Published name
Have we captured all the activities (or ‘use cases’) required to operate power systems and markets in a high CER future?
Have we assigned each of the activities to the role and existing actor most appropriate to undertake the activity now and in the near term?
If no, note the activities you consider could or should be undertaken by an alternative existing actor now or in the near term and describe why this actor would be better placed to undertake the activity.
Refer the attached submission.
Recommendations are made relating to Customer Agent, CER Conformance Monitor and CER Conformance Assessor.
Should any of the actor assignments be reconsidered now or in the future?
If yes, note the activities you consider could or should be undertaken by an alternative existing actor in the future and describe why this actor would be better placed to undertake the activity in the future. When explaining why, please refer to our assessment criteria in appendix A.
Refer the attached submission.
Recommendations are made relating to Customer Agent, CER Conformance Monitor and CER Conformance Assessor.
We have identified six key areas where we consider it to be an immediate priority to clarify, formalise and standardise the roles, expectations and accountabilities. Select the area that you consider to be the highest priority?
Why do you consider this to be the highest priority area to clarify, formalise and standardise the roles, expectations and accountabilities?
A high CER future is only feasible provided CER fulfil their role in system security frameworks.
Other comments
No comments.
Device-level data
Refer the attached submission.
CER monitoring data
Refer the attached submission.
Off-market mechanisms
Refer the attached submission.
Conformance and compliance of CER participating in off-market mechanisms
Refer the attached submission.
CER in system security frameworks
Refer the attached submission.
Conformance and compliance of CER within security frameworks
Refer the attached submission.
Do you think off-market mechanisms, along with other actions to improve visibility and predictability, support effective orchestration and embed CER in system security frameworks will, over time, be able to capture most (if not all) of the benefits of market orchestration of CER?
Do you think the long-term benefits of distribution level market arrangements would outweigh the cost and complexity of implementation?
Please provide reasons to explain your selection above.
Most customers are unlikely to participate in distribution level markets because they will avoid that level of complexity. Thus there will be few benefits.
What triggers/conditions in the future might indicate a need for more fundamental reform to more comprehensively integrate CER into the NEM wholesale market?
No triggers are apparent.
If reforms to distribution-level market arrangements were progressed, which of the models described in the chapter do you consider most appropriate to integrate CER into the NEM wholesale market?
Please provide reasons to explain your selection above.
None of the distribution level market models are considered appropriate.
Are there any other market designs that you think should be considered, compared to Designs A-C in this paper?
No
When considering how best to integrate CER into the power system and market are the institutional arrangements that govern how decisions are made within a DSO a priority for you?
Please provide reasons to explain your selection above.
Of the potential issues we have identified when considering whether or not DNSPs can perform the role of DSO effectively,which issue do you consider to be the highest priority to address?
Please provide reasons to explain your selection above.
Refer to the attachment.
Lack of consistency across DNSPs introduces overall inefficiency across the industry.
Do you support further investigation of governance reform options, and if so, which one/s?
Please provide reasons to explain your selection above.
This reform should address Lack of consistency across DNSPs.
Do you consider any of the governance reform options not appropriate in the Australian context?
Please provide reasons to explain your selection above.
For distribution networks in Australia with high penetrations of residential customer CER, having a DSO independent of the DNO is anticipated to be an extremely difficult arrangement to make work effectively. The challenges described in Section 5.4.2 of the consultation paper are anticipated to be major, particularly those of operational complexity.
Do you have any further comments relating to governance option?
No
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