PIAC made a submission to the Australian Energy Market Operator (AEMO) on its updated draft Baselines Eligibility and Compliance Metrics Policy for Wholesale Demand Response (WDR).
PIAC generally supports AEMO’s draft determination, however is concerned a large proportion of loads may be ineligible due to proposed participation constraints, particularly those which are variable and temperature sensitive and therefore high value WDR.
We strongly encourage AEMO to considers ways of addressing inefficient dispatch and uncertainty other than through an accuracy threshold.
We support calls from a number of stakeholders that the bias metric is not clearly necessary and recommend AEMO continue to seek alternative means of dealing with bias that do not unnecessarily restrict participation.
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