Submission to AEMC Unlocking CER benefits through flexible trading consultation paper Alternative formats available on request to PIAC - Contact PIAC
PIAC provided a response to the AEMC’s Unlocking CER (consumer energy resources) Benefits through Flexible Trading Consultation Paper (the Paper). The Paper sought feedback on a proposed rule change to “introduce flexible trading by enabling consumers to have their CER separately metered and therefore treated independently in market settlements, allowing consumers to engage with multiple service providers if they choose to.”
Our submission agreed that well- designed flexible trading provisions could help enable a more efficient energy system transition, contributing to improved coordination of consumer energy resources (CER) through the development of virtual power plants and materially reducing maximum demand and the need for new generation.
We highlighted that to realise this potential provisions for flexible trading must be predicated on the principle that flexible trading:
Is optional and ‘additional’, ensuring that consumers who do not participate are not disadvantaged and retain equitable access to efficient, dependable essential energy services.
Does not exclude or ‘lock out’ any consumer from participating because of complexity, limitations at their premises or the imposition of high upfront costs.
Has minimal impact on existing structures and systems, minimising additional complexity and cost impacts on ‘essential energy services’.
In response to the AEMC’s request for feedback on preferred models we strongly recommended a multi-element (or parallel), single-meter model be adopted. This approach best promotes the principles above, and is preferable to AEMO’s proposed ‘subtractive metering’ model.