The Australian Energy Market Operator (AEMO) is consulting on the content of initial minimum distributed energy resource (DER) technical standards.
This consultation is being run concurrently to AEMO’s rule change request to the Australian Energy Market Commission (AEMC) to establish a power for AEMO to set technical standards a well as Energy Security Board’s (ESB) broader review of the governance of DER technical standards.
The bi-directional nature of energy flows presents a new set of technical requirements that need to be considered in managing system security and reliability whilst also balancing the customer investment, value and participation of DERs.
We also consider that promoting interoperability through technical standards will be a key enabler for the effective use and optimisation of DER.
AGL believes the setting of technical standards arrangements should be carefully sequenced to ensure a fit-for-purpose decision-making process informs the development of any new technical standards as follows:
- The AEMC consider the ESB proposed governance arrangements for DER technical standards that will inform the role AEMO and other market participants have with respect to technical standards development.
- The AEMC consider AEMO’s proposal to establish minimum technical standards, having regard to any governance reforms.
- AEMO then consult on how they intend to apply any new arrangements, including the content of any minimum DER technical standards.
Given the need to accommodate this sequencing, we recommend AEMO defer its consultation until such time as these preceding reforms are concluded.
Should AEMO proceed with completing its consultation prior to the completion of the ESB and AEMC consultations, we recommend that in setting DER minimum technical standards AEMO adopt an open, transparent and fulsome review that includes an assessment of:
- Technical system security;
- Consumer impact of any proposed technical standards; and
- Cost implications of various elements of standards, including those relating to uniform power quality response modes and interoperability.
This assessment should be reviewed and approved by an appropriate independent modelling expert. In particular, we would not support AEMO’s proposed position to adopt the revised 4777.2 without conducting this assessment.
A copy of our submission is available here.