PIAC considers that the draft rule determination for the Register of distributed energy resources is in the long-term interests of consumers. PIAC agrees that AEMO is a suitable host for the register and that there is value in starting with a static register in terms of timeliness, but that the aim should be to eventually create a dynamic register. PIAC supports the draft rule that AEMO develop a guideline rather than including all of the details in the NER.
The design of the register needs to be forward focused and have the flexibility to be relevant in a rapidly evolving market. The register needs to be transparent and enable accountability. Protecting consumers’ privacy needs to be a priority with a straight forward procedure developed to enable consumers to access and correct their own data. More consideration needs to be given to how consumers can directly benefit from the DER register. The register should also be used to improve safety, not only to be used by first responders but also used to inform and assist consumers when there is a product recall, as well as product end of life disposal.
