How technical standards are developed, implemented, and enforced have a direct impact on the performance, functionality, and cost of Consumer Energy Resources (CER). This affects not only the broader market and system operation, but how consumers view, relate to, and operate these assets, impacting the routines of daily life inside Australian homes and business. That’s why it is vital that we get them right.
We broadly support proposed recommendations 1-12 outlined in the draft report. However, we would encourage the AEMC to review the recommendations and liaise with the proposed responsible parties to ensure that they can and will be delivered. We also recommend the AEMC address recommendation 13 concurrently, and investigate opportunities to reform national technical regulation, given the rates of non-compliance, the timeframe to implement some of these recommendations and the issue of them being voluntary.
Our view is that all current and future technical standards need to be developed and enforced within an overarching policy framework that can connect consumer outcomes, market and system design and objectives, and the standards setting process. This policy framework should be applied by a separate governance body, such as a new national consumer energy resource technical regulator. This approach would guide not only AS4777.2.2020 but all future technical standards that are developed, mandated, implemented and enforced.
Read our full submission here.