21 Wolseley Parade
Kensington, Vic  3031
(03)93767515
1 February 1996

Sustainable Energy Development Authority
c/- Mr Paul Dirago
Dept of Energy NSW
fax(02)9901 8400

Dear Sir/Madam,
			The SDF Working Group's report has come to my attention recently. Some in the Victorian  electricity distribution industry are of the view that your Working Group is laying the foundations we should have had in Victoria for a couple of years now.

I am an active member of the Alternative Technology Association which is currently operating the 60kW Breamlea wind generator. (I actually own it at the moment, but the ATA's volunteer group still officially runs open days and performs routine maintenance).

I write to draw your attention to certain problems and shortcomings to do with the trading of energy through an allegedly "transparent" transmission/distribution system. Perhaps you can avoid some of the mistakes and anomalies that seem to beset us at the moment.

Main points:

*Legislation, regulation and licencing in Victoria seem to have completely ignored environmental issues such as the greenhouse effect.

*Wind energy from Breamlea is sold to a remote distribution business (CitiPOWER Ltd) in Melbourne, against the net energy flow from the Latrobe Valley. The wind turbine's local DB is Powercor, which is benefitting to the tune of about 9 MWh per calendar month. This is obviously peanuts to them, (About $400/month at current levels of the System Marginal Price) but the vexed question of who should pay for embedded generation is really holding up the development of windpower in Victoria.

*Any trading rules which do not take the direction of net energy flows into account will not be equitable to all the parties involved and will not send the right signals to the market. 

*I have been trying to persuade the policy makers in the Vic Dept of Agriculture, Minerals & Energy, that the transparent grid is illusory, and that local DBs with embedded generation should have an enforceable obligation to pay for non-schedulable embedded generation at the prevailing pool price (ie every half hour!). We have a data logger at Breamlea which records energy export on a half-hourly basis, and I have written some simple software which allows correlation of this data with SMP.  I can thus calculate each month the exact savings to Powercor in not having to purchase that energy from the wholesale market. The amounts are trifling in our case, but for a 5MW wind farm on the same site, it would represent an enormous "free lunch".

*Much of the results of my data analysis has been placed on the internet  (accessible with Netscape, and probably other browsers) at 
      ftp://suburbia.net/pub/users/alternative-technology/wind  
General info can be found on the ATA's Web page at http://suburbia.net/~ata/breamlea.htm  

*The Alternative Technology Association has demonstrated in only one year that a community group can successfully manage and operate a wind turbine (see table and chart attached). Our group is aware of a 30 kW Westwind machine being available in Perth. If there is sufficient interest from a committed group of the ATA's current NSW-based membership, we may well be able to quickly initiate a proposal for SEDA to fund the installation of that machine on a suitable site on the NSW coast. However, income from the sale of energy would be unlikely to return a profit on such an investment, even with volunteer (ATA member) labour doing all the maintenance. Sites with 3 phase 415 volt power available would reduce installation costs considerably.

*Energy export from Breamlea can occur without a generating licence currently, owing to a general exemption in force until 30 June 1996. The Office of the Regulator-General has indicated that a class licence will probably be arranged to formalise the legal framework without (hopefully) the introduction of hefty licence fees.

*Distribution businesses in Victoria each have two arms: "poles & wires"  and "retailing". Since embedded generation has benefits for the poles & wires division, but may cost more than wholesale electricity from the traditional sources, there is the potential for disputes to arise between the two divisions. DBs should not allow such problems to delay or hinder the development of renewables, which have enormous secondary value in terms of corporate image.

*Attachments:
* paper submitted to the 1995 Wind Energy Workshop (Monash Uni)
* Breamlea energy export since 1987 (bar graph) plus summary table
* Table "proving" the value of windpower Jul-Nov 1995
* Recent correspondence to "The Age" highlighting the uncertainty
   surrounding the attitude of the new owners of DB's to renewables.
* Issue paper from Nick Wyatt of Dept of Agric,Minerals& Energy, Vic

Yours faithfully,
                     Michael Gunter                                                   
