AGL welcomes the opportunity to respond to the AEMC’s frequency control directions paper, which considers how best to incentive provision of valuable system frequency control services.

AGL supports amendments to existing contingency FCAS arrangements through the addition of a 2-second raise and lower fast frequency response service, to sit alongside the six existing contingency services. We also support applying the existing pricing and cost recovery mechanisms to this new 2-second market, with the potential to also reward provision of inertia.

Finally, we support implementing primary regulating services from 2023, to replace the existing mandatory primary frequency response requirements, to support the power system during normal operation. We support further investigation by the AEMC of how causer pays factors for this service should be calculated, to fairly share the cost burden amongst participants, including whether causer pays should be ‘double-sided’.

Read the full submission here and here.