AGL responds to the Australian Energy Market Commission Clarifying mandatory primary frequency response (PFR) obligations for bidirectional plant directions paper supporting the proposal draft rule that requires that batteries provide primary frequency response when they are following frequency anyway. AGL supported the rule as mandatory PFR is required for other units in the NEM capable of doing so, however we consider a market for PFR would be vastly superior to the current mechanism of mandatory PFR.

Read the full submission here.