The Australian Energy Market Operator (AEMO) is currently reviewing its Market Ancillary Service Specification (MASS) generally and in relation to DER participation in FCAS market. AEMO recently published its draft determination for consultation.

AGL made a formal submission in response, a copy of which is available here.

AGL’s view

AGL is generally supportive of the amendments proposed by AEMO in the second stage of the General MASS Review and we appreciate AEMO’s openness to stakeholder feedback in the earlier stages of this consultation.

In the context of the DER MASS Review, however, we are concerned that AEMO’s proposed sampling rate specifications present an unnecessary barrier to entry for DER participation in fast FCAS markets that is inconsistent with AEMO’s strategic intent to facilitate DER market integration.

As participants in AEMO’s VPP Demonstrations, we note the strategic intent that has underpinned that program to inform the integration of VPPs into the NEM before they reach scale, including the regulatory arrangements affecting the ability of VPPs to participate and inform new or amended arrangement where appropriate.

To determine appropriate technical specifications for business-as-usual operations, AEMO will need to effectively balance the system security needs with the strategic intent to facilitate DER participation in FCAS markets. In this regard, we would urge AEMO to consider the potential for alternative options to address any systems security risks that may prove more effective and cost-efficient for market participants.