The Clean Energy Council (CEC) welcomes the opportunity to provide feedback to the Australian Energy Market Operator (AEMO) on the draft High Level Implementation Assessment (HLIA) for the Integrating Price Responsive Resources (IPRR) into the National Electricity Market Rule Change.
Consumer Energy Resources (CER) will play a major role in achieving Australia’s decarbonisation ambitions, especially in moving towards our targets in the immediate future and during the current period where we work towards unlocking investment in large scale renewable projects.
We recognise that effective integration of CER is reliant on improving the quality of forecasting in both near term 'dispatch’ and longer term ‘planning’. This effective integration is a necessary precursor to achieving the benefits projected by the CEC and others, and encouraging more orchestrated assets and virtual power plants (VPPs) into the market.
The CEC feedback to AEMO is based on the following principles which we think is necessary for successful implementation of the IPRR Rule Change:
- Customer choice. This is a fundamental principle and clearly embedded in both the Rule Change and the AEMO HLIA. The current approach proposed by AEMO and the AEMC clearly recognises that not all customers will be interested in having their resources scheduled by a market participant.
- Simple to follow processes and low administrative complexity. While it will be critical for AEMO to confirm that individual CER devices and aggregated VSR portfolios meet the relevant technical requirements considered necessary for effective dispatch, it will also be critical to reduce the administrative complexity where possible.
- Fit for purpose processes that recognise the unique characteristics of CER compared with single, utility scale, scheduled assets.
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