The JEC made a submission to the Australian Energy Market Commission’s rule change process concerning changes to how the market operator considers demand-side factors, such as the take-up of behind the meter generation, demand response, electrification, energy efficiency improvements, and demand shifting. The rule requires the Australian Energy Market Operator (AEMO) to produce a demand-side factor statement as part of each integrated system plan (ISP), outlining how demand-side factors are expected to develop, and run sensitivities in the ISP considering the impacts on the optimal development path of higher or lower take-up of demand-side factors than anticipated.
While we support the rule change proposal, we made some small qualifications of this support.
First, we proposed that the information that the rule mandates the operator collects is not limited to information from distribution network service providers, as sole reliance on DNSPs would be inadequate to provide an accurate and usefully granular picture of demand-side factor developments.
Second, we proposed that the operator is obliged to discuss the new information requirements being placed on DNSPs with consumers, rather than just the DNSPs, and to determine the requirements based not on the costs and benefits to DNSPs, as proposed in the rule change draft, but the costs and benefits to consumers.
Finally, we reiterated our position that the AEMC is obliged to consider emission reduction impacts of the rule, even if an accurate estimation is not possible. We argued that as the direction of impact is clear, the objective of emission reductions could reasonably be included.
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