{"data":{"id":"sbm37cd6c91a0f99230760d9","short_id":7,"created":"2025-09-11T05:51:18.432Z","space_id":"spc373b7c376c789babe619b","project_id":"prj3737dfec9a5ee2d441175","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"ENGIE","upload-a-submiss_9dbd27":"fil37cd6c8595ca770793be1"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37cd6c8595ca770793be1":{"id":"fil37cd6c8595ca770793be1","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/20250911_ENGIE_submission_CER_technical_regulatory_framework.caedcff6.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/20250911_ENGIE_submission_CER_technical_regulatory_framework.caedcff6.pdf","filename":"20250911 - ENGIE submission - CER technical regulatory framework.pdf","transcribed":"Add\n\nConsumer Energy Resources Taskforce\nDepartment of Climate Change, Energy, the Environment and Water\nGPO Box 3090\nCanberra ACT 2601\n\n11 September 2025\n\nTo Consumer Energy Resources Taskforce,\n\nDraft National Technical Regulatory Framework for CER resources\n\nENGIE Australia & New Zealand (ENGIE) appreciates the opportunity to respond to the Department of\nClimate Change, Energy, the Environment and Water (the Department) on its consultation on aspects of the technology workstream in the National Consumer Energy Resources (CER) Roadmap.\n\nThe ENGIE Group is a global energy operator in the businesses of electricity, natural gas and energy services. In Australia, ENGIE operates an asset fleet which includes renewables, gas-powered generation, and battery energy storage systems. ENGIE also provides electricity and gas to retail customers across\nVictoria, South Australia, New South Wales, Queensland, and Western Australia.\n\nENGIE provides its retail customers with access to innovative products that have a focus on CER, such as residential virtual power plants (VPPs) and electric vehicle (EV) charging. ENGIE is also currently collaborating with several distribution network service providers (DNSPs) regarding opportunities for network-owned, retailer-leased community batteries.\n\nENGIE is supportive of national consistency and harmonisation in relation to CER integration and requirements. Reducing inconsistencies in requirements should reduce the costs of regulatory burden for participants and improve outcomes for consumers. For that reason, ENGIE supports the development of a\nNational CER Technical Regulatory Framework.\n\nIn this submission, ENGIE highlights several considerations for the Department to consider as it progresses the National CER Technical Code.\n\nRegulatory functions and regulatory body\n\nENGIE agrees that the responsible regulator for the National CER Technical Code must be flexible and responsive to the increasingly changing environment and technology advancements. While this is an important objective, there will likely be significant barriers to the practical implementation of a government-created regulatory body that is not impacted by bureaucratic inefficiencies.\n\nPage 1\nThe proposed traits and capabilities of the regulatory body appear quite ambitious and there does not appear to be any existing regulators in the energy industry that would meet the desired traits and capabilities. The costs involved in creating and skilling up a regulatory body that can meet these traits and capabilities may be significant.\n\nENGIE is supportive of a regulatory framework that is transparent and principles-based and is managed in a manner that promotes certainty for participants.\n\nScope of the National CER Technical Code\n\nThe proposed scope of CER devices is appropriate for the initial version of a National CER Technical Code.\nHowever, it may be helpful for transparency and clarity around the criteria that would need to be met for an additional product or device to be added to the scope of the Code.\n\nFor example, it is not currently clear whether demand-shifting devices (such as pool pumps and hot water systems) would fall within the scope of the Code. ENGIE does not consider it is likely that the cost burden associated with updating device information for each of those demand-shifting devices would exceed the benefits to consumers and market participants. ENGIE would support the introduction of a criteria for inclusion in the Code that requires a type of device to be capable of exporting electricity to the grid.\n\nInstalled Device Register\n\nENGIE is broadly comfortable with the information that is proposed to be mandated for inclusion in the national Installed Device Register. ENGIE welcomes further consultation on the scope of the Installed Device\nRegister and how it can be developed in a manner that provides practical functionality to participants.\n\nFor example, ENGIE would welcome consideration of the inclusion of voluntary information that identifies whether the CER device is capable of providing other services, such as contingency frequency control ancillary services (FCAS). This type of information may support VPP operators in presenting options to prospective customers that provide benefits relative to the services the CER device may be capable of providing.\n\nMandatory updating of connection information\n\nIn relation to the regulatory measure to require CER actors to provide information at key points into the\nInstalled Device Register, ENGIE considers it is important to clearly define the entity responsible for each specific information type at different points of the customer journey. ENGIE’s initial concern is the potential burden of the information provision, particularly where this information may be duplicative of information already reported elsewhere or where the information is not reasonably available from that entity.\n\nENGIE also considers further work is required on understanding the compliance and enforcement approaches when issues occur. For example, there may be scenarios where the Original Equipment\n\nPage 2\nManufacturer (OEM) has exited the market and is no longer supporting software updates, providing information to customers or servicing APIs to aggregators.\n\nENGIE would welcome further consultation on these proposed regulatory measures as the scope and detail is further developed.\n\nInformation for consumers\n\nENGIE is supportive of measures to empower consumers to participate in CER more confidently. As noted in the draft prototype, this may include educational guides, clear complaint pathways and customer-facing device and installer lists. CER devices and the associated industry structure is complex and tools that can simplify this information and improve consumer understanding are welcomed. ENGIE would welcome further collaboration with the Department on consumer information tools to ensure these are well-targeted and provide valuable information to consumers.\n\nConcluding remarks\n\nShould you have any queries in relation to this submission please do not hesitate to contact me on, telephone, 0436 929 403.\n\nYours sincerely,\n\nMatthew Giampiccolo\nManager, Regulation and Policy\n\nPage 3","size":153523,"redacted":[],"meta":{"name":"20250911_ENGIE_submission_CER_technical_regulatory_framework.caedcff6.pdf","local_path":"files/CqqgW8-dBD_Xyh-fuY8vGeFy.pdf"},"config":{}}}}}