Renewable energy projects in Australia range from solar, wind and hydro to tidal and geothermal. There has been an increasing uptake of hybrid projects, such as solar battery, solar diesel and solar wind projects, to mitigate intermittent renewable generation issues.

Significant renewable projects in Australia are usually developed under an engineering, procurement, and construction (EPC) model. An EPC model involves a principal engaging a contractor to design, build and deliver the asset in an operational state. Once commissioning is complete, the project is transferred to either debt or equity investors or the entity taking the electricity generated by the project.

Factors affecting the bankability of a renewable energy project generally include securing an offtaker (i.e., a purchaser of the electricity) or access to the electricity market to sell electricity; procuring access to the electricity network if the project is grid-connected; whether the project involves proven or new technology; the experience and creditworthiness of the parties involved, including the EPC contractor; whether government grants or funding is available; the availability of renewable incentives such as renewable energy certificates; and a stable long-term energy policy.


The past year has seen extraordinary growth in the renewable energy industry in Australia. The Clean Energy Council has reported that 50 large-scale energy projects have either been actively under construction or had secured financial commitment by the end 2017.2 In May 2017, total new clean energy investment was estimated at A$10.3 billion.3 It appears that this growth pattern is set to continue, with Green Energy Markets indicating that more than 100MW of rooftop solar PV installations have been installed each month of 2018, which is already 56 per cent above last year's record-breaking rate.4

The increase in solar penetration and intermittent renewable technologies has heightened concerns about energy security and reliability. This is particularly as a result of the widespread blackouts in South Australia during 2017. Renewable technologies in the form of battery storage have been used as a mechanism to combat reliability issues.5 The landmark Tesla lithium battery installed in South Australia has already been used successfully to respond to power failures. It was reported that the battery delivered 100MW into the national energy grid in 140 milliseconds following a power plant trip in Victoria.6

Another major renewable energy initiative that has been developed over the past year is the Western Australian Synergy Renewable Vehicle (SRV) (financed by Cbus Super and the Dutch Infrastructure Fund).7 The SRV will finance the A$500 million Warradarge Wind Farm along with the expansion of Greenough River Solar Farm (which was Australia's first large solar project when built) and the refurbishment of the Albany Grasmere Wind Farm.

The solar financing by Wirsol Energy and Edify Energy of A$380 million across three projects in Queensland and Victoria is another example of landmark renewable energy projects in Australia that are to be completed this year.8

Pumped hydro is also becoming part of the energy mix, including the proposed expansion of the Snowy Mountains hydro scheme. The proposed expansion would result in the biggest 'battery' in the southern hemisphere and is another good example of the measures being taken to combat the intermittency of renewable energy sources.9

The rapid growth in renewable energy projects in Australia has been attributed to the Renewable Energy Target (RET), which is expected to be met before it expires in 2020.10 The RET will be replaced by the National Energy Guarantee (NEG). The NEG aims to trigger investment in 'dispatchable' supply capacity (coal, gas, hydro, battery storage) and requires retailers and large energy users to make reductions in emissions levels and comply with reliability obligations.11 According to the Electricity Security Board, renewable energy will account for 28 to 36 per cent of total energy generation in 2030 under the NEG.

The NEG is also a departure from the Clean Energy Target recommended in the Independent Review of the Future Security of the National Electricity Market by Dr Alan Finkel AO.12 The Clean Energy Target proposed sets a target of new 'clean' electricity based on the required emissions reductions for the electricity sector by 2030.13 This Clean Energy Target, in contrast to the NEG, still promotes widespread investment in renewable or clean technologies. However, the NEG is still in its high-level design stage, so it is yet to be seen how it will impact investment in renewable energy and storage.

Another trend is the increased penetration of renewable energy technologies in the form of solar and battery storage. This correlates with the plunging cost of large-scale solar power, which is said to be a result of the RET.14


i The policy background

Australia's RET aims to ensure that by 2020 at least 33,000GWh (or 23.5 per cent) of Australia's total electricity is generated from renewable sources. The RET is an Australian federal government policy that has operated since 2001.15 Various state and territory governments of the Commonwealth of Australia have also implemented their own renewable energy targets.

Australia is on track to achieving the RET by 2020, with the Clean Energy Council noting that approximately 17,500GWh of renewable energy was generated in 2016 and 25,485GWh estimated for 2017.16 If the RET is achieved, that renewable energy will be enough to power around five million houses per year.17

The RET is made up of two schemes – the Large-scale Renewable Energy Target (LRET) and the Small-scale Renewable Energy Scheme (SRES). The LRET encourages investment in renewable power stations through financial incentives in the form of tradable certificates; the SRES encourages small users to install small-scale systems. Australian states and territories have also incentivised the uptake of small-scale solar generators by providing feed-in-tariffs.

It is expected that the LRET will deliver the majority of the RET.18 The price of renewable energy generation is becoming increasingly more cost-effective. Additionally, investment in large-scale solar projects has been assisted by the Australian Renewable Energy Agency (ARENA) and the Clean Energy Finance Corporation, which have pushed the prices of these projects down to almost half of what they recently were.19 For example, in 2015, ARENA committed A$20.90 million in funding for the DeGrussa solar project in Western Australia, which has a total project value of A$39.47 million.20

While the RET is dependent on investment in renewable energy sources, Australia's new NEG – announced by the Australian federal government on 17 November 2017 – is a technology-neutral policy, allowing for emissions reductions from all sources of power, be they fossil fuels or renewables,21 with the ultimate mix to be decided by the market.22 The Energy Security Board (ESB) recommended the NEG to the government in response to the Independent Review into the Future Security of the National Electricity Market.23

The NEG intends to deliver more reliable, affordable and cleaner energy to Australian consumers24 and has two components – a reliability guarantee and an emissions guarantee. The reliability guarantee will impose an obligation on electricity retailers to meet a percentage of their load requirements through flexible and dispatchable resources. The emissions guarantee will impose an obligation on retailers and large electricity users to meet their load requirements at a certain average emissions level. The latter component is designed to ensure that Australia meets its Paris Agreement obligations to reduce emissions by 26 to 28 per cent of 2005 levels by 2030.25

The NEG does not change the RET; but it is proposed that the emissions-guarantee aspect of the NEG will replace the RET in 2020.26

ii The regulatory framework

Network access and market dynamics

The largest electricity market in Australia is the National Electricity Market (NEM), which operates in all states and territories other than Western Australia and the Northern Territory.27 The NEM is operated by the Australian Energy Market Operator (AEMO), in accordance with the National Electricity Law and the National Electricity Rules.

The NEM includes a 'gross pool' market for electricity, where all transmission-connected generation is dispatched in each five-minute period based on the results of a security and transmission-constrained auction. The auction sets a marginal price for each five-minute period and has a price cap of A$14,200/MWh.28 Generation facilities can connect to the network in the NEM on a 'constrained-access' basis – that is, the total amount of generation capacity is not restricted to network capacity, but only the cheapest set of generators are dispatched to meet system requirements.

In the NEM, most renewable generators are considered to be 'semi-scheduled'. These facilities can normally generate unconstrained; however, the AEMO can direct them to operate below certain output limits in certain situations (for example, for system security).

In Western Australia, the Wholesale Electricity Market (WEM) is operated by the AEMO in accordance with the Wholesale Electricity Market Rules and WEM market procedures. The WEM is a gross pool electricity market that includes a mechanism to pay for capacity by low electricity price caps, and a hybrid constrained–unconstrained network access model. A constrained network access model is currently being considered by the Western Australian government.29 The constrained network access model being proposed for the WEM is similar to the model currently used in the NEM.

Western Australia's mechanism to ensure reliability and security of supply, through which scheduled generators and non-scheduled generators (such as wind and solar) can provide capacity when required, is called the Reserve Capacity Mechanism. The state government proposes to review alternative pricing models for the Reserve Capacity Mechanism in 2018.30


The RET is administered by the Clean Energy Regulator (CER) in accordance with the Renewable Energy (Electricity) Act 2000 (Cth) and the Renewable Energy (Electricity) Regulations 2001 (Cth). The CER is Australia's independent statutory authority, established in 2012 by the Clean Energy Regulator Act 2011 (Cth).

The RET operates as a market for tradable certificates for each megawatt of electricity generated from renewable sources. Tradable certificates are created and issued through the REC Registry, which is administered by the CER. 'Liable entities' (electricity retailers and some large users) must source those certificates from persons that generate power from renewable sources to meet their own renewable energy obligations, and then surrender those certificates to the CER in certain percentages (determined under the Renewable Energy (Electricity) Regulations) to meet annual targets for the RET.

The CER also validates tradable certificates and makes recommendations about tradable certificate requirements.


The NEG is in its early design stages. On 20 April 2018, the federal and state energy Ministers met at the Council of Australian Governments Energy Council and approved more detailed design work on the NEG. Stakeholder workshops will continue to be held throughout May and June 2018. A decision is to be made on the final design of the NEG by August 2018, with the ESB proposing that the NEG be legislated (primarily by way of amendments to the Australian Energy Market Agreement, the National Electricity Law and National Electricity Rules) by the end of 2018.31

We are interested to see the ultimate design of the NEG and in particular how it will affect, and the extent to which it may be adopted in, Western Australia and the Northern Territory, which both operate outside the NEM. The Western Australian Minister for Energy has indicated that, post 2020, there could be a non-national regime guiding the uptake of renewable energy technology.32

Approvals for renewable energy projects

There are many regulatory approvals required for renewable energy projects, including planning and environmental approval. The type and timing of approval processes will vary from state to state, depending on the scale and type of project. Applications for funding from ARENA typically take 60 days to negotiate (after an initial expression-of-interest phase) and require the applicant to satisfy the relevant merit criteria to a high standard. Project proponents may also be confronted with environmental-noise and visual-impact assessments.


i Project finance transaction structures

Current trends in project financing of renewable energy projects in Australia have seen the emergence of the use of 'project' or 'green energy' bonds. Australia's green bond market has doubled in size since the 2015, with the big four domestic banks, and international development banks, being the major issuers of bonds.33 Going forward, increased diversity of issuers is predicted as local governments and councils have shown interest in these types of bonds.34 In fact, the Victorian government in 2016 was the first government in Australia to use green bonds.35 Bonds are seen as an attractive method to finance renewable projects given that they are considerably cheaper than financing or refinancing through traditional project finance.36

In terms of bank lending, currently international lenders are very active in the Australian renewables market, as there is an aversion to long maturity loan funding by Australian lenders.37 However, there is some evidence that this trend may be changing with the landmark financing of three large solar farms by Wirsol Energy and Edify Energy this year. In this transaction, the Commonwealth Bank of Australia funded a 19-year term loan, the first time a domestic Australian bank has lent to a renewable energy project on such a long-term basis.38 In common with other transactions of this nature, it used a combination of debt finance in conjunction with a grant from the Australian government's Clean Energy Finance Corporation.39

An alternative financing arrangement for renewable projects that is starting to appear is the establishment of 'energy funds'. AGL, and now Synergy, have set up energy funds in partnership with institutional investors. The funds provide the opportunity for investors to finance a portfolio of renewable assets, which diversifies risk and reduces cost. It also reduces the amount of equity that energy providers are required to invest in new projects, as well as assisting the energy providers in meeting their 2020 renewable energy commitments. The arrangement is usually set up so that ownership in the renewable energy certificates generated by the project remains with the energy provider.

Australia also has a market for trading renewable energy certificates between financial institutions, brokers, traders, registered agents and electricity retailers. The highest demand for large-scale certificates comes from electricity retailers who are required to meet Australia's renewable energy target.40 Small-scale system owners and registered agents also have the option to sell small-scale technology certificates through the clearing house or to the electricity provider.41

ii Distributed and residential renewable energy

Australia has the highest penetration of rooftop solar of any country in the world,42 with Queensland accounting for the highest proportion of residential installations.43 As battery storage further saturates the market, it is predicted that solar PV growth will be focused in commercial and industrial sectors rather than in the residential market.44 Battery installations have more than doubled, with 1,566 installations in 2016 increasing to 3,763 installations in 2017.45

The ownership structure of solar and battery products varies. The Clean Energy Finance Corporation has provided funding for a major retailer to offer power purchase agreements to customers. The arrangement provides that the retailer owns, installs and maintains the systems, giving eligible residential and business customers the opportunity to buy any electricity generated from those systems at a price that is forecast to be lower than the average retail electricity tariff.46 The benefit of this approach is that residential customers avoid paying the upfront costs of installation while still enjoying a lower cost of energy.

In addition to the customer-ownership model, leasing is an alternative arrangement that is offered in Australia to customers. Solar companies design, install, own, operate and maintain the solar and battery systems and then lease the systems to the customers. The benefit of this approach to customers is that the monthly lease payments are less than the normal monthly power bill.47

Financial institutions have also partnered with the Clean Energy Finance Corporation to provide discounts when financing renewable technologies. For example, Macquarie Leasing currently provides discounted financing for electric vehicles,48 while Westpac also currently offers its customers a discount on renewable energy solutions. Finance options can be in the form of a finance lease, commercial loan or commercial hire purchase agreement.49

iii Blockchain technologies and smart contracts

While not yet commonplace, and with some regulatory hurdles to be overcome, blockchain technologies are emerging in the energy and renewables space. Power Ledger has created a peer-to-peer energy trading application envisaged to be for the benefit of producers and consumers. Its technology aims to enable the sale of surplus renewable energy generated at residential and commercial developments.50 Power Ledger has most recently partnered with a US-based clean energy company to bring its trading platform to North America.51 From a finance perspective, Australian banks are beginning to invest in blockchain technologies and the Australian Securities Exchange is exploring the viability of applying distributed ledger technology to current clearing and settlement systems.52

The Australian government has recently passed the Anti-Money Laundering and Counter Terrorism Financing Amendment Act 2017 to regulate digital currencies. The purpose of the Act is to ensure that currency exchange platforms are regulated to mitigate against money laundering and terrorism financing risks.53 However, these regulations only extend to participants who exchange digital currencies for money and would not currently appear to extend to the use of blockchain technologies limited to trading in renewable energy products. Other regulatory issues with the technology relate to attributing liability in a decentralised network,54 protection of personal data and privacy issues,55 as well as data security.56


On a world scale, Australia has a very small renewable energy manufacturing sector.

The manufacture of renewable energy products in Australia is limited to a number of isolated projects and no major renewable energy manufacturing industries exist in Australia. Presumably this is due to Australia's relatively high income levels and high energy prices, making manufacturing of such products more suited to other countries with lower input costs.

The majority of Australia's renewable energy 'manufacturing' relates to the development and commercialisation of intellectual property. This is arguably driven by the lack of subsidies available in Australia for renewable energy manufacturing, as well as the Australian government's apparent priority of investing in emerging renewable energy technologies and grants or tax incentives for companies that invest in research and development. For example, the Australian government is responsible for:

  1. the A$2 billion Australian Renewable Energy Agency (ARENA), a statutory authority charged with co-investing in projects that improve the competitiveness of renewable energy technologies and increase the supply of renewable energy in Australia; and
  2. the Commonwealth Scientific and Industrial Research Organisation's 'Low Emissions Technology Roadmap', which identifies the opportunities for Australia to be part of the future global energy supply chain.

Australia, and Western Australia in particular, is experiencing strong demand for its lithium mineral reserves because of the increase in lithium-ion batteries (used in electric vehicles and other large battery storage). Australia has the third-largest lithium resources in the world (approximately 16 per cent);57 is home to the world's largest and highest-grade spodumene deposit;58 and was the largest producer of lithium in 2017.59 A number of lithium processing plants are currently being built in Western Australia and the Western Australian government recently announced a task force to explore the potential for Western Australia to also leverage its significant nickel, cobalt, manganese, graphite and copper resources to expand into more of the battery supply chain.60

Australia has free trade agreements with a number of overseas jurisdictions and does not impose any specific tariffs on renewable energy equipment from its trading partners.


We expect that the strong investment in wind and solar projects will continue in the year ahead. Although there is uncertainty around the NEG and its impact on renewable energy projects, it does at least represent a long-term policy (which some commentators say has been lacking in Australia for some time).

We also expect that there will be increased investment (including from government-funded organisations) in projects addressing the intermittency caused by renewable generation and demand-profile issues caused by household rooftop solar.

Batteries and electric vehicles will likely become increasingly more affordable and will play a role in shaping the energy future for consumers.


Note to readers. The Australian Federal Government's policy position on the NEG has changed since this article was published in July 2018, and design plans to legislate the NEG will not proceed. Soon after Scott Morrison replaced Malcolm Turnbull as Prime Minister in August 2018, the Federal Government all but abandoned the NEG. However, some Australian State governments are continuing to develop the reliability guarantee component.

1 Simon Adams is a partner and Jo Garland is a special counsel at HFW.

2 Clean Energy Council, 'Reflecting on a record year for renewables' < https://www.cleanenergycouncil.org.au/news/2018/February/reflecting-record-year-renewables.html>.

3 Capgemini, 'World Energy Markets Observatory', 19 Ed, November 2017, 252 < https://www.capgemini.com/wp-content/uploads/2017/11/wemo2017-vst27-web.pdf>.

5 Harmsen, Nick, 'Tesla's big battery a shining light for SA but storms leave neighbours in the dark', ABC News < http://www.abc.net.au/news/2017-12-01/tesla-giant-battery-officially-launched-in-sa/9215318>.

6 Kimmorley, Sarah, '“That's a record”: Elon Musk's Tesla battery in South Australia responded in just 140 milliseconds after a coal-fired power plant failed' < https://www.businessinsider.com.au/elon-musks-

7 Gifford, Jonathan 'CBUS Super, Dutch Infrastructure Fund to hold 80.1% in Synergy renewable portfolio' < https://www.pv-magazine-australia.com/2018/04/10/cbus-super-dutch-infrastructure-fund-to-hold-

9 In the Black, 'Renewable energy gets set to outsmart coal' < https://www.intheblack.com/articles/2018/

10 Clean Energy Council, 'Reflecting on a record year for renewables' < https://www.cleanenergycouncil.org.au/news/2018/February/reflecting-record-year-renewables.html>.

11 Potter, Ben, 'Explained: how the National Energy Guarantee works', Australian Financial Review (13 April 2018).

12 Australian Government, Department of Environment and Energy, 'Independent Review into the Future Security of the National Electricity Market' < https://www.energy.gov.au/government-priorities/energy-markets/independent-review-future-security-national-electricity-market>.

13 Climate Council, 'Unpacking the Finkel Review' < https://www.climatecouncil.org.au/uploads/39b9568472864b73a1b1c63e99a0aed5.pdf>.

14 Clean Energy Council, 'Reflecting on a record year for renewables' < https://www.cleanenergycouncil.org.au/news/2018/February/reflecting-record-year-renewables.html>.

15 In 2015, the RET was reviewed and was scaled down from the previously legislated amount of 41,000GWh to the current 33,000GWh.

16 Clean Energy Council, 'Renewable Energy Target' < https://www.cleanenergycouncil.org.au/policy-
advocacy/renewable-energy-target.html>. The Clean Energy Council is the peak body for the clean energy industry in Australia.

17 Australian Government Clean Energy Regulator, 'Tracking Towards 2020: Encouraging renewable energy in Australia' (2016), 13 < http://www.cleanenergyregulator.gov.au/DocumentAssets/Documents/The%

18 Tomaras, Juli, Parliamentary Library Briefing Book – 45th Parliament, 'Renewable energy policy: retreat, renewal and revitalisation?', 128 < http://parlinfo.aph.gov.au/parlInfo/download/library/prspub/4787355/upload_binary/4787355.pdf;fileType=application/pdf>. Clean Energy Regulator, 'How the scheme works' < http://www.cleanenergyregulator.gov.au/RET/About-the-Renewable-Energy-Target/How-the-scheme-works>.

19 See note 5 above.

20 Australian Government Australian Renewable Energy Agency, 'DeGrussa solar project' < https://arena.gov.au/projects/degrussa-solar-project/>.

21 Australian Financial Review, 'Energy Minister Josh Frydenberg calls on Australian governments to back NEG' (20 April 2018).

22 Council of Australian Governments Energy Council, 'National Energy Guarantee Questions and Answers', 4 < http://www.coagenergycouncil.gov.au/sites/prod.energycouncil/files/publications/documents/National%20Energy%20Guarantee%20Questions%20%26%20Answers.pdf>.

23 Dr A Finkel AO, K Moses, C Munro, T Effeney, Professor M O'Kane AC, 'Independent Review into the Future Security of the National Electricity Market: Blueprint for the Future' (June 2017) < https://www.energy.gov.au/sites/g/files/net3411/f/independent-review-future-nem-blueprint-for-the-future-2017.pdf>.

24 Council of Australian Governments Energy Council, 'Energy Security Board National Energy Guarantee – Consultation Paper' (February 2018) < http://www.coagenergycouncil.gov.au/publications/energy-security-

26 See notes 4 and 10 above.

27 The Interim Northern Territory Electricity Market was implemented in 2015 and is managed by the Market Operator and System Controller. The territory government will review the learnings from the design, development and implementation of the interim market and consider what is needed for a full Northern Territory electricity market; Department of Treasury and Finance, 'Interim Northern Territory Electricity Market', 2 < https://www.powerwater.com.au/__data/assets/pdf_file/0007/93328/intem-dtf-policy-paper.pdf>.

28 AEMO, 'Fact Sheet The National Electricity Market' < https://www.aemo.com.au/media/Files/Electricity-

29 Government of Western Australia Department of Treasury, 'Electricity Sector Reform Initiatives – A roadmap for the current reform work program' < http://www.treasury.wa.gov.au/uploadedFiles/Site-

30 Ibid.

31 Energy Security Board, 'National Energy Guarantee: High Level Design Document' (20 April 2018), 11 and 47 < http://coagenergycouncil.gov.au/publications/initial-design-guarantee>.

32 The West Australian, 'WA could go it alone on green power policy beyond 2020 after coalition ditch Renewable Energy Target' (18 October 2017) < https://thewest.com.au/news/wa/wa-could-go-it-alone-on-

33 Oliver Yates, Australia's budding Green Bond Market, Clean Energy Finance Corporation < https://www.cefc.com.au/media/feature-articles/files/australias-budding-green-bond-market.aspx>.

34 Ibid.

35 Victorian Government, 'Victorian Green Bonds an Australian and World First' (media release, 20 July 2016) < https://www.premier.vic.gov.au/victorian-green-bonds-an-australian-and-world-first/>.

36 World Business Council for Sustainable Development, 'Pathways to scale finance for renewable energy' (11 November 2016), 13 < http://www.wbcsd.org/Programs/Energy-Circular-Economy/Climate-Energy/Resources/Pathways-to-scale-finance-for-renewable-energy>.

37 Edify Energy Pty Limited and WeleeAustralia Pty Ltd, 'Whitsunday Solar Farm –Knowledge Sharing Report – Securing Project Financing' (October 2017), 11 < http://edifyenergy.com/wp/wp-content/uploads/2017/11/ARENA-Knowledge-sharing-report-Securing-project-finance.pdf.>.

38 Ibid., 7.

39 Ibid.

40 Australian Government Clean Energy Regulator, 'Renewable Energy Target – Tracking Towards 2020: Encouraging renewable energy in Australia' (30 March 2017), 22.

41 Ibid., 18.

42 International Energy Agency, 'Medium Term Renewable Energy Market Report 2016' (2016), 144 < https://www.iea.org/publications/freepublications/publication/MTRMR2016.pdf>.

44 Ibid.

45 Ibid., 6.

46 Clean Energy Finance Corporation, 'CEFC makes solar more accessible for hourseholds, businesses' (fact sheet, July 2015) < https://www.cefc.com.au/media/107381/cefc-factsheet_origin_lr.pdf>.

48 Macquarie Leasing, Energy Efficient Finance, Macquarie Group Limited < https://www.macquarie.com/au/business-banking/loans-asset-finance/technology-vehicles-and-equipment/>.

49 Westpac Banking Corporation, Energy Efficient Finance, Westpac Banking Corporation < https://www.westpac.com.au/business-banking/business-loans/equipment-finance/energy-efficient-finance/>.

50 Power Ledger, 'All Power to Producers and Consumers', Power Ledger < https://web.powerledger.io/>.

51 Power Ledger, 'Power Ledger Partners With Helpanswers To Bring Distributed Renewable Energy Trading To North America' (press release, 2 February 2018) < https://web.powerledger.io/mediarelease/>.

52 Tranter Wilson, Alice, 'Cracking the code: bringing initial coin offerings and decentralised autonomous organizations within the Australian corporate law framework' (2018), 34(1) Australian Banking & Finance Law Bulletin, 14, 15.

53 Cheung, Ka-Chi, 'Blockchain: enforcement and regulations' (2018), 20(10) Internet Law Bulletin, 178, 180.

54 Tranter Wilson, Alice, 'Cracking the code: bringing initial coin offerings and decentralised autonomous organizations within the Australian corporate law framework' (2018), 34(1) Australian Banking & Finance Law Bulletin, 14, 15.

55 Cheung, Ka-Chi, 'Blockchain: enforcement and regulations' (2018), 20(10) Internet Law Bulletin, 178, 179.

56 Tranter Wilson, Alice, 'Cracking the code: bringing initial coin offerings and decentralised autonomous organizations within the Australian corporate law framework' (2018), 34(1) Australian Banking & Finance Law Bulletin, 14, 15.

58 In Greenbushes, Western Australia, approximately 250km south of Perth < http://www.ga.gov.au/data-pubs/data-and-publications-search/publications/aimr/lithium>.

59 See note 40 above.