We appreciate the opportunity to comment on the Australian Energy Market Commission’s (AEMC) Governance of Distributed Energy Resources Technical Standards, Draft Determination Paper.

In our view the current governance process in which Distributed Energy Resources (DER) Technical Standards are created and implemented, lacks an overarching policy framework. Our previous submissions on this issue (see links below) have highlighted the need to focus on consumer outcomes, as the framing for the development of technical standards. Appropriate standards are a key input to giving consumers confidence that they have choice and control over their generation, storage assets and appliances in their homes and small business premises, and by guiding manufacturers and installers to ensure a safe and effective product.

A clear policy framework would recognise the inter-relationship between consumers and the use and control over their assets and appliances and the effective operation of both the energy system and related markets. While integration of these “consumer energy resources” means developing capabilities that allow the various technologies to communicate with each other and the system, this must be done in the context of consumer and society outcomes and social licence.

Read our submission here where we go into further detail on consumer participation in the energy system and markets, the disconnect between consumer outcomes, system objectives and the standard setting process and finally, a way forward where we propose a standing governance body overseen by the AEMC.

Previous DER Submissions

• Submission to the AEMC’s National Electricity Amendment (Technical Standards for Distributed Energy Resources) Rule 2020 and National Energy Retail Amendment (Technical Standards for Distributed Energy Resources) Rule 2020 Consultation Paper.
• Submission to the AEMC’s National Electricity Amendment (Technical Standards for Distributed Energy Resources) Rule 2020 and National Energy Retail Amendment (Technical Standards for Distributed Energy Resources) Rule 2020 Draft Determination.
• Submission to the ESB’s Governance of DER Technical Standards Consultation Paper
• Submission to AEMO’s Initial Distributed Energy Resource Minimum Technical Standards Issues Paper.
• Submission to the AEMC’s Governance of Distributed Energy Resources Technical Standards, Consultation Paper.