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14 September 2025
Consumer Energy Resources Taskforce
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
Canberra ACT 2601
Submitted electronically: certaskforce@dcceew.gov.au
Re: National Technical Regulatory Framework for CER and Technical Standards for
CER Interoperability
Red Energy and Lumo Energy (Red and Lumo) welcome the opportunity to respond to the
Department of Climate Change, Energy, the Environment and Water’s (the Department’s) consultation on National Technical Regulatory Framework for CER (Workstream T2) and
Technical Standards for CER Interoperability (Workstream T1).
We acknowledge the significant role Consumer Energy Resources (CER) will play in
Australia's energy transition and emission reduction targets. We agree that a National
Technical Regulatory Framework can harmonise technical standards for devices and installers more broadly and at a jurisdictional level. We also strongly support technical standards for CER interoperability as important enablers of competition in CER-related services, as this ensures consumers are not locked into specific products or providers.
However, an important consideration is how owners of CER want to use their assets and how this will evolve over time. The transition is in its early stages and it is likely that many
CER owners have invested in these assets to optimise their own consumption or respond to static price signals, such as more cost reflective network tariffs. This will shift over time and more CER owners will be willing to contract with third parties to aggregate and coordinate the output of their CER to participate in more centralised processes, such as wholesale and
FCAS market. It is important that the technical framework retains consumer agency and choice over the use of CER. This means mandated technical standards that reflect the preferences and needs of CER owners, rather than broad assumptions (about a willingness to participate in centralised processes, for example).
Technical Regulatory Framework
We encourage the Department to carefully consider the scale, form, and timing of active
CER participation. The degree of CER orchestration should determine the need for mandatory accreditation of CER devices or installers, as well as the scope of requested connection information.
While mandatory accreditation of devices and installers within a streamlined national market for CER devices offers consumer protections, it may also introduce compliance and enforcement risks, potentially increasing costs for consumers. Therefore, we recommend an iterative approach under which the Department can assess how the market is developing and to which devices and activities any mandatory requirements should apply. A targeted cost-benefit analysis should be conducted to ensure that benefits clearly outweigh consumer costs and to prevent barriers to market entry.
Our view is that prescribed CER connection information is appropriate for orchestrated devices or those with direct potential to impact system security (e.g. generators, solar PV, batteries). The relevant information is the presence of an inverter and export capacity.
However, mandatory collection of information about non-orchestrated devices raises privacy issues and may impose some costs for little benefit. A further consideration is to define which actors in the Technical Regulatory Framework should have access to what level of information, particularly for any information broadcast in real-time.
There is value in an inter-jurisdictional body to establish minimum standards, accreditations, and compliance and enforcement. The Clean Energy Regulator is a reasonable candidate to assume this role. This function could also extend to the oversight of Dynamic Operating
Envelopes, which will become an increasingly important component of the transition.
Interoperability
Interoperability is an essential element of the transition and we welcome the Department’s ongoing focus. We agree with the proposed scope of a National CER Technical Code, which will focus on devices containing bi-directional inverters (inverters and power conversion equipment, PV modules, energy storage devices), and the associated CER communications protocols (CSIP-AUS). This approach would directly and broadly contribute to CER orchestration.
Existing standards such as AS4777.1/ AS4777.2 and current backstop mechanisms already support many of the identified requirements for energy generation and storage devices. e.g.
disconnection (R-1), modulate power in response to grid connection (R-2), modulate power in response to external signal (R-3), local CER to CER coordination (R-11) and default CER settings (R-13). We also support interoperability standards for energy generation and storage devices that provide unique identifiers (R-10) and trusted communication pathways
(R-12) and should be prioritised, along with switch providers (or customer) (R-9).
However, our view is that remote communication requirements such as remote reading of device telemetry (R-4), remote reading of device settings (R-5) and remote updating of device settings (R-6), should only be considered where there is a clear need and after conducting a thorough cost-benefit analysis, particularly before being applied to flexible loads.
About Red and Lumo
We are 100% Australian owned subsidiaries of Snowy Hydro. Collectively, we retail electricity and gas in New South Wales, Queensland, South Australia, Victoria and the ACT to over 1.5 million customers.
Red and Lumo thank the Department for the opportunity to comment on the consultation paper. Should you wish to discuss or have any further enquiries regarding this submission, please call Thakshila Gunaratna, Regulatory Manager, on 0461 338 686.
Yours sincerely
Geoff Hargreaves
Manager - Regulatory Affairs
Red Energy Pty Ltd
Lumo Energy (Australia) Pty Ltd
