Creating an Energy Data Strategy – AGL responds to Energy Security Board

The Energy Security Board (ESB) recently consulted on their proposed Data Strategy. The Data Strategy includes 32 recommendations across four pillars as depicted below:

Any Strategy is only effective as the foundations that it is built on and the key to a strong foundation is to set clear objectives on why the data is needed. This in turn is underpinned by clearly defined role(s) for the agencies. Role clarity for agencies makes it easier to determine what data the agency needs and what capabilities and systems are required to support its role(s). Finally, once all these factors are known, you can assess what data, processes and arrangements currently exist to support the Strategy.

The proposed ESB Data Strategy appears to start the process from the gap analysis and not consider the role and capabilities of the agencies to after the data gaps are dealt with. The proposed Data Strategy also does not follow the recommendations of the Finkel Report in 2017, which encouraged improved data flows and governance under a phase 1 approach. In considering the ESB pillars and recommendations, we assessed where there are current arrangements, policy alternatives or other ways to resolve the issue in a more cost-effective and less burdensome way.

Below is a bird’s eye view of our recommendation for a revised Data Strategy approach which prioritises Phase 1 pillars.

We believe that Phase 1 of the ESB Data Strategy should undertake a review of the current data sets collected, or able to be collected under the existing powers of market bodies. These market bodies should also look to streamline and create efficiencies in existing regulatory reporting and data collection requirements (our submission highlights a number of different reporting and data collection obligations on market participants). Finally, Pillar 1 should look to improve the data and information sharing between stakeholders, by utilising existing data sharing arrangements such as the Consumer Data Right and the Data Availability and Transparency Bill.

By undertaking this Phase 1 approach, the ESB and other industry participants will be able to ensure adequate time and consideration is given to any remaining data gaps, based on a full assessment of the impacts of regulatory intervention in the market since the Finkel review, and to see what issues were resolved in Phase 1. It will ensure that thorough cost-benefit assessments are undertaken before pursuing formal recommendations.

You can read our full submission to the ESB here.