Energy Consumers Australia appreciates the opportunity to provide comments on the Integrating Price Responsive Resources into the NEM consultation paper.

At Energy Consumers Australia, we prefer to refer to ‘price-responsive resources’ as ‘consumer energy resources’ (CER), because this places importance on the consumers who own these resources. Consumers do not sit outside the system, they are the system.

For the energy transition to be least-cost, consumers will need to rapidly increase their uptake of CER, and these technologies will need to be well integrated into the market.

If the integration of small-scale CER is done successfully, these small-scale resources will grow large in aggregate and be treated equitably with utility-scale resources in the energy system. This will benefit all consumers, by:

• Providing low-cost sources of services, like generation capacity, energy, and voltage and frequency regulation, that the electricity system requires;
• Reducing the quantity of services AEMO must procure, and therefore the cost, by increasing AEMO’s visibility of consumer demand; and
• Providing direct benefits to CER owners by rewarding them for the value their resources bring to the system.

Our submission makes three key points in response to the questions raised in the consultation paper:

1. AEMO will eventually need to have visibility over CER, and consumers will benefit from this visibility.
2. Visibility shouldn’t be mandated and should vary by resource type.
3. To incentivise visibility, grant energy service providers access to markets if they provide greater visibility of their resources to AEMO.

Read the full submission here.