{"data":{"id":"sbm37d287cdd9b28c5a0cb3f","short_id":12,"created":"2025-09-12T05:39:09.401Z","space_id":"spc373b7c376c789babe619b","project_id":"prj3737dfec9a5ee2d441175","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"AGL","upload-a-submiss_9dbd27":"fil37d287ab94b2b01fb24c1"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37d287ab94b2b01fb24c1":{"id":"fil37d287ab94b2b01fb24c1","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/AGL_Response_to_National_Technical_Regulatory_Framework_for_CER.34cafcca.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/AGL_Response_to_National_Technical_Regulatory_Framework_for_CER.34cafcca.pdf","filename":"AGL Response to National Technical Regulatory Framework for CER.pdf","transcribed":"AGL Energy Limited\nT 02 9921 2999 Level 24, 200 George St\nSydney NSW 2000\nagl.com.au Locked Bag 14120 MCMC\nABN: 74 115 061 375 Melbourne VIC 8001\n\nDepartment of Climate Change, the Environment, Energy and Water\n\nConsumer Energy Resources Taskforce\n\nSubmission via DCCEEW website portal\n\n12 September 2025\n\nConsultation Paper – National Consumer Energy Resources (CER) Roadmap – National Technical\nRegulatory Framework for CER – T2\n\nAGL Energy (AGL) welcomes the opportunity to provide responses to the questions posed by the Department of\nClimate Change, the Environment, Energy and Water (DCCEEW) in response its Consultation Paper on a national technical regulatory framework for CER.\nAGL supports the establishment of a National Technical Regulatory Framework and the paper’s objectives. The establishment of a national framework could play an important role in harmonising requirements across jurisdictions and network areas. Improved conformance with standards can also support a transition to a high-\nCER future by creating greater certainty on the behaviour of CER.\nAGL is broadly supportive of four of the functions in the framework prototype (Establishing national CER technical requirements, Mandatory accreditation of CER devices, Mandatory installer accreditation and accountability and Support CER system integrity). While supportive of the intent, AGL’s view is that the function\nMandatory updating of CER connection information would be practically unenforceable in the short term if it seeks to capture remote updates from multiple actors.\nThe proposed regulatory reforms are extensive and will have far reaching impacts on the supply chain for a range of CER. Disproportionate obligations on original equipment manufacturers (OEMs) and installers risks limiting the pace of electrification and CER installations in Australia. AGL would support a gradual implementation of requirements and encourages the CER Taskforce to ensure technical requirements are supported by evidence of need. A gradual implementation would enable regulators to upskill to deliver their new functions, and DCCEEW to test whether the framework is delivering on its intended traits (e.g., a nimble and responsive regulator).\nAGL supports DCCEEW’s objective to emphasise preventing non-compliance rather than punitive enforcement.\nIf DCCEEW aspires to have a strong CER installation workforce in the future, this should be underpinned by upskilling and streamlining of regulatory processes. Tying some of these obligations to incentives could also help improve compliance beyond what could be achieved by an educational and advisory function.\nAppendix A includes responses to select questions in the consultation paper. If you have any queries about this submission, please contact Andrea Espinosa on aespinosa2@agl.com.au.\n\nYours sincerely,\n\nKyle Auret\n\nSenior Manager Policy and Markets Regulation\n\nAGL Energy\n\n1\nAbout AGL\n\nProudly Australian for more than 187 years, AGL supplies energy and other essential services to residential, small and large businesses and wholesale customers. AGL is committed to providing our customers with simple, fair and accessible services as they decarbonise and electrify the way they live, move and work. AGL is investing in flexibility and has been making strong progress against our grid-scale battery and distributed energy resources (DER) targets. As of FY25 AGL had 1.49 GW of decentralised assets under orchestration, and a FY27 target of 2.5 GW of demand-side flexibility. AGL is also a market leader in the development of innovative products that enable consumers to make informed choices on how and when to optimise their energy usage to better manage their energy costs.\n\n2\nAppendix A – Response to consultation questions\n\nQuestion Response\n\nDo the system outcomes The system outcomes appear appropriate, but AGL notes that stronger\ncapture what is needed for standards on buildings, vehicles, and appliances that facilitate improvements in\nthe CER system to energy efficiency and productivity are necessary to support electrification and\nfunction? CER adoption.\n\nAre the current challenges, The National CER Technical Framework could play an important role in\nexamples and impacts resolving these challenges. AGL observes that:\ncomprehensive? Is a\nNational CER Technical • The objective to maintain device conformance and connection of CER\nRegulatory Framework the devices throughout the lifecycle is incredibly complex and may not be\nbest mechanism to resolve best resolved through the national framework.\nthese? • An additional example of where technical requirements and standards\nare applied and interpreted differently across and within jurisdictions is\nin the application of PKI to devices communicating via CSIP-Aus.\nWhile this is being harmonised through the not-for-profit NEPKI, the\nNational CER Technical Regulatory Framework offers an opportunity\nto create longer-term arrangements to manage this function within\ngovernment.\n\nAre the five regulatory AGL is broadly supportive of functions 1,2,3 and 5: Establishing national CER\nfunctions the appropriate technical requirements, Mandatory accreditation of CER devices, Mandatory\npriorities for the National installer accreditation and accountability and Support CER system integrity.\nCER Technical Regulatory\nAGL’s view is that function 4 Mandatory updating of CER connection\nFramework?\ninformation would be practically unenforceable in the short term if it seeks to\ncapture remote updates.\n\nWhat are the barriers to • Function 1: AGL strongly supports the objective of ensuring technical\nimplementing the proposed requirements and standards are applied and interpreted consistently\nregulatory functions? What across Australia. However, this objective would not be achieved if\nopportunities are there to distribution network service providers (DNSPs) or state regulators are\nleverage existing able to modify or add requirements and deviate from the National CER\napproaches? Technical Code. Therefore, it would be necessary for DCCEEW and\nthe regulator (when established) to closely engage with DNSPs, state\nregulators and industry to ensure there are no material deviations\nbetween the requirements and its actual implementation.\n• Function 2: DCCEEW could consider whether BESS need to be limited\nto lithium-based batteries. The regulator should enable technology\ndevelopment and innovation by ensuring other types of batteries are\nnot excluded by default from the product list (and therefore installation\nin Australia). DCCEEW could also consider an option to list multiple\nCER asset types within a single device to reduce the need for separate\naccreditation processes.\n• Function 4: As noted in the previous question, the requirement to\nupdate the Installed Device Register every time there is a remote\nupdate (e.g., software update or device settings) is likely to be\nunenforceable in the short term. This would then lead to poor data\nquality which would not deliver on the objectives sought. It would be\npreferrable to implement the Installed Device Register gradually – e.g.,\ncreate an obligation to collect information at the time of installation and\nservicing on-site. Implementation would also need to consider which\nparties can input directly onto the register and be granted access to the\n\n3\nQuestion Response\ninformation. AGL’s view is that the FRMP for the associated NMI\nshould be granted access to this information.\nOnce that information has been found to be successfully collected with\nsatisfactory quality and completeness, DCCEEW / the regulator could\nconsider expanding the obligation to servicing and updates. AGL also\nnotes that in the case of aggregator updates, it wouldn’t be feasible to\nprovide updates every time market participation occurs. This sort of\ninformation exchange should remain within the scope of other reforms,\nprimarily the Integrating Price Responsive Resources Rule\nimplementation. Information could potentially be provided by\naggregators when there are changes to the asset mode.\nDCCEEW should also be mindful of the sensitivity of data related to\nCER devices and their operations. Where information is sought on\nconsumers’ CER, it will be important to ensure this is supported by\ncustomer acceptance either through the creation of the right incentives\nor through effective engagement from industry and\ngovernments. DCCEEW should also consider whether elements of the\nCDR framework can be leveraged to support this function.\n\nWhat work is underway Should the function Mandatory updating of CER connection information be which might interact with implemented, this should only come into force after AEMO’s DER Register is the proposed regulatory uplifted and the associated access / data sharing arrangements are finalised functions? How could these (e.g., as part of the CER Data Exchange project). DCCEEW, in collaboration interactions be managed? with AEMO and industry, could then assess whether this is an appropriate tool\nto support the intended obligation.\n\nHow do we ensure This would be achieved by ensuring the requirements set by the regulator are regulator decisions are based on strong evidence of need (e.g., material risk to the energy system or consumer centric? harm to consumers) to ensure innovation and customer choice are upheld.\n\nIs the suggested As outlined earlier, AGL would support an incremental implementation of the compliance and Installed Device Register. It will also be important to uplift systems (e.g., the enforcement approach DER Register) to support this function effectively before obligations appropriate and commence.\nachievable?\nHowever, broadly supportive of compliance-by-design approach. It will be\nimportant to keep data requirements to the minimum necessary and to support\neasy data submission. It will also be important to manage registration data\nefficiency and reduce data collection frictions. DCCEEW could consider\nleveraging the existing supply chain to reduce duplication – for example,\ntransferring information from electrical compliance certificates into the Installed\nDevice Register.\n\nHow do we maintain Disproportionate obligations on installers risks limiting the pace of effective regulation while electrification and CER installations in Australia. AGL supports DCCEEW’s minimising regulatory objective to emphasise preventing non-compliance rather than punitive burden for installers? enforcement. If DCCEEW aspires to have a strong CER installation workforce\nin the future, this should be underpinned by upskilling and streamlining of\nregulatory processes. Tying some of these obligations to incentives could also\nhelp improve compliance beyond what could be achieved by an educational\nand advisory function.\nDCCEEW could leverage existing organisations such as Solar Accreditation\nAustralia for rooftop solar and battery systems and could consider how other\n\n4\nQuestion Response\norganisations such as the Electric Vehicle Council could play a part for other\ntypes of installations.\n\nAre these appropriate AGL agrees that obligations on customer agents should be considered in more options for conformance detail and separately (and in the context of the market workstreams).\nmanagement? Should others be considered?\nWhen/what are the triggers?\n\nHow will the Framework As noted in the previous response, obligations on customer agents (e.g., VPP practically work, particularly operators) should be considered separately. Generally, reforms should seek to in its interactions with those uplift industry obligations to ensure consumers are protected regardless of who currently have a whether their service provider is covered within the scope of the NEL/NERL.\ndegree of control over The focus should not be on creating additional requirements on parties which aspects of CER within the are already heavily regulated within the electricity framework.\nsystem? An OEM has product requirements, how does a DNSP/aggregator have to fit in with those requirements? e.g. VPPs currently have no regulation.\n\nHow do we identify and Identification of requirements should occur transparently and in close prioritise the work program consultation with industry. DCCEEW / the regulator should ensure there is a for requirements? balanced representation of interests and expertise as part of this process. The\nprocess should prioritise the adoption of international standards to avoid\nimpacting consumer choice and, where Australian standards are adopted,\nensure these are implemented consistently across and within jurisdictions.\nAppropriate lead time should be given to industry to adjust to new obligations.\n\nWhat consideration should AGL supports the initial scope, which does not include smart devices.\nthe framework make, if any,\nDCCEEW should also ensure the regulator’s scope only covers devices that of demand shifting devices\ninteract with the network. For example, in the case of inverter, power such as smart pool pumps\nconversion equipment and integrated protection devices this should not include and controlled load hot\ndevices that are not part of a generating system and grid-connected.\nwater systems? Should they be addressed, or should the regulator only cover CER that can add power to the grid?\n\n5\nQuestion Response\n\nWhat about other Matters related to smart meters and associated requirements should continue associated elements such to be regulated within NEL/NERL framework.\nas smart meters? Should national regulation determine required minimum standards for smart meters, taking into account consumer benefit and desired system outcomes?\n\nOne of the key methods of Matters related to DOEs should continue to be regulated within NEL managing CER interaction framework. However, the regulator should play a role in ensuring CSIP-Aus with the grid is the use of requirements for backstops and DOEs are applied and interpreted consistently dynamic operating across DNSPs. In later years, the regulator could also incorporate the functions envelopes (DOEs). DOEs of the not-for-profit NEPKI as this entity is currently authorised to operate until provide upper and lower 30 June 2030.\nbounds on the maximum and minimum flow of power through a given point within an electricity distribution network during a particular time interval for CER device(s). Where do you think the responsibility for regulating DOEs should sit? (And why?)\n\n6","size":177719,"redacted":[],"meta":{"name":"AGL_Response_to_National_Technical_Regulatory_Framework_for_CER.34cafcca.pdf","local_path":"files/z4RcK5qwTV7HQ2AhbEE71lXB.pdf"},"config":{}}}}}