We appreciate the opportunity to make a submission to the Australian Energy Regulator (AER) on their review of the Distributed Energy Resources (DER) Integration Expenditure guidance note.

We are pleased that the AER is providing this guidance note as it is imperative that there is transparency in distribution network investment with clear input assumptions for integrating DER.

However, we do have two primary concerns with the guidance as drafted.

• First, we see a clear opportunity to significantly motivate Distributed Network Service Providers (DNSPs) to more seriously look at consumer energy/demand flexibility as part of the solution set. We suggest that the AER make consumer demand management and other non-network approaches the default option for integrating DER.
• Second, the draft guidance decidedly excludes “intangible benefits” that are critical elements in consumer decision making from their cost-benefit analysis.

We invite you to read our full submission, which includes a broader note from Strategen on a future-resilient and consumer-focused approach to integrating DER, for more detail on the issues and opportunities that we have identified. We would be happy to partner with the Market Bodies or other industry partners in order to further the discussion.