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September 2025 – Australia
Submission on the Technical Standards for Consumer Energy
Resources (CER) Interoperability Consultation Paper
10th Sept 2025
CER Taskforce
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
Canberra ACT 2601
Lodged electronically
SolarEdge Technologies is a global frontrunner in smart energy solutions, particularly renowned for revolutionising how solar power is harvested and managed with its direct current (DC)-optimised inverter systems. Since its foundation in 2006, the company has shipped over 57 GW of systems and monitors more than 4.3 million solar installations across 145 countries, demonstrating its considerable global reach and technological leadership. SolarEdge’s design, pairing optimisers with a string inverter, boosts energy yield, enhancing output by 2%–15% in all settings and delivers up to 50 extra days of energy per year. Its broad, diversified product line (including inverters, power optimisers, monitoring platforms, electric vehicle charging, and battery storage) further underpins its strong market position and appeal to a wide range of energy stakeholders across both residential and commercial distributed markets.
SolarEdge welcomes the opportunity to respond to the Department of Climate Change, Energy, the
Environment and Water’s consultation on the National CER Roadmap, Technical Standards for
Consumer Energy Resources (CER) Interoperability workstream.
Introductory remarks
It is evident with the rapid update of home batteries, under the Cheaper Home Batteries Program, that consumers' priorities for buying devices are now based more around self-consumption than market participation.
Customers already have access to choose from a wide range of energy products, as well as system aggregators (VPPs) to maximise consumer returns on investment in CER if they so wish. Given that under the Cheaper Home Batteries Program, systems need to be VPP capable, and considering compliance for Emergency Backstop mechanisms, CER, as a mandatory functional, already requires the ability to communicate with the energy provider to be able to operate the devices.
September 2025 – Australia
It is stated in the paper that some states and territories have implemented, or are in the process of developing, initial standards to improve interoperability (Table 3), however, none of these actions improve interoperability; they actually restrict it and reduce consumer choice.
When the DNSP has control over consumer CER and also controls when and by how much energy can be controlled, this does not create a competitive landscape. It has already created the situation that VPP providers and energy retailers are now competing with the DNSPs who have a higher level of priority when it comes to visibility and control over the CER devices.
Furthermore, functions such as the generation signalling device in Queensland will override any other control signal; it actually stops CER under control from operating completely, meaning that all behind- the-meter self-consumption will cease. How can this be considered a mechanism to improve interoperability?
Communication pathways such as CSIP-AUS (Common Smart Inverter Profile Australia, SA HB 218:2023) are CER to DNSP utility server connection and communication pathways, market participants and energy providers do not use this protocol, again this does, and will not improve interoperability, it hinders it as the DNSP monopolies, that have the overarching and control authority over the CER complete directly with market participants and energy providers reducing consumer choice and options.
The approach of this paper seems to assume, or imply, that the concept of interoperability, especially behind-the-meter interoperability, is a new idea and that standards should be developed to create a platform for all devices to talk to all other devices. Firstly, interoperability has been around for many years; most OEMs already have proven solutions rolled out in scale in Australia and internationally.
Secondly, creating an open communication platform should not be a mandatory approach for consideration, as this in many situations, will create issues for consumers due to warranty and support challenges. Having said that, multiple solutions already exist in the Australian industry for HEM’s providers to be able to talk to and coordinate devices from multiple OEMs.
The actual need and outcomes implied within this paper have not been articulated or considered.
Again, there are implications of the restriction of consumer choice and limitation of control functionality, which is simply not true. There are assumptions that consumers are not able to access energy provider platforms that simply do not exist. Ideally, there should be a paper looking at what new and innovative market mechanisms and DOE-type tariff structures could be developed to encourage greater uptake of VPPs and distributed interoperability and then look at how to link these to devices, as this would have been far more revealing as to why consumer behaviour is predominantly focused on self-consumption over network participation.
When it comes to complexity over energy provider churn, this has nothing to do with hardware or communication function of CER, it is all to do with contracts and arrangements with energy providers, which is not a topic addressed in this paper.
September 2025 – Australia
Feedback on Consultation Questions
Question 1 - Should the capacity for consumers to switch energy service providers (churn) be prioritised and what are the impacts?
In principle, freeing up the capacity for consumers to switch energy service providers (churn)
should be supported, but in itself it should not be prioritised as this is an outcome to a series of
other key requirements that require initial focus and development.
The assumption in this question is that churn is impacted by a limitation of CER integration
protocols or a lack of a nationally consistent approach. In reality, most of the churn restriction or
complexity comes from the energy providers or CER aggregators.
Improving coordination between CER devices within a household, like a solar panel and a
battery, is an odd statement as solar panels are not controlled; it is the inverter, which is the
controllable CER device, that will need to work in tandem with the battery system (if not already
fully integrated, as 70%+ of installed devices already are). So, operating the two independently
rarely, if never, happens. This is a theoretical use case with no practical application, so it should
not be considered. The only real consideration would be separating out devices such as Solar &
battery systems (combined) from EV Chargers and maybe large controllable loads such as hot
water heating systems.
Furthermore, there is an assumption that allowing consumers to switch energy service providers
between individual CER devices will somehow unlock greater choice and value; there is no
evidence that this scenario exists either. It is often the case that an energy service provider will
aggregate all CER devices into a single package.
The ability for consumers to smoothly switch their energy service provider is likely to encourage
innovation and unlock additional value to consumers from greater choice from retail contracts,
is again a limitation on the energy providers and not the CER device communication protocol.
It has not been established either that switching providers can encourage the development of
innovative products and retail contracts through which CER owners can provide flexibility
services to DNSPs and the system operator, and be remunerated in return, as such remuneration
packages do not really exist; if anything, they compete with each other, especially when
aggregators have to battle with mandatory DNSP control.
Question 2 - What are your views on interoperability hierarchy via the vehicle and an EVSE? Do you think the EVSE should take precedence over the vehicle or vice versa?
The EVSE should always take precedence over the vehicle; the vehicle should not be considered
at all.
September 2025 – Australia
It makes no logical sense for Electric vehicles and EVSE to have been separated and treated as
two separate CER devices. An electric vehicle cannot be defined as CER as it is not a piece of
electrical equipment and as such, cannot be defined in legislation or called up in any of the
Australian Standards.
Power, either too or from an Electric Vehicle, has to go through an EVSE, therefore by defining
both as CER would then create the situation that the control and function of the vehicle would
always be overruled by the control and function of the EVSE, therefore negating any beneficial
outcome.
What is key, however, is that the EVSE at any point in time should be able to communicate to
the DNSP or energy provider its potential functional outcome. For instance, a charge command
would not be possible if the car were already charged.
It is also worth highlighting that EVSE should be able to be controlled by a HEMS, as in most
cases it is always desirable to charge an EV from excess solar power before exporting it to the
grid; this function should fall within the hierarchy of controls as well.
Question 3 - Should minimum device/system requirements be applied to EV Level 1, Mode 1 and Mode
2 charging technologies, as per discussion in section 4.1?
There is no need to apply any minimum device/system requirements for EV Level 1, Mode 1 and
Mode 2 charging technologies, as per the discussion in section 4.1 as these are not only defined
as out of scope but also limit any type of controllability and visibility, given that they can be
transported with the car and used anywhere.
Question 4 – Should minimum device/system requirements be applied to public EVSE?
Yes, regardless of ownership (private or DNSP).
Question 5 – Are there any CER device types or use cases not adequately captured in the 13 identified requirements?
No.
Question 6 - Are there any other standards that can support each identified requirement?
The issue with approaching this subject from standards only is that it will stifle innovation.
It is already well established that standards lag behind industry, so mandating or defining
interoperable standards will not support the development and enhancement of the industry.
September 2025 – Australia
In addition, it should be considered to adopt an outcomes-based approach to interoperability to
embrace innovation; without this, there will be a cap and limitation of the progression of the
industry.
Question 7 - In the mapping exercise in Table 5.14, do you agree with the identified gaps? Are there existing standards that could fill these identified gaps?
As previously mentioned, what is an outcomes-based approach to interoperability to embrace
innovation; without this, there will be a cap and limitation of the progression of the industry as
standards lag behind industry. Simply defining interoperable standards will not support the
development and enhancement of the industry.
Question 8 - Do you have views on the prioritisation of further standards work to address the identified gaps?
The approach taken looks at device-level standards and protocols, but completely misses HEMs
devices that are already fully capable of filling a lot of the gaps identified. For instance:
• R-12, R-7, R-3, R-10, R-9 all state they are missing the following device standards:
o (EVSE Load only)
o (EVSE V2G) must include EVSE
o Missing (EV)
o AS4777.2 (PV)
o AS4777.2, AS 4755.3.5 (ESS)
o AS 4755 Air Conditioners, Pool Pumps, missing hot water heaters (Flex Loads)
o Missing (EMS)
Although this may be correct but all of these data sets and control functions can be
provided via a HEMs controller and local HEMs to CER proprietary communication
software.
• R-12, R-7, R-3, R-2, R-5, R-4, R8, R-11, R-6 and R-1, all state they are missing EMS in the
communication standards, although it is very unlikely that a standalone EMS will exist,
most of these requirements come from the HEMs device as a standalone entity or from
the inverter, which has this function built in.
Question 9 - How can Australia align with international standards while maintaining flexibility for local conditions?
It can’t….
The issue with international standards is that they have been designed for different grids,
different market mechanisms, different regulatory requirements and consumer obligations.
September 2025 – Australia
The other issue is that as soon as international standards, such as IEC, are adopted with
immediate effect. Australia would therefore have to manage the ongoing challenge of battling
immediate adoption when such standards are amended or updated. Australia is one of the only
countries in the world that has adoption periods for the implementation of new or updated
standards.
What is advisable is to look to do a modified adoption of international standards so that they
suit the Australian landscape, such as has been done with the CSIP (IEEE 2030.5) development
into CSIP-AUS (AS 5385:2023).
Question 10 - Are there any risks associated with the identified requirements, such as remote updating of device settings?
There are three fundamental risks in the defined requirements:
1. There is the assumption that all communication needs to be with the individual CER device;
this ignores all HEMs and proprietary systems.
2. There is the assumption that it will be a good outcome for interoperability communication
protocol to be mandated and that any CER device should be able to communicate with any
other CER device or individually to an energy provider or network.
In many situations, such an approach is actually a worse outcome for a consumer as devices
will not necessarily co-optimise when issues arise. Claiming on product warranties is
extremely difficult for a consumer. The best example of this is at a system level when a
battery, inverter and EV Charger are of different brands. When the system is trying to
maximise behind-the-meter benefit for the consumer, such as trying to maximise self-
consumption, the management, and hierarchy between the battery and EV Charger will need
to be managed. If the battery, for instance, stops charging and goes into error mode, it can
often be the case that the battery manufacturer will blame the inverter or HEMs provider, the
inverter manufacturer or HEMs provider will blame the battery manufacturer, and the client
then is in a situation where getting an issue resolved is extremely challenging.
In many situations, the customer is better off having products from the same OEM with their
own, secure proprietary control software, which would be more advanced and function
better than anything defined in current standards, which lag behind innovation.
Although having standards for interoperability is a very sensible idea, they should not be
mandated, and outcomes-based approaches to function, visibility and control should also be
considered.
September 2025 – Australia
3. Remote updating of devices needs to be very carefully managed and tested, as this can and
often does introduce unforeseen issues. Any changes to devices should be carried out by the
OEM as they will have internal alpha and beta testing processes to carefully manage the roll-
out of updates to ensure new issues or conflicts do not arise. It should always be at the
discretion of the OEM to carry out such efforts, as the product and its function will always fall
under the warranty obligation of the OEM as defined in the Australian Consumer Law.
Question 11 - Modulating power in response to grid conditions or an external signal can be implemented through zero generation or zero export. Is there a preference for either of these approaches or both?
Zero generation or zero export are very blunt stick approaches and are not considered
modulation of power; these are either simply curtailing export or curtailing complete
production. There is no mention of control of import, export or overall production in a granular
fashion.
The requirement, as defined in 5.2 R-2 for modulating power in response to grid conditions,
requires CER to automatically adjust power input/output in a standardised response to grid
conditions. For any AS/NZS 4777.2:2020 certified device, this function is already mandatory.
Features already implemented in Australia in all such grid-interactive devices include:
• Voltage response modes;
o Volt-Watt
o Volt-Var
o Sustained over-voltage response modes
o Voltage disturbance withstand
o Multiple voltage disturbance withstand
o Voltage phase and shift withstand
• Frequency response modes:
o Response to increase in frequency
o Response to decrease in frequency
o Rate of change of frequency
• Fixed & reactive power modes
• Power rate limits
o Gradient of power rate limit
o Soft ramp limit
o Non-linearity of power rate limits
• Changes in energy source operation
• Active and passive anti-islanding
When CER is required to automatically adjust power input/output in a standardised response
due to an external signal, although it can be implemented through zero generation or zero
September 2025 – Australia
export, it is only ever needed to be managed down to zero export for the purposes of
Emergency Backstop Mechanisms.
The need for Zero Generation is never called for, as this has zero social license and is seen as
unfairly impacting on the consumer, as it will remove any self-consumption capability they have
and will force them to import from the grid to cover their loads when they have the potential to
cover this requirement via their own generation.
(Note, zero generation is the mechanism used by Energy Queensland for the
implementation of Emergency Backstop Mechanisms, as they opted to use the DRM0
function; this has received widespread criticism from the industry).
It is accepted that the requirement to modulate power in response to grid conditions is an
important capability for CER devices that can generate power. Mechanisms such as Flexible
Exports or DOEs already provide this service; there is no need whatsoever to consider
preferencing zero generation or zero export, it is the completely wrong approach and wrong
question.
The only question to consider is whether Flexible Exports or DOEs should be prioritised. For this
question, the answer would be DOEs, as they can also manage the introduction of load onto the
network, as opposed to only having the management of exports. The market mechanisms need
to be considered for this, so that consumers are finally rewarded for sacrificing self-
consumption.
Question 12 - What are the risks of supplier (OEM) locking in under current standards, and how might these be mitigated?
CER, at a system level, can comprise of devices from multiple OEMs.
The primary device level OEM, though that supplies the functional hardware such as an inverter,
battery or EV Charger, would offer little to no risk of lock-in under current standards as they
have to comply with such a range of standards already, and all existing standards can co-exist.
Independent device controller (or HEMs provider) OEMs, however, do have the ability to lock in
consumers as they control the singular communication channel for the site-level CER devices. In
most cases, where CER, as part of the overall system is supplied from multiple OEMs, there will
need to be a single point of control and communication as mandatory compliance
requirements, such as Emergency Backstop Mechanisms only send a single command to the
NMI location, but is multiple inverters are used as part of the system, from different OEMs then
they will require coordination from a 3rd party device controller.
September 2025 – Australia
One risk of lock-in under current standards is not from the OEM but from the DNSPs. Under
CSIP-AUS (AS 5385:2023), CER is locked into a permanent communication and control
mechanism with the DNSPs utility server; in some circumstances, this represents a control and
communication package being sent every 5 minutes. This, in itself, can limit the ability of devices
to respond to other energy providers, as the networks have overarching control. It also creates a
huge burden on the OEMs to provide and support this function over and above mechanisms
that could support better financial outcomes for the consumer.
Question 13 - What are costs and benefits for alternative applicable standards approaches and how does this impact networks, suppliers and consumers?
The real question is, what is the cost of developing and implementing alternative applicable
standards?
Australian CER already has one of the highest volumes of standards to which devices need to
comply. The benefits of alternative applicable standards are questionable without really being
able to understand what the benefits actually are. Currently, this question is based on theoretical
market mechanisms and packages from energy providers for interoperable mechanisms, which
simply do not exist.
There needs to be an analysis of actual viable products first, and after that, a cost-benefit
analysis based on the pathways for implantation.
The current situation, due to the monopolistic nature of the DNSP function, has already
mandated visibility and control over all primary CER devices. To now be able to implement
additional mechanisms will, by nature, be costly and have limited consumer benefit. Ideally, the
entire landscape and network business structure over CER needs to be reviewed to create a
more equitable outcome for consumers.
Question 14 - What are potential pathways to accelerate the standards development and modification processes?
There are none without creating unforeseen issues and putting a huge amount of pressure on
the OEMs to implement standards very quickly.
This question needs to be considered as part of the consultation on the National Technical
Regulatory Framework for CER.
Question 15 - The design of CSIP-AUS has 4 possible pathways (native, gateway, cloud, cloud/gateway).
Only the native pathway enables consumers to switch providers. Do you have views as to the merit of the alternative pathways for CSIP-AUS?
This question makes no sense.
September 2025 – Australia
Why is it assumed that gateway, cloud, and cloud/gateway do not enable consumers to switch
providers? This is factually incorrect.
The restriction on a consumer's ability to switch providers is normally due to contractual
restrictions, not technological ones.
If there ever is a restriction based on the gateway, cloud, or cloud/gateway, it will be due to the
fact that these mechanisms only have a single communication channel, which is used via CSIP-
AUS for DNSP utility server communication.
Any gateway, cloud, or cloud/gateway pathway that has multiple communication channels (as
most do), would have no restriction on a consumer being able to switch providers.
Question 16 - What are the benefits or disadvantages of facilitating control of a physical device or via the cloud?
This question also makes no sense.
Everything goes via the cloud apart from a DRM ripple control receiver, as has been imposed by
Energy Queensland for their Emergency Backstop Mechanism rollout, as this communication
pathway is via electrical wires.
Question 17 - What are the benefits and disadvantages of applying interoperability standards at a site versus a device level?
The disadvantages of applying interoperability standards at a site level are that, in most cases, a
separate HEMs device will be required to manage the coordination of devices. This not only
creates a single point of failure for the entire site, but it also adds complexity and cost for
installation and commissioning.
Many CER devices, such as the inverter, will already offer the equivalent of the HEMs function, so
this will alleviate the requirements for separate controllers.
Additionally, all CER devices should have fallback positions, so they should also have their own
corresponding communication and control standard, so if communication to the HEMs drops
out, they will still operate.
Ultimately, unless very crude relay-level control of CER, such as DRM, is implemented, all CER
devices will be required to have their own interoperability standard communication software
applied to be able to communicate with the controlling device.
September 2025 – Australia
Question 18 - What lessons can be drawn from the current approach to CSIP-AUS in terms of testability and conformance?
The lessons learned from the rollout of CSIP-AUS is that this is a perfect example of how the
implementation of a standard should not be done, for the following reasons:
• CSIP-AUS was introduced ahead of a final published standard
• There is no nationally consistent approach to the rollout
• Interpretation and implementation were given to the DNSPs, who have all created their
own requirements
• There is now a move to retrospective, to try to create a national alignment, which means
redoing all of the previous development and implementation work.
• CSIP-AUS has been developed by the networks for the networks with very little
consideration of consumer data rights or privacy.
• There are no safeguards around when or why CSIP-AUS should be used
• The cost for DNSP to develop and manage CSIP-AUS is paid for by the consumer
• The cost for an OEM to develop, manage and support CSIP-AUS is paid for by the OEM.
• The implementation of CSIP-AUS was rushed; in all jurisdictions, unrealistic timeframes
had to be extended
• There is no way to test the CSIP-AUS function until it goes live, which has caused huge
issues for the industry
• Cyber security provisions have not been included in CSIP-AUS, although the scale and
volume of CER under control by DNSPs create significant system security risks.
Question 19 - What are the net benefit and cost implications of adopting different standards pathways
(e.g. native vs adapter/HEMS-based)?
The question needs to be viewed from an outcomes-based approach.
The real question is what would different standards pathways (e.g. native vs adapter/HEMS-
based) offer consumers and CER devices compared to current pathways.
What is important to address is that the concept of interoperability is not new; this paper seems
to imply that this is a new model which is being proposed, and the applicable standards for
communication need to be contemplated. In reality, interoperability has been in place for years;
it is seen as a viable and beneficial outcome for consumers, OEMs, whether CER device or HEMs
providers already have solutions and products that meet most of the required scenarios.
Any net benefit is questionable at most; the cost implications of adopting different standards
pathways will be high, as there is very little need based on the current requirements within the
Australian industry.
September 2025 – Australia
Question 20 - What are the benefits and costs implications of requiring all EVSE (both uni-directional and bidirectional chargers) to support OCPP 2.0.1 and ISO 15118-20 to promote V2G use cases?
V2G will be a niche application for EVSE. It would be an unrealistic burden and cost on industry
to support OCPP 2.0.1 and ISO 15118-20 for unidirectional devices.
Thank you for the opportunity to provide input into the Consultation Paper.
If you would like to have any further information or would like clarification to any of the points raised, please contact me directly to discuss.
Yours sincerely,
James Sturch
Technical Director, International Markets
SolarEdge Technologies (Australia) PTY LTD.
Level 13, 222 Exhibition Street,
Melbourne
VIC 3000
Australia
