The Western Australian Energy Transformation Taskforce is currently consulting on one aspect of its Distributed Energy Resources (DER) Roadmap, that sets out the WA Government’s forward vision for the integration of the DER into the WA market over the next five years.

The Issues Paper focused on DER orchestration roles and responsibilities and seeks industry feedback on a range of matters related to distribution market design, aggregation of DER, customer protections and a range of supplementary issues.

AGL supports the strategic vision for DER elaborated in the Taskforce’s DER Roadmap, where DER supports the broader electricity system and benefits all grid users.

In developing appropriate policy solutions to assist the energy market transition, we believe that industry and market participants should trial technologies and business models to then inform fact-based and ‘no regret’ changes to the energy market framework.

We strongly support the Project Symphony market trial proposed in WA that will provide a range of valuable insights to inform the development of requirements of aggregated DER integration into both the Wholesale Electricity Market and National Electricity Market. We also understand that AEMO is continuing to develop a range of other market trials, including the Victorian DER marketplace, that will provide a range of complementary insights to inform DER market design.

AGL considers some of the proposed changes in the Issues Paper to be premature without obtaining insights from these trials and risk creating additional barriers to DER integration and/or unintended consequences to market participants and end-user customers.

AGL recommends the following concepts be considered further:

  1. Opportunities to attract competitive retail aggregation that may deliver greater benefits to customers through visibility and applicable consumer protections.
  2. Facilitate battery investment incentives.
  3. Consider appropriate safeguards on the distribution system operator and distribution market operator functions to ensure they support the operation of a competitive market for DER services.
  4. The need for appropriate ring-fencing requirements to delineate the network and DSO functions from participation in the emerging market for DER services.
  5. The Project Symphony trial informs the regulatory framework.

A copy of our submission is available here.