{"data":{"id":"sbm37f68246c59c54b459899","short_id":27,"created":"2025-09-19T05:19:26.917Z","space_id":"spc373b7c376c789babe619b","project_id":"prj3737dfec9a5ee2d441175","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"Tesla","upload-a-submiss_9dbd27":"fil37f6822b7fa6ed3c4882f"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37f6822b7fa6ed3c4882f":{"id":"fil37f6822b7fa6ed3c4882f","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/DCCEEW_National_Technical_Framework_Submission.5687b1bb.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7c376c789babe619b/DCCEEW_National_Technical_Framework_Submission.5687b1bb.pdf","filename":"DCCEEW National Technical Framework Submission.pdf","transcribed":"Tesla Motors Australia, Pty. Ltd.\n\n546 Gardeners Road\nAlexandria NSW 2015\nAustralia\n\n16 September 2025\n\nCER Taskforce\n\nDepartment of Climate Change,\nEnergy, the Environment and Water\n\nRE: T2 Develop a national regulatory framework for CER to set and enforce standards\n\nTesla welcomes the opportunity to provide feedback on the Department of Climate Change, Energy, the\nEnvironment and Water’s consultation on the Draft Prototype for a National Technical Regulatory Framework for Consumer Energy Resources (CER).\n\nAustralia’s households and businesses are driving one of the most rapid clean energy transitions globally.\nWith rooftop solar, batteries, electric vehicles, and emerging digital services being adopted at scale, the electricity system is no longer defined by centralised generation but by millions of distributed assets at the edge. Consumers are now not only passive recipients of energy but active participants in energy markets.\n\nThis transformation demands a regulatory framework that is nationally consistent, consumer-centric, and designed for the long term. However, the greatest risk is that regulation becomes overly focused on creating or duplicating technical standards. In our view, the most pressing need is not for more standards, but for a governance structure that makes compliance simpler, ensures consistent interpretation of existing rules, and reduces the burden of fragmented and sometimes arbitrary decisions made across different parts of the system.\n\nToo often, consumers and service providers face inconsistent requirements: DNSPs interpreting connection standards differently, regulators applying overlapping product lists, or even individual DNSP teams taking divergent views on the same technical issue. The same challenges are increasingly visible with platform providers, such as those running DNSP emergency backstops, where differences in implementation create further inconsistency. What is missing is a forum and decision-maker with authority to harmonise interpretations, engage all corners of industry, and provide clear guidance. This, more than any new standard, will deliver trust, efficiency, and innovation.\n\nThe objectives of the framework, consumer investment attractiveness, business viability, correct installation, visibility and security, and proactive innovation management, are sound. Yet success will depend less on the drafting of technical requirements and more on how those requirements are governed and applied.\n\nSuccess indicators should not be framed simply as whether new standards exist or whether compliance processes are documented. Instead, they must measure system outcomes: is the regulatory framework\ndelivering a functioning, cohesive system where consumers can easily adopt CER, where compliance is straightforward and predictable for industry, and where the system itself is secure, reliable, and able to integrate new technologies?\n\nToday, key gaps remain. Standards are developed and interpreted inconsistently across jurisdictions, DNSPs apply different timelines and obligations, and overlapping product listings impose costs on manufacturers and installers. These are not signs of a functioning system. A future-ready framework must therefore place as much weight on measuring coordination and consistency as it does on technical specifications. These outcomes should be the north star of the framework.\n\nSincerely,\n\nEmily Gadaleta\nSenior Energy Policy Advisor\nCurrent Challenges and the Role of a National Framework\n\nThe draft paper rightly identifies fragmented standards, inconsistent installation practices, and poor data visibility as current challenges. Tesla’s experience confirms these problems. Device integrations that are compliant in one jurisdiction may be rejected in another due to differing interpretations of the same standard.\nInstallers are required to navigate inconsistent portals, checklists, and DNSP processes. Aggregators face uncertainty about how a customer’s device will be treated when participating in a program.\n\nThe result is higher costs, slower innovation, and reduced consumer confidence. Importantly, these are not problems of inadequate standards but of governance and coordination. A national framework must therefore prioritise the establishment of a regulator that has the authority to:\n\n• Provide definitive interpretations of technical codes and standards\n\n• Mandate consistent application of connection and compliance processes across DNSPs\n\n• Bring together all relevant stakeholders, OEMs, aggregators, retailers, DNSPs, consumers, and\ntechnology platform providers, in structured forums where issues are resolved quickly and\ntransparently\n\nThis will deliver the biggest win for consumers and industry alike: not more rules, but consistent and trusted application of existing rules.\n\nNational CER Technical Code\n\nThe National CER Technical Code should provide a single baseline of technical requirements, but its purpose should be to simplify compliance and harmonise application, not to proliferate new technical obligations.\nTesla strongly recommends that the regulator be empowered to make decisions on how the Code is to be interpreted in practice. For example, if two DNSPs apply CSIP-AUS differently, the regulator must be able to provide a national ruling that resolves the inconsistency. Similarly, where international standards can be directly adopted, the regulator should provide clarity on equivalence, so OEMs are not forced into duplicative testing regimes.\n\nThe regulator should also establish a transparent forward work program, giving industry confidence about what standards are being considered for adoption and on what timelines. This process should also include transparent consultation with industry on where the biggest priorities are due to pain points or bottlenecks in accelerating deployment of CER.\n\nImmediate priorities should include inverters, batteries, EVSE, and communications protocols such as CSIP-\nAUS. But the focus should be less on adding categories of standards and more on ensuring that existing ones are applied consistently and efficiently, with clear consumer protections in place. This is not about producing endless standards; it is about providing certainty, predictability, and clear interpretation.\n\n3\nDevice Accreditation\n\nDevice accreditation is a vital part of protecting consumers and building confidence in emerging technologies. Consumers should have the assurance that the products installed in their homes are safe, reliable, and capable of supporting participation in markets and services over time. A nationally consistent accreditation framework also helps to create a level playing field for manufacturers and service providers, ensuring that compliance obligations are clear and transparent.\n\nIn Australia, the Clean Energy Council (CEC) has long maintained approved product lists for inverters and power conversion equipment (PCE), PV modules, and lithium-based energy storage devices. These lists play an important role in ensuring that products meet relevant Australian and international standards, and they form the foundation for the design and installation of solar and battery storage systems. They are also formally embedded in the wider regulatory framework: the use of CEC-listed products is a requirement of several DNSPs, state and federal rebate programs, and the Small-scale Renewable Energy Scheme (SRES), where only systems with listed products are eligible for small-scale technology certificates (STCs).\n\nThis central role means the CEC lists are not just a reference tool, but effectively a gatekeeper for market access. Installers, retailers, and stockists must regularly consult the lists, and products can be de-listed at any time. While this function has delivered significant consumer protection, the current processes for obtaining and maintaining listings are increasingly strained.\n\nManufacturers report that obtaining product listings can take many months, often requiring multiple iterations of submissions, with limited transparency around timelines or the basis for decisions. For global technology providers, this uncertainty creates significant difficulties in product release cycles and adds cost. For installers and retailers, delays in product listings can mean reduced choice, stock bottlenecks, or even stranded inventory. Consumers ultimately bear the impact through slower access to new technologies and reduced competition.\n\nIt is important to acknowledge the CEC’s long-standing role and expertise in product quality and consumer protection. But as CER uptake scales rapidly, the accreditation system must evolve to meet the pace of innovation. Without reform, there is a risk that Australia becomes a “second-tier” market, where global technologies are delayed in reaching consumers because of lengthy or opaque approval processes.\n\nA clear example is the treatment of vehicle-to-grid (V2G) technologies. While the CEC has indicated it does not intend to create a separate V2G list, it has proposed updating the inverter list to capture new information.\nThe recent AS/NZS 4777.2:2020 Amd 2:2024 standard includes EVSE-specific clauses covering both mode 3 and mode 4 bidirectional charging:\n\n• Mode 4 charging enables electricity to flow to and from the vehicle via EVSE that contains an\ninverter mounted externally on the wall. These products clearly fall within the scope of the inverter\nstandard and are therefore captured by the CEC’s approved inverter list.\n• Mode 3 charging enables electricity to flow to and from the vehicle via an inverter embedded within\nthe car itself. The extent to which these systems, or their components, should fall under the\napproved inverter list remains unresolved, and processes for reviewing applications are unclear.\n\nThis lack of clarity leaves global OEMs in a difficult position. On the one hand, governments and industry are pressing manufacturers to accelerate the introduction of V2G in Australia. On the other, the absence of a defined regulatory pathway makes it hard for multinational players to prioritise the Australian market. The result is delay, despite strong interest.\n\nThis example illustrates why a governance framework is so critical. A regulator with the authority to work alongside the CEC, OEMs, and standards bodies could provide the clarity and decision-making capacity required to set out how emerging technologies like V2G will be treated. Without such a forum, uncertainty will persist, global players will hesitate to prioritise Australia, and consumers will miss out on the benefits of innovation.\n\nThe solution is not to duplicate the CEC’s function but to complement it with governance reform. A national regulator should provide the oversight and authority to:\n\n• Improve transparency by setting clear service-level expectations for approval timelines and\nproviding structured, consistent feedback where applications require modification\n\n• Ensure consistency by making accreditation decisions binding across DNSPs and rebate programs,\nso that an accredited device is recognised everywhere\n\n• Oversee emerging technologies like V2G, ensuring regulatory pathways are clarified and\nharmonised early, rather than leaving gaps that slow adoption\n\n• Monitor ongoing obligations such as firmware and software updates, ensuring consumers retain\nsafe and functional devices throughout the lifecycle of their system, even if a manufacturer exits\nthe market\n\nBy focusing on governance and simplification, the regulator can make accreditation faster, fairer, and more predictable. This would reduce compliance burdens, improve confidence for global manufacturers, and accelerate access for consumers, all while retaining the strong protections that the CEC’s lists were designed to deliver.\n\nDevice Register and Data Visibility\n\nA national Installed Device Register is valuable, but its purpose should not be to create another compliance obligation for its own sake. Instead, it should be designed as a governance tool that enables consistent treatment of consumer assets across the system.\n\nThe regulator should decide what data fields are essential, how they are to be reported, and how discrepancies are to be resolved. Crucially, this authority should extend to platform providers, including those running DNSPs’ utility servers for emergency backstops, who often implement controls differently. If\n\n5\nplatform providers are not brought into the framework, consumers will continue to face inconsistent outcomes depending on which DNSP or vendor controls their device.\n\nData governance must also be central. Consumers must be able to see and manage their own device information, and competitive providers must not be exposed to unnecessary sharing of sensitive data. The regulator should provide clear, enforceable rules on access and use of register data, ensuring harmonisation across jurisdictions.\n\nThe register must be easy to comply with. Compliance-by-design should be the principle: pre-populated models, QR code scanning, and streamlined portals that minimise manual reporting. The regulator should focus on ensuring that processes are simple, consistent, and nationally harmonised, so that installers, OEMs, and aggregators do not waste resources reconciling multiple reporting obligations.\n\nSystem Integrity and Governance\n\nThe introduction of a dedicated national regulator is not optional it is a priority. Australia is no longer in the early stages of CER adoption. With more than 50,000 battery storage systems already installed under the\nCheaper Home Batteries program, and a growing regulatory and policy push for more flexible products and services, consumers are being asked to participate in increasingly complex energy arrangements. Without a clear regulator, this complexity risks creating confusion, mistrust, and inconsistent outcomes.\n\nThe regulator’s mandate must be explicitly consumer-centric, but its greatest value will be as a governance body that simplifies and harmonises the system. Its role should not be to constantly generate new technical standards, but to provide authoritative interpretations of existing ones, ensure consistent application across\nDNSPs, and bring together stakeholders to resolve conflicts. By doing so, it can address one of the biggest missing pieces in the current landscape: the lack of a trusted decision-maker to end the practice of “random decisions” made by individual jurisdictions or DNSP teams that diverge from intent of simplifying operations in Australia.\n\nThe introduction of such a regulator is also essential to build consumer trust in new market offers.\nConsumers will only embrace orchestration, dynamic tariffs, or vehicle-to-grid if they trust that their devices will work securely, consistently, and in ways that deliver value to them. A regulator with a consumer-first mandate can provide that assurance.\n\nTesla recommends a phased approach to establishing the regulator. States and territories could agree on an initial set of harmonisation priorities while formal arrangements for a national body are developed and legislated. This ensures immediate progress without waiting for lengthy parliamentary processes. Over time, the regulator’s scope could expand to cover a broader scope of work, but initially it could convene to progress critical work such as national alignment on CSIP-AUS implementation.\n\nCrucially, the regulator must not work in isolation. Its decisions must be embedded within the broader governance landscape of AEMO, the AER, jurisdictional regulators, and existing technical processes. The regulator should serve as the central forum for alignment, coordinating with other institutions to avoid\nduplication and to ensure that technical regulation supports, rather than conflicts with, market design and consumer protections.\n\nIn practice, this means designing a regulator with three core traits from the outset: independence to ensure objectivity, technical expertise to remain ahead of global innovation, and collaborative governance structures that embed consumer voices, industry expertise, and jurisdictional perspectives. With these traits, the regulator can provide the clarity and consistency that will encourage consumers to take up new offers, while reducing compliance burdens for industry.\n\nHiring of appropriate technical staff will also be absolutely critical in this process. The regulator must be staffed with engineers and specialists who understand the operation of CER, network systems, and digital platforms. Without staff who truly appreciate the technical realities of the system, the regulator will struggle to provide authoritative interpretations or to win the confidence of industry. Building this technical capability from the outset should be a core priority of the phased approach. The CER Taskforce must prioritise strategies to secure the right mix of engineering and technical talent, so that the regulator has the capability and credibility to perform its role with authority.\n\nThe need for such governance is urgent. CER adoption is no longer hypothetical, it is reshaping the grid today. A regulator that can provide harmonisation, resolve disputes, and streamline compliance will deliver immediate benefits, even before its full statutory authority is in place. States should therefore move quickly to agree a first tranche of harmonisation measures, while Parliament progresses the legislation for a national regulator.\n\nCompliance and Conformance\n\nCompliance should be built into processes, not layered on top. The regulator can play a powerful role here by making compliance simpler and more consistent. The regulator must also provide national rulings on how compliance obligations are to be interpreted, so that industry is not left to navigate inconsistent demands from different DNSPs or jurisdictions.\n\nOngoing conformance is another area where governance matters more than technical detail. Devices should default to safe operational modes if disconnected, OEMs should be accountable for maintaining updates, and consumers should not be left with stranded assets. But it is the regulator’s authority to enforce and harmonise these obligations that will make the difference. By focusing on simplification and national consistency, the regulator can transform compliance from a costly administrative burden into a trusted baseline that builds consumer confidence and supports innovation.\n\nConclusion\n\nThe Draft Prototype is an important step forward, but its success will not come from producing more standards. Instead, it will come from establishing a regulator with the authority, expertise, and governance structures to harmonise interpretations, simplify compliance, and build consumer trust.\n\n7\nBy focusing on governance rather than proliferation of rules, Australia can reduce compliance burden, eliminate arbitrary or inconsistent decisions, and create a regulatory environment where consumers confidently adopt CER and innovators bring new products to market.\n\nTesla strongly supports the establishment of such a regulator, phased in with immediate harmonisation priorities and expanded over time. We stand ready to work with DCCEEW, Ministers, and the CER Taskforce to design a governance framework that is consumer-centric, future-ready, and globally leading.","size":180266,"redacted":[],"meta":{"name":"DCCEEW_National_Technical_Framework_Submission.5687b1bb.pdf","local_path":"files/4EBM6ppB6MqD_BOjszHZBlAp.pdf"},"config":{}}}}}