PIAC recognises that the main reason for the rule change proposals is to ensure a high level of competition in the DER market. The proponents state and we agree that the way to do this is to prevent networks from adding DER such as batteries to their regulated asset bases. PIAC understands that service classification may not be the most appropriate mechanism through which to meet the objectives of the rule change proposals. Overall we suggest, in line with the Total Environment Centre’s submission, that there are potentially two ways to reduce the current complexity and to increase competition in line with the objectives of the proposed rule change. First, to change the way the AER classifies services, or, second, by requiring or allowing the AER to classify some assets as well as or instead of services.
