AGL welcomes the opportunity to provide responses to the consultation questions posed by the Australian Energy Market Operator in relation to the Consumer Energy Resources (CER) Data Exchange. AGL is broadly supportive of the concept of a CER Data Exchange but cautions that many of the proposed use cases rely on future frameworks and reforms to be effective. In the face of uncertainty, there is a risk of building solutions that either encompass various future states (leading to unnecessary broadening of the project scope and costs) or which simply do not deliver on their intended benefits. To limit this risk, the initial focus should be on use cases that address gaps in the current regulatory framework.
Read the full submission here.