{"data":{"id":"sbm376687e45fa50a01734df","short_id":16,"created":"2025-08-22T06:20:15.839Z","space_id":"spc36787c0b36938b78e8ab4","project_id":"prj3669ab09ab934671268d5","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil37ad75810b506409d314c","m3yavyyl":"Blank","mh2xmjhi":"Blank","zovp5q48":"AGL","question-3_2644c5":"AGL broadly agrees with the gaps categories, but notes that the detail of what is needed (and therefore what should be prioritised) will be intricately related with the findings of the M3/P5 consultation paper. AGL’s view is that many of the assumptions in both papers – including whether all consumers will want to, or be able to, become active energy market participants – should be tested.\n\nAGL is also concerned about the volume of information that would need to be exchanged in an ‘ideal’ scenario. AGL does not agree that near-real time frequency and latency has been fully justified across most use cases. The costs of this approach would likely outweigh its benefits. The CER Taskforce should look for ways to minimise the volume of data collected through this process.\n\nThe CER Taskforce should also be mindful of the sensitivity of data related to CER devices and their operations. Where information is sought on consumers’ CER, it will be important to ensure this is supported by customer acceptance either through the creation of the right incentives or through effective engagement from industry and governments.","question-4_35a33c":"Blank","do-you-have-any_8a5f45":"Blank","do-you-agree-wit_300280":"AGL broadly supports the actions in this paper. However, the level of information collected through this process should not go beyond what’s strictly necessary for system and network management.\n\nThe CER Taskforce should ensure the data sharing MVP:\n\nis based on strong evidence of need based on demonstrated system and network risks from CER\n\nis underpinned by the appropriate data privacy measures, which include consideration of which information needs to be collected, which information can be shared and who can be granted access\n\nincludes a coordination element across workstream (2a, 2b, 2c) to ensure there is no duplication.\n\nThe CER Taskforce should also consider the trade-offs of data access to non-market participants. While there are benefits of this approach – such as improving the coverage of data sharing arrangements – broader access to this data (and the associated data bases) could exacerbate privacy and cyber security risks. The report itself notes that across all use cases categorised, 20% of data was identified as Critical and 58% as Restricted. AGL also notes the complexities of procuring data from parties which are currently outside of the scope of the national electricity laws and rules, as this could affect the quality and completeness of the information (and therefore it’s useability).\n\nAction 2c would leverage the CER Data Exchange, which is expected to be built on the foundations of AEMO’s Industry Data Exchange (IDX) and Identity Access Management (IDAM) services. These initiatives are still under development and have proven complex even in their initial iterations. It may be premature to plan an expansion on these systems when their initial design and effectiveness is still in question.","if-not-what-woul_9c683c":"Refer to question above","in-relation-to-t_a36457":"Blank","would-you-like-t_08a393":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37ad75810b506409d314c":{"id":"fil37ad75810b506409d314c","bucket":"files-au-climate","remote_path":"climate-au/p/prj3669ab09ab934671268d5/submission/spc36787c0b36938b78e8ab4/16_AGL_sbm376687e45fa50a01734df_attachment_redacted.2c0315b4.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3669ab09ab934671268d5/submission/spc36787c0b36938b78e8ab4/16_AGL_sbm376687e45fa50a01734df_attachment_redacted.2c0315b4.pdf","filename":"16 - AGL - sbm376687e45fa50a01734df - attachment - redacted.pdf","transcribed":null,"size":149842,"redacted":[],"meta":{"name":"16_AGL_sbm376687e45fa50a01734df_attachment_redacted.2c0315b4.pdf","local_path":"files/gc-6_d37uUUelNTnIyqiMG4o.pdf"},"config":{}}}}}