As part of delivering the Post 2025 DER Implementation Plan, the Energy Security Board (ESB) is seeking stakeholder views on an assessment framework to inform consideration of the trade-offs involved in applying relevant technical standards relating to inverter-based DER devices.

AGL made a formal submission in response to the ESB’s consultation paper, a copy of which is available here.

AGL supports the ESB’s strategic objective to develop a policy framework that can ensure DER technical standards work in customers’ best interests. We also agree with the ESB’s guiding principles. As we observed in the context of the ESB’s Post-2025 Market Design Project, promoting interoperability through technical standards will be a key enabler for the optimisation of DER across Australia’s energy markets.

Nevertheless, substantial work remains to establish a national technical standards framework that:

• Promotes customer choice and enable customer participation by aligning with internationally accepted standards, where consistent with Australian energy market structures;
• Supports portability to the extent that the benefits outweigh the costs;
• Enables access to secure and open IT platforms as well as technical DER device capabilities; and
• Aligns with the policy direction towards a market-based framework to allow customers to engage and share in DER value.

While we appreciate the work undertaken to date in the development of the Australian implementation guide for IEEE 2030.5 (CSIP-AUS), we remain concerned that the use cases initially implemented in CSIP-AUS focus on network outcomes without sufficient attention given to aggregator use cases that could support more cost-effective outcomes based on the structure of Australia’s energy market system. It will be critical that the standard applied in Australia supports aggregation use cases at the NMI level to facilitate DER co-optimisation across multiple value streams.

The technical standards framework should also be flexibly designed to accommodate alternative communications pathways in the longer-term, as the market for DER services evolves, including to and from individual devices. However, in this context it will remain important that the framework:

• Supports technical service delivery to and from devices;
• Aligns with internationally accepted standards; and
• Provides accurate measurement to support financial transactions between multiple parties in the energy supply chain and ensures consumer confidence.

We provide a range of recommendations in our submission on the assessment framework, applicability, compliance, costs, and related decisions.