AGL supports the draft rule’s intent to more effectively integrate consumer energy resources (CER), and other unscheduled price-responsive resources (UPRR), into the electricity system for the benefit of all energy users. The rule change consultation process has highlighted the underlying challenges of integrating CER and UPRR into a market and operational framework designed for market generators exclusively focused on market dispatch. 

There is a risk that the rule will not meaningfully resolve the challenges it originally sought to address without revisions to its design. To address this, the submission proposes changes to dispatch mode requirements to reduce the burden and costs of participation and enhancements to the proposed monitoring and reporting framework.

Read the full submission here.