Review of the System Restart Standard Draft Determination

AGL welcomes the Panel’s recent recommendations on system restart services, which present a forward-looking framework aligned with the evolving role of Essential System Services (ESS). The proposed dual-pathway model—featuring two-hour and eight-hour restoration options—offers flexibility to balance restoration speed, cost efficiency, and system resilience. This structure may also support broader participation, including from battery technologies.

AGL sees value in exploring emerging technologies such as grid-forming inverters and service stacking and notes that further clarity on their operational deployment would support informed investment and planning.

As competitive restart services continue to develop, AGL considers it important that the role of network operators is clearly defined to support transparency and effective market outcomes. Regulatory frameworks that encourage innovation and broaden participation will be key to delivering restart services efficiently and at lowest long-term cost to consumers.

With coal closures approaching, early planning is essential. AGL supports practical trials, clearer operational guidance, and broader technology consideration to ensure restart services remain fit-for-purpose in a high-renewables future.

Read the full submission (PDF)