PIAC made a submission to the AEMC’s Contestability of energy services draft rule determination. PIAC supported the intent of the rule to facilitate the updated of distributed energy resources and help facilitate an effective market for the provision of these assets and services. Furthermore, PIAC supported the reforms designed to improve the process for classification of distribution services. However, PIAC has some concerns about the draft rule. Broadly, these concerns relate to the apparent conflation of ownership and control and the assumption that a contestable energy services market will always result in good outcomes for consumers.