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11 September 2025
Mr Simon Duggan
Deputy Secretary, Energy Group
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
CANBERRA ACT 2601
Dear Mr Duggan
Technical Standards for Consumer Energy Resources Interoperability
Energex Limited (Energex) and Ergon Energy Corporation Limited (Ergon Energy
Network) welcome the opportunity to respond to the Department of Climate Change,
Energy, the Environment and Water (the Department) on the consultation on Technical
Standards for Consumer Energy Resources (CER) Interoperability.
As Distribution Network Service Providers, Energex and Ergon Energy Network are committed to supporting a secure, flexible, and consumer-focused energy system, and we recognise the critical role that interoperability plays in achieving this outcome. Our submission (provided in Attachment A) highlights key considerations for the development of a nationally consistent and future-ready interoperability framework. We support the
Department’s efforts to establish clear, practical standards that enable innovation, protect consumers, and ensure system-wide coordination.
In summary, Energex and Ergon Energy Network support:
Strong interoperability foundations for CER – Interoperability is essential to
enable consumer choice, support scalable integration of diverse technologies, and
ensure secure, coordinated operation across the energy system.
Leveraging and strengthening existing industry groups – Standards
development should build on the work of existing bodies such as Standards
Australia and international organisations, ensuring alignment while adapting to
local conditions.
Clear definition of interoperability layers – A structured approach is needed to
distinguish between site-level and device-level interoperability, with reference
architectures guiding the roles of Energy Management Systems, Resource
Managers, and external actors.
Collaborative industry engagement to accelerate standards development – A
flexible and well-resourced engagement process, combined with clear
implementation pathways and transition planning, will help ensure standards are
practical, testable, and widely adopted.
Ergon Energy Corporation Limited ABN 50 087 646 062
Energex Limited ABN 40 078 849 055
We appreciate the opportunity to contribute to this consultation and look forward to ongoing collaboration as the framework is refined.
Should the Department require additional information or wish to discuss any aspect of this submission, please contact either myself on 0429 394 855, or Charmain Martin on 0438
021 254.
Yours sincerely
Alena Chrismas
Manager Regulatory Affairs
Telephone: 0429 394 855
Email: alena.chrismas@energyq.com.au
2
Ergon Energy Corporation Limited ABN 50 087 646 062
Energex Limited ABN 40 078 849 055
ATTACHMENT A – ENERGEX AND ERGON ENERGY NETWORK SUBMISSION
NATIONAL CONSUMER ENERGY RESOURCES (CER) ROADMAP – TECHNICAL STANDARDS FOR CER
INTEROPERABILITY
Consultation question Energex and Ergon Energy Network response
Chapter 3 Background and context
General feedback The consultation paper does not clearly define what constitutes a CER device. A precise definition is
essential to ensure accurate interpretation of the requirements outlined in Chapter 5 and to enable
appropriate allocation across different types of CER devices. The examples provided, along with the
note at the bottom of the text box on page 11, suggest that the term “CER device” encompasses all
interoperable control devices located at a customer site. This includes the individual CER’s Resource
Manager (RM)1 as well as the site’s Electrical Energy Management System (EEMS). 2 For the purposes
of this response, it is assumed that this broader interpretation of “CER device” applies.
Question 1 - Should the capacity for Energex and Ergon Energy Network support the principle of consumer choice in selecting energy
consumers to switch energy service service providers and acknowledge the implementation of several rule changes aimed at enhancing
providers (churn) be prioritised and what consumer enablement and choice. However, it is important to recognise that this ability is not
are the impacts? universally available. For instance, customers within embedded networks may experience difficulties
in switching providers, and some regions may have limited or no access to competitive retail
offerings. While the ability to switch providers can significantly empower consumers, the broader
costs associated with prioritising this capability - particularly from an interoperability standpoint -
should be carefully weighed against the potential benefits.
1
Refer IEC 63402-1:2025.
2
Refer IEC60364-8-82:2022.
1
Consultation question Energex and Ergon Energy Network response
Chapter 4 Use Case mapping
Question 2 - What are your views on To ensure compliance with installation limits and circuit protection operation, Electric Vehicle Supply interoperability hierarchy via the vehicle Equipment (EVSE) limits must take precedence. With the introduction of dynamic operating and an EVSE? Do you think the EVSE envelopes (DOEs) and other local optimisation strategies, such as charging based on surplus solar should take precedence over the vehicle generation, these limits may vary over time. Within these dynamically adjusted bounds, the vehicle or vice versa? can initiate, pause, and modulate its charging rate. This behaviour is governed by relevant standards,
including IEC 61851 and ISO 15118.
Question 3 - Should minimum From a network management perspective, implementing controllable limits at 20A and above, offers device/system requirements be applied significant benefits, particularly in supporting the management of peak demand conditions. This to EV Level 1, Mode 1 and Mode 2 capability contributes to improved network efficiency and reliability, delivering value to all users.
charging technologies, as per discussion Consideration should be given to approaches adopted in other jurisdictions, such as the UK's smart in section 4.1? charging framework, which may offer useful insights for implementation and policy development.
It should be noted that 10A chargers that connect via standard general purpose outlets do not require
interoperability due to their limited impact on the power system.
Question 4 – Should minimum Minimum device and system requirements should be applied to public EVSE, with specifications device/system requirements be applied tailored to their operational context, business models, and network needs, particularly where to public EVSE? controllable or smart charging capabilities are involved. To ensure safe, secure, and reliable
operation across all public EVSE installations, baseline technical and cyber security standards
should be applied consistently.
2
Consultation question Energex and Ergon Energy Network response
Chapter 5 Requirements identification
Question 5 - Are there any CER device A set of generic requirement categories for intelligent devices and systems comprising orchestrated types or use cases not adequately intelligent devices has been evaluated to assess the completeness of CER device requirements. This captured in the 13 identified assessment assumes that CER devices include both EEMS and RMs, as outlined in the response to requirements? Question 1. The following list provides commentary on the requirements identified in the consultation
paper, as well as those that appear to be missing:
(1) Connect / Disconnect:
R-1: Assuming that a disconnect does not interrupt the communications to the CER device,
consider alternative word such as de-energise / re-energise to avoid confusion, and
Missing: A reconnect / re-energise capability should be explicitly incorporated to avoid
confusion.
(2) Device Configuration Management:
Includes Device Settings Management: R-5, R-6 and R-13. Device settings are not only used to
manage the device’s functional behaviour, but also for establishing the right communication
pathways and for cyber security (e.g. certificates).
Includes R-10. To maximise the value of a unique identifier (UID), it should be tied to the useful
life of the physical CER device from installation through to decommissioning. Maintaining a
consistent UID for the period the device is connected to the power system offers several key
benefits, including:
- Reduced data exchange and storage requirements: Because the UID remains unchanged,
there is no need for additional data transfer events or data storage. At the expected scale
of registered CER in the system, this translates to significant reductions in data volumes
and associated costs, and
3
Consultation question Energex and Ergon Energy Network response
- Improved traceability and system modelling: A consistent UID simplifies tracking of asset
performance and degradation over time. This supports more accurate forecasting and
lifecycle modelling, which is particularly valuable when aggregated CER behaviour may
impact local network areas or the broader energy system.
In conclusion, the proposed methods to tie the UID to a Media Access Control (MAC) address
or a certificate number are not recommended. A MAC address is tied to the useful life of the
communications module, which may fail while the CER device remains functional. Similarly,
cyber security certificates are designed to be updated regularly, making them unsuitable as an
identifier.
A more robust and practical alternative is to base the UID on the Manufacturer-Model-Serial
Number. This approach aligns with data held in the Distributed Energy Resources (DER)
Register and can be accessed using device level interoperability protocols such as Sunspec
Modbus and OCPP 2.x. This method supports long-term traceability, simplifies integration,
and enhances consistency across systems.
Missing: Device Firmware Management. Firmware management is highly important for
changes of device capabilities (including responses to faults) and cyber security
management. If missing, gaps in firmware management pose significant system and
reputational risks.
While firmware management may not require an interoperability standard and may remain
proprietary to the manufacturer, there are mandatory requirements that manufacturers must
meet to acquire accreditation. These include the ability to rapidly respond to discovered
firmware vulnerabilities by deploying a bulk update across the entire fleet of connected and
affected CER devices.
All access to CER device configuration should be subject to cyber security protections, which
are not currently mentioned under R-5.
4
Consultation question Energex and Ergon Energy Network response
(3) Device Telemetry Management:
Includes: R-4
Potentially missing: Depending on failure modes, it may be useful – or in some cases
necessary - to store a history of some or all telemetry data on the device. This would allow
retrieval in the event that the original transmission fails. While this requirement may be
partially addressed under the note on “device logging”, its scope and intent is not clearly
defined.
(4) Device (Site) Operations Management – applicable to RMs:
Includes: R-2 and a subset of R-3 (respond to limits or target signals received from EEMS).
(5) Device Communications Management:
Includes a subset of R-11, relating to establishing communications within a premises
Includes a subset of R-12, relating to communications with systems of other actors, such as
customer agents or Distribution System Operators (DSOs)
Potentially missing: Depending on interpretation, certain parameters critical to network
connectivity may not be explicitly addressed. These include IP addresses, links to third-party
services (e.g. supplier platforms), and other configuration elements that enable the CER
device to interface with external networks. While these may be assumed to fall under device
settings or R-12, clearer articulation of these requirements would strengthen the framework.
(6) Device Security Management:
Includes a subset of R-12, as relating to cyber security
Potentially missing: Additional cyber security requirements may apply to EEMS devices,
including mandatory or recommended features such as firewalls, intrusion detection, and
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Consultation question Energex and Ergon Energy Network response
alarm mechanisms to respond to abnormal signals (e.g. denial of service attacks). These
enhanced capabilities are critical for maintaining system integrity and should be defined by
the relevant working groups, as outlined in Table 1 of Section 2.2.
Question 6 - Are there any other Existing standards that could be further leveraged or expanded include: standards that can support each
IEEE 2030.5 / AS 5385, which is already adopted in Australia and supports several requirements, identified requirement?
including trusted communications, modulation of power, and remote control. However, it could
be expanded to better support switching providers (R-9) and local CER coordination (R-11),
particularly under native configurations
IEC 61968-9 and IEC 61970, which are data model standards that support grid-relevant device
settings and telemetry. These standards could be extended to support site-level monitoring (R-8)
and default settings (R-13)
ISO 15118, especially ISO 15118-20, which supports communication between electric vehicles
and EVSE, including vehicle-to-grid (V2G) capabilities. This standard could be mapped more
explicitly to support remote updating of device settings (R-6) and switching providers (R-9)
OCPP 2.0.1 / IEC 63584 which supports communication and management of EVSE. It could be
extended to support the remote provision of price signals (R-7) and telemetry (R-4) for both EVSE
and electric vehicles, and
AS/NZS 4777.2 which is a performance standard for inverters. It could be enhanced to support
improved default settings (R-13).
Question 7 - In the mapping exercise in It is noted that AS 5385, which is an identical adoption of IEEE 2030.5-2018, is primarily designed for
Table 5.14, do you agree with the device-level or premises-level communication and control of CER. Therefore, further consideration is identified gaps? Are there existing needed regarding how distribution network operators and aggregators can coordinate and control standards that could fill these identified CER across multiple premises and broader geographical areas.
gaps?
6
Consultation question Energex and Ergon Energy Network response
While SA TS 5573:2025 is referenced, it currently lacks sufficient guidance and mechanisms to
support key functions such as grouping CER assets across different premises, issuing control signals
to CER groups for aggregated response, and managing data flow and validation for multi-premises
aggregation. The absence of these capabilities risks inconsistent implementation across aggregators,
which may impact provider churn flexibility and limit the effective use of CER in delivering grid
services.
It is recommended that future updates to SA TS 5573 incorporate frameworks to support aggregated
CER services, as this would significantly enhance capabilities for CER grouping, interoperability, and
coordinated grid support.
Question 8 - Do you have views on the Accurate measurement and verification of CER response, whether at the individual device level or in prioritisation of further standards work to aggregate, is a foundational requirement for enabling effective CER services. Achieving this requires a address the identified gaps? balanced approach that considers the cost and complexity of data acquisition, transfer and storage,
while ensuring sufficient detail to support operational and regulatory needs.
Device-level telemetry (R-4) is expected to impose a significant cost burden, whereas site-level
telemetry (R-8) presents a more moderate impact. This is particularly relevant when integrating
multiple CER and non-CER assets (e.g. air-conditioning or cooking loads) at a single premises, where
site-level data is likely to provide adequate granularity for network and operator purposes.
Clear guidance is needed in the development of measurement and verification plans and
frameworks to ensure consistency across networks, operators, and customers.
Question 9 - How can Australia align with Work is already underway to adopt or align with several international standards, with Standards international standards while Australia engaging with international standards bodies to adapt standards where possible. Continued maintaining flexibility for local investment in and support for standards bodies will help bridge global standards with local conditions? requirements, supporting consumer choice and scalable CER deployment across jurisdictions.
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Consultation question Energex and Ergon Energy Network response
Question 10 - Are there any risks The increasing digital connectivity of CER devices, along with remote configuration capabilities and associated with the identified evolving functional requirements, introduces a range of cyber security, operational, and privacy requirements, such as remote updating risks. These risks must be carefully assessed and mitigated to safeguard the integrity and resilience of of device settings? the power system. Key risks include:
(1) Cyber security Breach and Unauthorised Access - remote update mechanisms present
vulnerabilities that may be exploited for unauthorised access. Such breaches could allow
attackers to alter device settings, compromise system integrity, or disrupt grid operations. A
successful attack on centralised platforms, such as those operated by DSOs or Customer Agents,
could result in widespread disconnections or operational failures across the network. Even
localised attacks targeting individual CER systems may lead to financial loss, compromised
safety, or service disruption for asset owners.
(2) Propagation of Erroneous Settings - misconfigurations, whether caused by human error, software
defects or malicious interference, can rapidly propagate across fleets of devices. This risk is
particularly critical when vulnerabilities affect devices from a single vendor, potentially impacting
entire network areas or the broader power system. Such misconfigurations can lead to instability
in voltage or frequency, resulting in widespread maloperation and compromising system
reliability.
(3) Loss of Situational Awareness - inadequate logging, monitoring, or validation of remote updates
can leave operators unaware of critical changes. This lack of visibility undermines operational
control and response capabilities, increasing the risk of cascading failures.
(4) Operational Downtime and Recovery Costs- remediation of widespread misconfigurations is often
time-consuming and costly. It may require manual rollback procedures, temporary shutdowns of
affected assets, and extensive coordination among stakeholders.
(5) Privacy Risks - unauthorised access to telemetry data can lead to privacy violations for individual
CER owners. Such data may reveal sensitive information about asset usage, personal habits, or
occupancy status, raising concerns about surveillance and data protection.
8
Consultation question Energex and Ergon Energy Network response
(6) Disconnect Functionality Risks - the ability to remotely disconnect CER devices introduces a
critical vulnerability. If compromised, this functionality could be exploited to cause large-scale
outages or targeted disruptions, with significant implications for grid stability and customer trust.
A comprehensive risk and failure mode assessment of the proposed architecture is essential. This
should include:
Implementation of robust cyber security controls
Validation and rollback mechanisms for remote updates
Continuous monitoring and logging of device changes
Privacy safeguards for telemetry data
Response and continuity planning for large-scale incidents, and
Security of Critical Infrastructure obligations, particularly for risks with system-wide
implications.
Question 11 - Modulating power in Energex’s and Ergon Energy Network’s preferred approach for sending external signals is to modulate response to grid conditions or an power flows at the connection point using a fixed export limit or DOE. This method provides greater external signal can be implemented flexibility and agency for customers, enabling them to manage their energy use during network through zero generation or zero export. Is constraints while maintaining self-consumption.
there a preference for either of these
In contrast, autonomous responses to grid conditions (as per AS/NZS 4777.2), are best managed by approaches or both?
individual CER devices. This approach minimises latency of response and reduces reliance on
communication links.
Ideally, responses should follow a tiered structure:
First, curtailment to zero export during moderate network constraints, and
Then, if conditions become critical, curtailment to zero generation.
This layered response strategy supports both system stability and customer participation.
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Consultation question Energex and Ergon Energy Network response
Question 12 - What are the risks of There is a potential risk of supplier lock-in where CER devices are tightly integrated with proprietary supplier (OEM) lock-in under current platforms or communication protocols. This can limit the customer’s ability to switch service standards, and how might these be providers, thereby restricting competition, stifling innovation, and undermining consumer choice and mitigated? protections.
Key risks include:
Proprietary interfaces that prevent interoperability with other service providers
Lack of standardised provisioning mechanisms for switching providers, and
Closed ecosystems where device functionality is tied to a specific vendor’s platform.
Mitigation strategies include:
Mandating the use of open, standardised communication protocols (e.g. IEEE 2030.5, CSIP-
AUS)
Defining interoperability requirements in implementation guides and standards (e.g. HB 218)
Enabling consumer-initiated switching mechanisms through device management systems,
and
Requiring data portability and re-provisioning support to facilitate seamless transitions
between providers.
Question 13 - What are costs and Selecting appropriate standards requires balancing ease of implementation, cost, range of benefits for alternative applicable applicability, and potential penetration. Adopting standards without international alignment is rarely a standards approaches and how does this prudent choice given the size of Australia’s market, as it may increase costs or discourage supplier impact networks, suppliers and participation. Therefore, to ensure positive outcomes for consumers, any standards adoption should consumers? be subject to a robust assessment process.
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Consultation question Energex and Ergon Energy Network response
Chapter 7 Industry response to interoperability
Question 14 - What are potential Standards development requires careful consideration to ensure outcomes are appropriate for pathways to accelerate the standards Australian consumers, which drives some of the time required to develop and review. At the same development and modification time, consideration should be given to a more flexible and responsive public engagement process, as processes? existing public engagement periods for standards are typically quite short. Increased access to
resources may assist in accelerating development.
Importantly, standards development is only one part of the broader modification process.
Implementation and transition planning are also critical, allowing time for Original Equipment
Manufacturers (OEMs), testing and listing agencies, installers, suppliers, and networks to outwork any
changes introduced through standards changes.
Question 15 - The design of CSIP-AUS Referring to Figure 3 in section 7.1.4, which outlines four potential pathways, it is important to note has 4 possible pathways (native, that these do not represent the only possible future-state architecture options. Aggregators are not gateway, cloud, cloud/gateway). Only the only actors capable of deploying applications on cloud platforms. Utility servers and gateway the native pathway enables consumers applications could technically also be deployed on cloud platforms. Therefore, the focus should be to switch providers. Do you have views on identifying which actor communicates directly with the on-premises CER installation, rather than as to the merit of the alternative the hosting platform of a particular application.
pathways for CSIP-AUS?
Standardisation of CER device capabilities and interoperability across all actors is critical. It will
support customer flexibility and choice of providers, reduce overall system architecture complexity
and costs and enable continuity mechanisms for CER integration in the event of prolonged aggregator
system outages. Furthermore, it will facilitate alternative access models - such as direct control by a
DSO or customer agent - which may be necessary during emergency situations, as opposed to normal
operations.
It is recommended that a digital enterprise architecture approach and associated skillsets be applied
in the design of reference architecture(s).
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Consultation question Energex and Ergon Energy Network response
Question 16 - What are the benefits or Refer to the response to Question 15. If this question is intended to compare the “gateway” option disadvantages of facilitating control of a with the “aggregator cloud” option, it is important to note that international standards already exist to physical device or via the cloud? support interoperable control of physical CER devices by a local EEMS or gateway. In contrast, cloud
intermediation may not yet readily support the same level of interoperability.
Question 17 - What are the benefits and Interoperability at both the site and device levels is complimentary and essential for effective CER disadvantages of applying integration. As referenced in IEC 63402-1, these interfaces are defined as S0 and S2 – where S0 interoperability standards at a site versus represents the link between the DSO and the premises, and S2 represents the link between the EEMS a device level? and individual CER device RMs.
Site-level signals may be difficult to follow on sites with multiple CER devices from different vendors
unless device level interoperability is in place. Currently, this depends on manual integration between
an EEMS and each supported CER device.
Question 18 - What lessons can be The current approach to CSIP-AUS highlights several important lessons regarding testability and drawn from the current approach to conformance. One key insight is the need for clearly defined implementation pathways and testing
CSIP-AUS in terms of testability and procedures to ensure consistent application across jurisdictions and device types. The evolution from conformance? SA HB 218:2023 to SA TS 5573:2025 demonstrates the value of formalising guidance into a technical
specification that includes structured test procedures for both client and utility servers.
However, challenges remain, particularly with configurations such as gateway and aggregator cloud
pathways, where communication between the cloud and end devices is not standardised, making
end-to-end testing difficult and potentially limiting consumer choice. The lack of minimum
performance requirements for clients has also led to inconsistent integration experiences for
manufacturers.
These issues underscore the importance of developing comprehensive conformance frameworks,
including standardised testing protocols, certification processes, and clear definitions of
communication pathways. By addressing these gaps, future iterations of CSIP-AUS can better
support interoperability, consumer switching, and scalable deployment of CER technologies.
12
Consultation question Energex and Ergon Energy Network response
Question 19 - What are the net benefit We recognise that long-term, a home energy management system (HEMS) may be the most viable and cost implications of adopting solution, particularly for customers with diverse CER from multiple OEMs. However, it’s important not different standards pathways (e.g. native to exclude customers who are fully invested in a single OEM ecosystem from participating without vs adapter/HEMS-based)? requiring additional hardware.
Cloud-based platforms offer a practical transition pathway for customers with existing hardware,
helping to avoid the high upfront costs of purchasing a HEMS.
In the short term, offering multiple integration options supports flexibility and consumer choice, while
the overarching goal remains to avoid poor customer outcomes and ensure equitable access to DOE
participation.
Question 20 - What are the benefits and It is unclear how requiring unidirectional EVSE to support a particular protocol would enable V2G costs implications of requiring all EVSE integration. However, ensuring all EVSE are controllable via network or other signals can help manage
(both uni-directional and bidirectional charging loads and reduce impacts on the grid during peak periods. There is merit in simplifying chargers) to support OCPP 2.0.1 and ISO coordination across all EVSE, whether in a charge or discharge (vehicle-to-building or V2G) state, to
15118-20 to promote V2G use cases? reduce negative grid impacts and to enable market participation.
Implementing such requirements would involve some costs, particularly in ensuring new devices are
compliant. However, this could be mitigated through alignment with international standards.
Transitional arrangements would also need to be considered.
13
Upload a submission
11 September 2025
Mr Simon Duggan
Deputy Secretary, Energy Group
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
CANBERRA ACT 2601
Dear Mr Duggan
National Technical Regulatory Framework for Consumer Energy Resources – Draft
Prototype
Energex Limited (Energex) and Ergon Energy Corporation Limited (Ergon Energy
Network), as distribution network service providers (DNSPs) operating in Queensland, welcome the opportunity to respond to the Department of Climate Change, Energy, the
Environment and Water (the Department) on the consultation on the draft prototype for the
National Technical Regulatory Framework for Consumer Energy Resources (CER).
We appreciate the opportunity to contribute to this important consultation and commend the Department’s efforts to develop a coherent and future-focused regulatory framework.
Our submission (provided in Attachment A) highlights key considerations to ensure the framework is technically robust, consumer-centric, and aligned with broader energy system reforms.
In summary, Energex and Ergon Energy Network support:
Establishing a unified national approach – A consistent national framework for
CER technical regulation is essential to streamline compliance, reduce duplication,
and enable scalable integration, with flexibility retained for jurisdictional nuances
where justified.
Strengthening long-term accountability – The proposed regulatory functions
must be expanded to include mechanisms for ongoing device conformance,
especially considering risks such as firmware updates and vendor exits, to
safeguard consumers and system reliability.
Prioritising interoperability and system resilience – Early inclusion of
interoperability and cyber security standards is critical to avoid fragmented
implementations and ensure that CER devices can operate securely and
cohesively within the broader energy system.
Designing regulation that is practical and consumer-aware – Regulatory
settings should be practical and minimise burden by aligning with existing licensing
frameworks, accreditation schemes, and leveraging digital tools to support
installers and consumers.
Ergon Energy Corporation Limited ABN 50 087 646 062
Energex Limited ABN 40 078 849 055
Leveraging existing initiatives with strong governance – While industry-led
projects are developing technical standards, these efforts must be coordinated
under a national body with appropriate authority. Developing standards outside the
formal Standards Australia process can offer flexibility, but only with genuine
cross-jurisdictional engagement and transparent consultation. Without this, there is
a risk of fragmented outcomes and inconsistent implementation.
Designing technical standards for safe, secure and economic system
operation – A National CER Technical Code must balance safety, security, and
economic efficiency across the energy system. Risk-based technical decisions
should be guided by stakeholders with appropriate expertise and responsibilities to
ensure robust and reliable outcomes.
Energex and Ergon Energy Network welcome further engagement as the framework evolves and would be pleased to participate in any future discussions or working groups.
Should the Department require additional information or wish to discuss any aspect of this submission, please contact either myself on 0429 394 855, or Charmain Martin on 0438
021 254.
Yours sincerely
Alena Chrismas
Manager Regulatory Affairs
Telephone: 0429 394 855
Email: alena.chrismas@energyq.com.au
2
Ergon Energy Corporation Limited ABN 50 087 646 062
Energex Limited ABN 40 078 849 055
ATTACHMENT A – ENERGEX AND ERGON ENERGY NETWORK SUBMISSION
NATIONAL CONSUMER ENERGY RESOURCES (CER) ROADMAP – NATIONAL TECHNICAL
FRAMEWORK – DRAFT PROTOTYPE
Consultation question Energex and Ergon Energy Network response
Do the system outcomes capture what is needed for The four objectives outlined in Section 1.1 of the consultation paper do not appear to the CER system to function? directly cascade from the National CER Roadmap, although there is a reasonable basis
to infer alignment. These objectives extend beyond the immediate scope of the
proposed regulatory framework for CER devices and connections. To ensure coherence
across reform efforts, it is important that all power system and market initiatives are
guided by a consistent set of overarching objectives.
Likewise, the system outcomes derived from these objectives, as presented in Section
1.2, are broad in nature and should ideally be endorsed at the same level as the system
objectives themselves. While the proposed technical regulator would play a key role in
supporting these outcomes, compliance with CER device and connection standards
alone will not be sufficient to realise them. For example, the attractiveness of CER
investment for consumers and businesses is shaped by a range of factors beyond
technical regulation, including the financial incentives available through engagement
with customer agents.
There also appears to be an implicit assumption that a significant volume of CER will be
available for orchestration and coordination, thereby contributing substantial aggregate
generation capacity or flexible demand. However, this outcome is contingent on
consumer sentiment, trust, and appetite. Many consumers invest in CER primarily to
achieve energy independence, maintaining a grid connection solely for reliability
purposes.
1
Consultation question Energex and Ergon Energy Network response
Compounding this challenge is the fact that a large amount of rooftop solar PV
(representing the highest penetration globally) has already been installed without the
technical capability for orchestration. Similarly, batteries are being connected at a rapid
pace, frequently without the necessary functionality or contractual frameworks to
support coordinated operation. These trends suggest that assuming widespread
orchestration readiness may overlook significant structural and behavioural barriers.
The scope and oversight of the technical regulator, as well as broader decisions
regarding the redesign of the energy system, market and network, will vary significantly
depending on the future role of distributed CER. If CER becomes integral to Australia’s
energy security, this will elevate requirements around asset integrity and introduce
stronger security of critical infrastructure obligations. Conversely, if CER remains
primarily a tool for individual energy independence, the regulatory and system design
implications will be markedly different.
Are the current challenges, examples and impacts The technical challenges identified in the consultation paper are broadly appropriate comprehensive? Is a National CER Technical and reflect key considerations for the sector. However, Energex and Ergon Energy
Regulatory Framework the best mechanism to resolve Network note that some of the examples and associated impacts presented do not fully these? align with current practice. For example, customer’s battery installations are generally
consistent with existing technical requirements. Australian Standards for both
installation and performance are well-established and referenced by distribution
network service providers (DNSPs) in their connection standards. In addition, DNSPs
such as Energex and Ergon Energy Network, along with most others, rely on the Clean
Energy Council product list to guide compliance.
As highlighted in our response to the Redefining roles and responsibilities for power
system and market operations in a high CER future (M3/P5) consultation, any proposed
technical regulator must also have oversight of CER system conformance and
compliance from both a security and market perspective. While the consultation paper
focuses primarily on device-level and installation compliance, it is important to
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Consultation question Energex and Ergon Energy Network response
recognise that devices such as inverters are highly configurable, particularly in terms of
logic and control settings. These configurations can significantly influence system
behaviour and performance.
Therefore, it is critical to consider which responsibilities for system security may
appropriately sit with the Australian Energy Market Operator (AEMO), and how these
would interact with the responsibilities of the proposed technical regulator. A clear
delineation of roles is necessary to ensure that system-level outcomes are achieved
without duplicating effort or creating regulatory gaps.
Are the five regulatory functions the appropriate From a DNSP perspective, Energex and Ergon Energy Network are supportive of a priorities for the National CER Technical Regulatory National CER Technical Code. However, it is important to acknowledge that the Energy
Framework? Networks Australia (ENA) Technical Guidelines already exist to promote harmonisation
across DNSPs. DNSPs also contribute significantly to the development of standards
such as AS4777, which underpin consistent network requirements nationally.
Furthermore, DNSPs have historically led the development of connection standards,
balancing innovation with the need to maintain network safety and security.
It is therefore critical that any new technical code does not hinder innovation or restrict
the ability of DNSPs to adapt to emerging technologies. Clear articulation of state-based
jurisdictional considerations within the National CER Technical Code is essential,
similar to the approach taken in the National Construction Code. Another option could
involve the regulator publishing high-level or model standards, which DNSPs could
adopt or justify deviations from. Alternatively, DNSPs or a coordinating body such as the
ENA could be tasked with aligning these standards in parallel with the development of
the National CER Technical Code.
The proposed functions 1, 2, 3 and 4 are appropriate for a framework focused on
technical device and connection compliance. However, function 3 “Mandatory installer
accreditation and accountability” requires further consideration regarding mechanisms
for addressing repeat non-conformance and ensuring accountability.
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Consultation question Energex and Ergon Energy Network response
Function 5 “Support CER System Integrity” includes a sub-function for “Monitoring and
reporting on system integrity and progress against performance indicators for system
outcomes”. This responsibility extends beyond the scope of a CER technical regulator
focused on device and connection compliance. As such, the sub-function should be
reframed as “Monitoring and reporting of CER device and connection conformance
against performance indicators for system outcomes”.
What are the barriers to implementing the proposed Key barriers to implementing the proposed regulatory functions include differences in regulatory functions? What opportunities are there to jurisdictional regulations, limited data visibility, underdeveloped compliance and leverage existing approaches? enforcement mechanisms, and challenges in workforce readiness and legacy device
management.
Compliance with technical performance requirements is multi-faceted. Existing
schemes, such as the Clean Energy Council’s product accreditation program and the
Solar Accreditation Australia installer program, can be leveraged to support device
compliance. There is also scope to enhance device registers, for example the AEMO
Distributed Energy Resources Register requirements have not been updated since 2019,
presenting an opportunity for improvement.
At the same time, broader community engagement is required. Devices like inverters
have numerous settings that, if altered, may impact technical compliance. Any
enforcement entity will not only require cost-effective investigation tools to identify non-
compliance, but also appropriate levers to incentivise ongoing compliance or apply
penalties if appropriate.
Given the growing contribution of CER to the overall power system, it may be appropriate
to consider cost-benefit analysis at a system-wide level to ensure regulatory efforts are
proportionate and effective.
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Consultation question Energex and Ergon Energy Network response
What work is underway which might interact with the It is important to recognise that the development of harmonised technical standards or proposed regulatory functions? How could these codes is only one component of successful implementation. Equally critical are industry interactions be managed? engagement and the provision of comprehensive training packages for installers and
other stakeholders. These elements ensure that changes are understood, adopted, and
effectively applied in practice.
Furthermore, the consultation paper does not appear to consider the social licence
implications associated with changing technical requirements. Any shift in technical
requirements must be accompanied by transparent communication, stakeholder buy-
in, and a clear understanding of the impacts on industry participants and consumers.
Without this, implementation risks resistance or misalignment with broader energy
transition goals.
How do we ensure regulator decisions are consumer To ensure decision-making remains genuinely consumer-centric, three key factors must centric? be prioritised:
(1) Safety of individuals
(2) Security of the electricity system, and
(3) Regulatory impact on cost of living.
These priorities should be embedded within the regulator’s legislated charter,
potentially supported by corresponding reporting obligations. The regulator can then
apply best-practice engagement approaches to meet its consumer-centric mandate,
recognising that such approaches may evolve over time.
In addition, the regulator will be bound by the consumer protections developed under
the Consumer Workstream. These protections must reflect the scope and potential
impacts of the regulator’s decisions and be designed accordingly to safeguard
consumer interests.
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Consultation question Energex and Ergon Energy Network response
Clarity is also needed regarding the organisational allocation and proposed operating
model for the regulator. This is essential to understand the skillsets available and any
limitations in scope. Not all entities will be equipped to deliver all functions, and their
physical footprint and operational capacity will vary.
Finally, if CER is expected to contribute up to 40 per cent of the future power system, it is
critical that its regulation aligns with the frameworks applied to other significant forms of
generation. Those responsible for system operation must have a clear and consistent
understanding of CER compliance status to ensure system reliability and integrity.
Is the suggested compliance and enforcement The compliance and enforcement framework outlined in the consultation paper requires approach appropriate and achievable? further development, particularly in clarifying enforcement mechanisms and assigning
responsibility for enforcement activities. While a robust approach is achievable, it will
depend on the responsible entity receiving adequate funding to meet its obligations.
Additionally, the framework must ensure that the costs associated with compliance and
enforcement are equitably distributed - specifically among consumers who benefit from
CER - rather than being universally applied across all consumers.
With respect to accreditation of CER Devices, Energex and Ergon Energy Network
provide the following comments:
To improve efficiency, the framework should incorporate digital capabilities that
enable a high degree of automation in compliance management. This includes:
- Advanced information management systems
- AI supported assessment pathways, and
- Automated testbeds integrated with grid simulators, aligned with the
standards prescribed by the National CER Technical Code.
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Consultation question Energex and Ergon Energy Network response
Firmware updates present a significant risk to ongoing device conformance. A
firmware change can result in widespread non-compliance across a device
model, as seen in analogous incidents such as the 2024 CrowdStrike-related IT
outages or the 2010 Toyota Prius safety recall due to firmware related braking
issues. For widely deployed CER devices, this could lead to large-scale non-
conformance in a short timeframe. The compliance framework must therefore
include mechanisms to assess and maintain ongoing conformance following
firmware updates. Notably, while the current proposal addresses firmware
updates under connection conformance, firmware is fundamentally a device
conformance issue.
We support the prioritisation of international standards within the draft
framework. Further consideration should be given to aligning with existing
accreditation schemes in major global markets. This would facilitate the entry of
high-quality CER devices into the Australian market by enabling economies of
scale for original equipment manufacturers (OEMs).
With respect to accreditation of CER connection conformance, we are of the view that:
The sampling approach proposed in Section 1.12 could be expanded into a more
comprehensive and largely automated connection auditing capability. This
would enhance oversight while reducing manual burden, and
To minimise reporting obligations for actors who may alter device settings,
including consumers themselves, it may be beneficial to implement automated
notifications to the regulator when settings are changed. This has implications
for interoperability and device standards, and given the anticipated scale of CER
deployment, any solution must carefully consider the cost and scalability of data
transfer and storage.
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Consultation question Energex and Ergon Energy Network response
How do we maintain effective regulation while Each DNSP has distinct service and installation requirements, which highlights the need minimising regulatory burden for installers? for more tailored, state-based continuing professional development (CPD) to reflect
jurisdictional differences.
To support the proposed requirement for DNSPs to verify installer accreditation at the
point of connection, installer accreditation datasets should be provided to DNSPs at no
cost. Ensuring DNSPs have access to accreditation data will enable them to fulfil their
obligations efficiently and reduce the administrative burden, including for installers.
Electrical licence holders across many Australian jurisdictions are already subject to
licence renewal and CPD obligations. There is a clear opportunity to align CER-related
requirements with existing electrical licensing frameworks. Doing so would reduce
duplication and minimise the regulatory burden on installers, while maintaining high
standards of safety and performance.
Are these appropriate options for conformance Ongoing conformance of CER devices is a shared responsibility across OEMs, DNSPs, management? Should others be considered? and installers. However, it is essential that customers are also kept informed and
When/what are the triggers? empowered. Ultimately, the customer holds the connection contract with the DNSP, yet
most rely entirely on the installer to ensure technical compliance. This relationship must
be placed at the centre of any conformance management framework.
A long-term strategy is needed to address scenarios such as installers or suppliers
exiting the market, and to manage the potential impacts of firmware updates on device
conformance. These considerations are critical to maintaining system integrity and
consumer trust over time.
Further clarity is also required regarding enforcement models and the powers of the
proposed regulator. This includes whether enforcement would leverage existing
jurisdictional instruments, such as the Electricity Act 1994 (Qld), or require new
legislative mechanisms. A well-defined enforcement framework will be essential to
support effective compliance and uphold consumer protections.
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Consultation question Energex and Ergon Energy Network response
How will the Framework practically work, particularly It is expected that the framework will operate by establishing clear technical in its interactions with those who currently have a requirements through a National CER Technical Code, with defined responsibilities for degree of control over aspects of CER within the various parties, as follows: system? An OEM has product requirements, how does
DNSPs would align their connection standards and connection offer conditions a DNSP/aggregator have to fit in with those
with the requirements set out in the code requirements? e.g. VPPs currently have no regulation.
OEMs would need to ensure that devices are demonstrated to comply with the
required technical standards to achieve accreditation
Installers would be responsible for ensuring that installations comply with the
code’s requirements, and
Customer agents (including aggregators, VPP operators, energy service
providers) would be expected to comply with relevant technical requirements
and consumer protections under the code and would hold obligations to
maintain connection and conformance for the CER devices they manage.
How do you reflect the priorities? What parts of the Clear definition of the basic functional requirements for CER devices is essential to
Code need to be tackled immediately ahead of the support non-market orchestration mechanisms, particularly dynamic operating
Regulator commencing. What other envelopes (DOEs) and system emergency response functions such as standards/requirements could/should be tackled disconnect/reconnect and backstop controls. These functions should be prioritised for immediately? standardisation, as current implementation across the National Electricity Market is
highly variable. The absence of consistent guidance creates ongoing investment
uncertainty for key actors such as DNSPs and risks entrenching divergent approaches
that may lead to significant sunk costs and expensive retrofits in the future.
A prudent first step would be to establish a clearly defined layered digital architecture
for the energy system, alongside a taxonomy of logical CER device types - independent
of their physical implementation. For example, a site’s energy management system may
be embedded within an inverter, integrated into a battery energy storage system, or exist
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Consultation question Energex and Ergon Energy Network response
as a standalone unit. Determining which functions should, and should not, be
performed by logical CER devices within the scope of the National CER Technical Code
is critical.
To support this, existing international frameworks should be consulted to ensure
functional and interoperability decoupling of CER devices. For example, the GridWise
Interoperability Context-Setting Framework which provides a structured approach to
system architecture and interoperability, and IEC 63402-1:2025.
How do we identify and prioritise the work program for A system-wide digital architecture oversight and roadmap is essential to effectively requirements? guide the work program of any regulatory body focused on CER device requirements, as
well as other entities responsible for defining components of the broader digital energy
system. This approach is consistent with best practice in the delivery of large-scale
digital and infrastructure programs.
The regulatory workplan for CER device requirements must be driven by the functional
needs of CER devices, which in turn are shaped by the capability roadmap for the overall
system architecture. Without this alignment, regulatory efforts risk being fragmented or
misdirected.
That said, as outlined in the previous response, there are already several clear “no-
regret” areas of work that can be progressed immediately. Existing international
frameworks can be used to validate these priorities and help identify additional areas for
early action.
What happens when things go wrong? What are the Organisations have long managed vendor-related risks in their ICT investments, ongoing roles and responsibilities? e.g. a particularly those with long lifecycles (10+ years). In the context of privately owned CER manufacturer folds or withdraws from the market, who devices, it is essential that similar risk considerations are embedded not only within the is responsible for software updates, any remaining regulatory framework but also within the design of consumer protections for CER warranty, etc. owners.
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Consultation question Energex and Ergon Energy Network response
Risk mitigation should begin at the strategic planning and device certification stage, not
only after an issue arises. The framework must proactively incorporate strategies to
manage vendor-related risks. These could include:
Consumer and installer education on vendor-related risks and long-term device
support
Assessment of vendor viability at market entry as part of the initial device
accreditation process
Minimum support obligations for OEMs, ensuring they cannot exit the Australian
market without provisions for continued support of deployed CER devices over a
reasonable lifespan
Ongoing monitoring of vendor viability and accredited product roadmaps,
enabling early detection of risks and timely withdrawal of accreditation if
necessary
Tracking vendors’ market penetration to assess the potential scale of system or
localised risk
Promoting diversity in the OEM market and installed CER fleet as a safeguard
against systemic risk from over-reliance on a small number of vendors
Providing transparent information to consumers and installers about vendor
viability and device reliability to support informed purchasing decisions
Considering property churn, ensuring protections and responsibilities are clear
when ownership of CER assets changes over time, and
Clearly defining upfront the mechanisms and levels of intervention available
from power system and cyber security perspectives, ensuring stakeholders
understand how and when these protections will be activated in response to
vendor-related risks or device vulnerabilities.
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Consultation question Energex and Ergon Energy Network response
What consideration should the framework make, if Demand flexibility and generation flexibility are fundamentally interconnected and both any, of demand shifting devices such as smart pool are essential for maintaining system stability. As such, any regulatory framework should pumps and controlled load hot water systems? Should encompass both aspects to ensure a balanced and resilient energy system.
they be addressed, or should the regulator only cover
CER that can add power to the grid?
What about other associated elements such as smart Smart meter standards are already established through existing Metrology Procedures.
meters? Should national regulation determine As a key digital building block within the broader energy system architecture, smart required minimum standards for smart meters, taking meter requirements must be designed to support and enable overall system outcomes.
into account consumer benefit and desired system Their role in data collection, interoperability, and system visibility makes them integral to outcomes? the success of a coordinated and digitally enabled energy future.
One of the key methods of managing CER interaction The regulation of DOEs can be interpreted broadly, encompassing multiple aspects of with the grid is the use of dynamic operating their implementation and operation. A key component is the methodology used to envelopes (DOEs). DOEs provide upper and lower calculate dynamic limits, which should be aligned with guidance provided by the bounds on the maximum and minimum flow of power Australian Energy Regulator. Additionally, DNSP investments in systems to support DOE through a given point within an electricity distribution functionality fall within the scope of the existing regulatory framework.
network during a particular time interval for CER
The communication infrastructure that facilitates message exchange between DNSP device(s). Where do you think the responsibility for
utility servers and customer premises could be regulated in the same way as other regulating DOEs should sit? (And why?)
technical standards. This would ensure consistency and reliability across the system.
Furthermore, third-party actors, such as customer agents, could leverage these
technical standards to support their services. In doing so, they should be subject to
consumer protection obligations similar to those applied to energy retailers, ensuring
customer interests are safeguarded.
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