory framework to hinder the process. Utilities in two other 
       states are already encouraging and promoting the use of grid-inter-
       active photovoltaic arrays on domestic rooftops. CitiPower in 
       Brunswick is currently feeding a combination of wind and photo-
       voltaic power into the local grid of suburban Melbourne. Thus it 
       seems that in the stimulating environment created by present rapid 
       change in the industry, pioneers and forward thinkers are already 
       exploring options appropriate to the development of sustainable and 
       renewable  technologies for electricity production. This has to be a 
       healthy phenomenon, entirely consistent with the Government's position 
       of allowing the free play of market forces,and should be allowed to 
       proceed with the minimum of restraint from any quarter. Whether 
       integration of renewables is best achieved by licencing individual 
       operations, class licences or exemption from licence requirements is 
       not presently clear:
	 If licencing is thought to be appropriate, we would strongly argue 
	 that any licence fee should be in direct proportion to annual energy 
	 output. Thus if Hazlewood fed 9 million MWh each year into the grid, 
	 it could pay say 2 cents/MWh or $180,000 annually for a licence. 
	 Similarly the Breamlea windgenerator with an expected annual pro-
	 duction of  100 MWh would pay a nominal $2.00 . Basing fees on 
	 installed capacity would disadvantage windpower, which is lucky if 
	 it can achieve a capacity factor of 35-40% (Breamlea achieves only 
	 20%).
	If exemption is the preferred option, regulation can be largely 
	 devolved to the distribution companies, who would negotiate 
	 reasonable conditions which fulfil their technical requirements 
	 for grid connection , as part of the normal negotiation process of 
	 a commercial contract. This  would seem to fit best with the 
	 scenario of  photovoltaic arrays sprouting from rooftops throughout 
	 the suburbs, or at least perhaps north of the Great Dividing Range. 
	 Refusal of a distribution company to allow grid connection of 
	 renewables of over 10 kW should be subject to arbitration by the 
	 ORG, preferably with the involvement of an independent consulting 
	 electrical engineer, prior to recourse through the civil courts.

       Rapid change in the industry, and the uncertain status of some 
       generating entities is causing difficulties for some e.g. the ATA is 
       experiencing some delay in putting on paper a verbal agreement with 
       PowerCor to remain connected to their 22 kV feeder. Similarly, 
       negotiations with our proposed customer (CitiPower) for a contract 
       for the supply of power are yet to be finalised due to uncertainty 
       about licence requirements, etc. The present efforts of the Office of 
       the Regulator-General to clarify the regulatory framework are 
       therefore welcomed. 

      It would be appreciated if your office could confirm at your earliest 
      convenience that our present operation of the Breamlea windgenerator 
      falls within the "protection" of the general exemption currently in force.

      We hope the above notes help the Office of the Regulator-General in its 
      deliberations. I have taken the liberty of sending copies of this letter 
      to other parties to whom it may be relevant, in case they wish to put 
      submissions to your Office before the end of this month.

			Yours sincerely,

				
			  Michael Gunter, Breamlea Ops. Group, ATA
		
Copies to:

	CitiPower, Brunswick Office
	PowerCor
	Karl Mallon, Mechanical Engineering Faculty, Melbourne University
	Dr Peter Freere,  Asia-Pacific Wind Energy Centre, Centre for Electrical
		Power Engineering, Monash University
