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Submission to the AER Draft Ring-fencing Guideline (version 3)

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Energy Consumers Australia

We appreciate the opportunity to provide a submission in response to the Australian Energy Regulator’s (AER) Draft Ring-fencing Guideline Version 3.

In our previous submission (supported by Strategen Australia Pty Ltd) we outlined the uncertainty around how storage technologies and applications are going to open up a range of technological, economic and societal innovations in the delivery and trading of energy and energy services.

We recognise that this is blurring the boundaries between traditional regulated and unregulated models and services. In doing so it creates new potential for value stacking of services with a range of benefits for customers.

However, the exact form and detailed structure of such applications (and value stacking realisation) is still emerging and is difficult to predict. Due to this disruption the future will likely look very different from the past to the extent that we cannot even currently anticipate exactly how such opportunities will be realised and evolved through this emerging technology.

For these reasons we advocated for a principles-based approach rather than a prescriptive approach to the Ring-Fencing Guideline, along with enhanced information provisions, to provide a means for emerging technology applications and markets to be evaluated as they expand and mature and as experience is gained, and shared, across a diverse and expanding range of technology applications.

We believe that the proposed Ring-Fencing Guideline reforms may not do enough to enable emerging opportunities in a manner that works in the long-term interests of consumers.

Read our full submission here.

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