The following submission from Energy Consumers Australia addresses the key questions raised by both the Energy Security Board (ESB) Interoperability Policy Directions paper and the Australian Energy Market Commission (AEMC) Review into Consumer Energy Resources (CER) Technical Standards Consultation paper. We have decided to combine our commentary and recommendations on both papers as we believe, from a consumer outcomes perspective, they are heavily related issues.

“How” technical standards are mandated and enforced, and “who” is responsible for mandating and enforcing, are the two key questions we see as unanswered in the current technical standards process. The following submission will make two key recommendations that address these questions.

1. That a policy framework for mandating and enforcing technical standards for CER is adopted. Such a framework will help ensure that technical standards are designed and enforced with optimal consumer outcomes.

2. An independent governance body should be assigned the responsibility of applying this policy framework. Without clear roles and responsibilities assigned to an overarching body, a policy framework will be less likely to deliver technical standards which achieve positive consumer outcomes. We are interested in discussing the ESB’s suggestion of a new national consumer energy resource technical regulator further but would maintain that this body be independent, apply a policy framework and maintain transparency.

Read our full submission here.