PIAC provided a submission to the Australian Energy Market Commission (AEMC)’s Review into Consumer Energy Resources (CER) Technical Standards (the Review) Draft Report (the Draft). The Report sought feedback on the implementation of CER technical standards in the National Electricity Rules.
We argued that optimised integration and effective utilisation of CER is an urgent priority in the ongoing transformation of our energy system. Robust CER standards are necessary to achieve the strongest consumer outcomes for all energy consumers.
While broadly supported the recommendations put forward in the Draft, we expressed concern with their voluntary nature.
We also encouraged the AEMC to outline the risks and costs associated with non-compliance of CER standards from a household perspective not just a system-wide perspective. Consumers are unlikely to be in a position to detect or remedy non-compliance and, where they have invested significant funds on the expectation of a level of service from their CER, should be supported to ensure those expectations are reasonably met.
Finally, we recommended that the AEMC address related issues in the Review including data access and ownership, interoperability, technological neutrality and the need for more comprehensive behind-the-meter technical standards.
