We appreciate the opportunity to comment on the Australian Energy Market Commission (AEMC)’s Consultation Paper which includes the National Electricity Amendment (Governance of Distributed Energy Resources Technical Standards) Rule 2022 and the National Energy Retail Amendment (Governance of Distributed Energy Resources Technical Standards) Rule 2022.
We have made previous submissions on this issue, including on the AEMC consultation paper and draft determination for the related rule change in August 2020 and January 2021, the Energy Security Board (ESB) consultation in August 2020, and the Australian Energy Market Operator (AEMO) in September 2020. In all of these, we have emphasised our focus is on better consumer outcomes. A strong consumer voice is required in the development of technical standards, as well as a decision-making process that appropriately recognises the value of Distributed Energy Resources (DER) to consumers.
The traditional way of approaching an issue of this type is to take a technological and systems approach. However, consumers do not use these assets in a purely economically efficient or technologically practical way, but rather based on their own needs and as part of daily functioning and wellbeing. It is for these reasons we propose co-design as an alternative approach to enable decisions around DER technical standards be focused on the end-user consumer. This method is founded in design thinking, a process of human-centred creative problem solving.