{"data":{"id":"sbm37d295ce44a3ec7fdf268","short_id":6,"created":"2025-09-12T05:54:27.012Z","space_id":"spc373b7e8fdc7876bf315e6","project_id":"prj3737dfec9a5ee2d441175","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"AGL","upload-a-submiss_9dbd27":"fil37d2958345a36cfe79fc6","upload-a-submiss_d30ec6":"fil37d2959795b2e7b56a32c"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37d2958345a36cfe79fc6":{"id":"fil37d2958345a36cfe79fc6","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/AGL_Response_to_Technical_Standards_for_CER_Interoperability_For_Publication_Redacted.01684156.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/AGL_Response_to_Technical_Standards_for_CER_Interoperability_For_Publication_Redacted.01684156.pdf","filename":"AGL Response to Technical Standards for CER Interoperability - For Publication_Redacted.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\nSubmissions via DCCEEW website portal\n\n12 September 2025\n\nConsultation Paper – National Consumer Energy Resources (CER) Roadmap – Technical Standards for\nCER Interoperability – T1\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 national technical regulatory framework for CER.\nAGL supports the CER Roadmap’s vision where CER becomes an integral part of Australia’s secure, affordable and future electricity systems, delivering benefits and equitable outcomes to all consumers. CER interoperability will play an important role in enabling this future.\nAGL supports the ‘first principles’ approach taken by DCCEEW to consider CER device requirements. As the energy mix changes, many energy consumers will change too. Diverse customer preferences will drive the need for a broad suite of products and services. Some customers may choose to accept third-party coordination of their devices, while others will seek to retain control of their assets but will respond effectively to the right incentives (e.g., event-based rewards or simple, actionable and fair price signals). Interoperability requirements\n– and if necessary, the associated interoperability standards – will need to be able to meet consumer needs and preferences as a first principle. They should support scalability, industry innovation, and competition.\nBetter interoperability offers the opportunity for improved product choice and customer experience. However, cost-effective, scalable and flexible interoperability solutions can be developed without adoption of standardised communications pathways – for example, via Application Programming Interface (API) integration. Where standardisation is sought, Australia should seek to align with international requirements in first instance.\nAGL supports the collaborative and transparent development of Australia-specific interoperability standards, where these can be voluntarily adopted by industry. However, mandatory adoption of local standards should be carefully balanced against the of risks limiting innovation and consumer choice. Where consumer protections are needed, existing regulatory frameworks, such as Australian Competition and Consumer law, may be better suited to ensure these protections are preserved rather than bespoke technical requirements.\nAppendix A includes responses to select questions in the consultation paper. If you have any queries about this submission, please contact %REDACTED_TEXT%.\n\nYours sincerely,\n\n%REDACTED_TEXT%\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\nQuestion 1 - Should the Consumer churn is already possible at a retailer level. VPP customers can\ncapacity for consumers to churn service providers and choose from a range of compatible products.\nswitch energy service There are some limitations in market systems (e.g., complexity to update\nproviders (churn) be National Meter Identifiers enrolled for Frequency Control Ancillary Services\nprioritised and what are the participation), but these do not prevent a customer from churning.\nimpacts?\nAt an original equipment manufacturer (OEM) level, interoperability standards\ncould play a role in dictating the minimum functionalities expected of CER.\nAGL is supportive of the principle of achieving a minimum level of consistency\nacross OEMs, as this can improve consumer choice and stimulate market\ndevelopment and competition. However, this needs to be balanced against the\nrisk of higher consumer costs if prescriptive requirements led to OEM exit and\nfewer options for consumers. Many OEMs in the Australian market are global\nand have a choice about whether to prioritise building for Australian markets or\nlarger international markets. Addressing churn may improve consumer\nconfidence, but it would not address other barriers which limit the transition to\nan ‘interoperable’ CER ecosystem – for example, customer reluctance to\naccept external control of their assets.\nWhile interoperability requirements can be used to support a minimum level of\n‘openness’, the extent of these should be carefully considered against the\nimpacts on innovation and consumer choice. For example, DCCEEW could\nseek to prioritise minimum requirements that allow CER to be orchestrated,\nwithout necessarily enabling customers to access and change operational\nsettings.\nAustralia’s CER market is rapidly evolving and highly competitive, so the risk of\nvendor dominance is likely low in the short-term. Where consumer protections\nare needed, existing regulatory frameworks, such as Australian Competition\nand Consumer law, may be better suited to ensure these protections are\npreserved rather than technical requirements. If these are not found suitable,\ntechnology requirements could be considered but these would ideally not be\nbespoke requirements for the Australian market.\n\nQuestion 2 - What are your There are advantages and disadvantages to both approaches, but it may be\nviews on interoperability preferable for EVSE (Electric Vehicle Supply Equipment) to take precedence.\nhierarchy via the vehicle\nAdvantages associated with EVSE precedence include:\nand an EVSE? Do you\nthink the EVSE should take - EVSE are the first connection point into the electricity network\nprecedence over the - EVSE is responsible for ensuring the power delivery is safe, within\nvehicle or vice versa? limits and compliant with network regulations\n- EVSE tend to have smart charging capabilities as a default, provided it\nis running a supporting Open Charge Point Protocol (OCPP), that can\nbe adjusted based on external signals to balance the supply load, in\nco-ordination with an electric vehicle’s (EV) preferences\n- EVSE precedence could help limit instances where EVs ‘bypass’ the\nchargers’ instructions.\nA key disadvantage of this approach is affecting vehicle battery performance\nand warranties. However, this could be potentially resolved through direct\nagreements between EVSE and EV manufactures. Additionally, EVSE can\noverride EV’s preferences which may result in a poor driver experience and\ninconsistent charging behaviour.\n\n3\nQuestion Response\n\nQuestion 3 - Should No. These requirements should not apply to EV Level 1 (Mode 2 and 3) minimum device/system chargers at this stage.\nrequirements be applied to\nEV Level 1, Mode 1 and\nMode 2 charging technologies, as per discussion in section 4.1?\n\nQuestion 4 – Should AGL does not oppose these requirements if they are consistent with minimum device/system international applications – e.g., OCPP.\nrequirements be applied to\nHowever, minimum service requirements should take into consideration public EVSE?\ndependence on network conditions, and signals (e.g., constraints) that might\nbe applied by the network and which would affect the EVSE service.\n\nQuestion 5 - Are there any The analysis seems comprehensive.\nCER device types or use cases not adequately captured in the 13 identified requirements?\n\nQuestion 6 - Are there any The analysis seems comprehensive.\nother standards that can support each identified requirement?\n\nQuestion 7 - In the mapping The analysis seems comprehensive.\nexercise in Table 5.14, do you agree with the identified gaps? Are there existing standards that could fill these identified gaps?\n\nQuestion 8 - Do you have Further standards should only be pursued when it’s evident the gap is causing views on the prioritisation of material issues. Injecting standards prematurely into CER products and further standards work to services will not necessarily increase deployment.\naddress the identified gaps? Some of the aims of this paper, such as increasing the uptake of CER\norchestration, will not necessarily be addressed by the creation of\ninteroperability standards if they do not address material gaps such as\nconsumer acceptance for these types of products.\n\nQuestion 9 - How can Australia should seek to align with international requirements. Mandatory\nAustralia align with adoption of local standards risks reducing consumer choice by locking-out international standards products from the Australian market.\nwhile maintaining flexibility\nAGL supports the collaborative and transparent development of Australia- for local conditions?\nspecific interoperability standards but not their mandatory adoption unless\nthere is a critical system need. If these standards can help support product\ndevelopment and offer value to consumers, then they are likely to be\nvoluntarily adopted by industry.\n\n4\nQuestion Response\n\nAs noted in the cover letter, cost-effective, scalable and flexible interoperability\nsolutions can be developed without adoption of standardised communications\npathways – for example, via API integration.\n\nQuestion 10 - Are there any Generally, broad access to CER data can exacerbate privacy and cyber risks associated with the security risks. Where information is sought on consumers’ CER, it will be identified requirements, important to ensure this is supported by customer acceptance (either through such as remote updating of the creation of the right incentives or through effective engagement from device settings? industry and governments) and underpinned by the appropriate data privacy\nmeasures. While indirectly related to the requirements, the level of information\ncollected from consumers should not go beyond what’s strictly necessary for\nsystem and network management and should be underpinned by the\nappropriate management of personally identifiable information.\nFurthermore, not all functionalities may be needed for each device at a site.\nOne asset with functionality per site may be sufficient to support the outcomes\nsought in this paper.\nSome of these requirements could also be challenging for EVSE which are not\nV2G compatible (as V2G EVSE must adhere to AS/NZS 4777.2 in Australia).\nSpecific risks identified include:\n- R-8 (monitor site-level power generation and loads) – This functionality\nmay be achievable for inverter-based systems adhering to AS/NZS\n4777.2 but not for other types of CER.\n- R-11 (local CER to CER coordination) – This poses a risk of\nunnecessarily complex CER coordination if there are multiple devices\nreceiving / sending information and which have the potential to make\n‘decisions’ on consumers’ energy usage.\n\nQuestion 11 - Modulating AGL’s preference is for this to be implemented via zero export, as this has the power in response to grid lowest impact on consumers.\nconditions or an external signal can be implemented through zero generation or zero export. Is there a preference for either of these approaches or both?\n\nQuestion 12 - What are the Refer to question 1.\nrisks of supplier (OEM) lock-in under current standards, and how might these be mitigated?\n\n5\nQuestion Response\n\nQuestion 14 - What are The existing processes could be subsumed within the national technical potential pathways to regulatory framework (as part of function 1) and occur in close consultation accelerate the standards with industry.\ndevelopment and\nThe process should prioritise the adoption of international standards to avoid modification processes?\nimpacting consumer choice. Appropriate lead time should be given to industry\nto adjust to new obligations.\nWhere Australia-specific standards are being developed, DCCEEW / the\nregulator should ensure there is a balanced representation of interests and\nexpertise as part of this process.\n\nQuestion 15 - The design of The existence of 4 different pathway facilitates integration from different\nCSIP-AUS has 4 possible technology providers at lower cost. AGL's preference is for these alternative pathways (native, gateway, pathways to be retained as CSIP-Aus is already mandated for emergency cloud, cloud/gateway). Only backstop implementations across several jurisdictions and is being utilised by the native pathway enables networks to implement dynamic operating envelopes. Further restrictions in its consumers to switch application could create additional costs on consumers and limit product providers. Do you have choice.\nviews as to the merit of the\nMore broadly, these are some of the risks and benefits associated with alternative pathways for\ndifferent communication pathways:\nCSIP-AUS?\n• Native pathways have improved plug-and-play flexibility, which can\nenable consumers to switch providers without hardware change. It also\navoids proprietary gateways or cloud dependencies.\n• Gateway pathways are a practical solution that can offer simplified\nintegration for OEMs and aggregators, but do introduce some vendor\nlock-in risks. They are also more prone to interoperability\nfragmentation.\n• Cloud pathways are scalable for aggregators and OEMs. However,\nthey can obscure control transparency for consumers and complicate\ncompliance with standards. This could potentially be mitigated through\nconsumer protections, rather than technology requirements.\n• Cloud / gateway pathways may combine the drawbacks of both cloud\nand gateway devices, potentially leading to higher cost and complexity,\ngreater risk of interoperability failure and limited consumer\ntransparency.\n\nQuestion 16 - What are the benefits or disadvantages of facilitating control of a physical device or via the cloud?\n\nAGL’s broader views on the benefits and disadvantages of cloud-based versus\nphysical device control are outlined overleaf.\n\n6\nQuestion Response\n\nCloud-based control\nBenefits:\n• Scalability and flexibility: Cloud platforms allow for rapid scaling,\nremote updates, and integration with third-party services.\n• Centralised orchestration: Enables aggregated control of fleets (e.g.,\nEV chargers, home batteries) for grid services, demand shaping, and\nenergy optimisation.\n• Data-driven insights: Cloud systems can collect and analyse usage\ndata to optimise performance and personalise customer experiences.\nDisadvantages:\n• Dependency on connectivity: Cloud control requires stable internet\naccess; outages can disrupt functionality.\n• Vendor lock-in: Proprietary cloud platforms may limit interoperability\nand consumer switching.\nPhysical device control\nBenefits:\n• Direct, low-latency control: Commands are executed locally, reducing\nreliance on external networks and improving responsiveness.\n• Enhanced consumer autonomy: Consumers retain control over their\nhardware, which supports switching providers and can avoid vendor\nlock-in.\n• Resilience to outages: Local control can continue functioning during\ninternet disruptions, which is valuable in remote or disaster-prone\nareas.\n\nDisadvantages:\n• Complexity in coordination: Managing multiple devices across different\nbrands and protocols can be technically challenging and costly.\n• Limited scalability: Physical control requires on-site infrastructure and\nmaintenance, which can hinder rapid deployment or upgrades.\n• Higher upfront costs: Installation and configuration of physical control\nsystems often involve significant capital expenditure.\n\n7\nQuestion Response\n\nQuestion 17 - What are the Site-Level Interoperability benefits and disadvantages\nBenefits: of applying interoperability standards at a site versus a • Simplified compliance: Standards applied at the site level reduce device level? duplication. A single smart device (e.g. battery or EMS) can coordinate\nother devices, avoiding the need for every device to meet all\nrequirements.\n• Lower cost and complexity: OEMs can avoid embedding full\ncompliance into every device, which reduces manufacturing and\ncertification costs.\n• Practical orchestration: Site-level control allows for holistic energy\nmanagement, especially in mixed-device environments (e.g. solar +\nEVSE + battery), which is common in commercial and residential\ndeployments.\nDisadvantages:\n• Limited granularity: Site-level standards may not capture device-\nspecific behaviours or capabilities, which can hinder advanced\norchestration or diagnostics.\n• Risk of single point failure: If the coordinating device fails, the entire\nsite may lose interoperability functionality.\n• Reduced portability: Devices may not be interoperable when moved to\nanother site unless reconfigured or re-certified.\nDevice-Level Interoperability\nBenefits:\n• Enhanced flexibility and portability: Devices can be moved between\nsites or networks without losing functionality, supporting consumer\nswitching and modular upgrades.\n• Granular control and diagnostics: Enables precise orchestration,\ntelemetry, and fault detection at the individual device level.\n• Future-proofing: Devices with built-in interoperability can adapt to\nevolving standards and use cases (e.g. V2G, dynamic pricing).\nDisadvantages:\n• Higher cost and complexity: Each device must meet full compliance,\nincreasing development, testing, and certification burdens for OEMs.\n• Risk of fragmentation: Without strong standardisation, device-level\nrequirements can vary widely, leading to inconsistent performance and\nconsumer confusion.\n• OEM resistance: Manufacturers may resist open standards that reduce\ntheir control over device ecosystems, leading to “walled garden”\nscenarios.\n\nQuestion 18 - What lessons AGL’s submission to the NSW Emergency Backstop Mechanism consultation can be drawn from the provides a detailed perspective on this question. In summary, the current approach to CSIP- implementation of CSIP-Aus across networks is not trivial and there is a high\nAUS in terms of testability risk of non-compliance, technical challenges, and in some instances, poor and conformance? customer experience. Harmonisation of requirements across and within\njurisdictions is essential to facilitate industry’s adoption of Australian-specific\nstandards. Testing and conformance requirements may also not be suitable for\nlarger systems – e.g., commercial and industrial (C&I) installations – and\nshould be adapted to reflect the actual design and operation of these systems.\n\n8\nQuestion Response\n\nQuestion 19 - What are the Native pathway net benefit and cost\nNet Benefits: implications of adopting different standards • Consumer switching: Enables seamless provider churn without pathways (e.g. native vs hardware changes.\nadapter/HEMS-based)? • Lower long-term cost: Avoids proprietary lock-in and stranded asset\nrisks.\n• Regulatory alignment: Supports future standards accreditation models.\nCost Implications:\n• Higher upfront OEM compliance costs: Devices must meet full protocol\nand performance standards.\n• Testing and certification burden: Requires robust validation\nframeworks, which may increase time-to-market.\nAdapter/HEMS-based pathway\nNet Benefits:\n• Lower OEM compliance burden: Standards applied at the HEMS level\nreduce duplication across devices.\n• Rapid deployment: Easier to retrofit legacy devices via protocol\nadapters or cloud-based HEMS.\n• Flexible orchestration: HEMS can coordinate multiple devices and\noptimise load across a site.\nCost Implications:\n• Higher integration complexity: Requires robust site-level coordination\nand may introduce single-point-of-failure risks.\n• Ongoing operational costs: Cloud services, software updates, and data\nmanagement add recurring costs.\n• Potential consumer lock-in: Proprietary HEMS platforms may limit\nswitching and interoperability.\n\nQuestion 20 - What are the AGL is broadly supportive of the adoption of OCPP 2.0.1 as its adoption is benefits and costs mature across the market. Some of the challenges raised by the paper (e.g.\nimplications of requiring all lock-in into third party vendors) have been resolved in earlier versions of\nEVSE (both uni-directional OCPP.\nand bidirectional chargers)\nAGL agrees that OCPP 2.0.1 has better security features than OCPP 1.6J, and to support OCPP 2.0.1 and\nwould help EVs and EVSE to talk to each other in a standard way, making\nISO 15118-20 to promote\nfeatures like Plug & Charge and vehicle-to-grid (V2G) easier to use\nV2G use cases?\nImplementing OCPP 2.0.1 and ISO 15118-20 requires more sophisticated\nhardware (currently costs more than $8,000) and software in both the EVSE\nand the electric vehicles themselves. Government incentives and support for\nresearch and development will be crucial to mitigate the costs of these\nrequirements and to accelerate the realisation of a truly smart and interactive\nEV network.\n\n9","size":188792,"redacted":[{"index":2885},{"index":2824}],"meta":{"name":"AGL_Response_to_Technical_Standards_for_CER_Interoperability_For_Publication_Redacted.01684156.pdf","local_path":"files/kink3lflH16iwzNDTbWievHr.pdf"},"config":{}},"fil37d2959795b2e7b56a32c":{"id":"fil37d2959795b2e7b56a32c","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/AGL_Response_to_Technical_Standards_for_CER_Interoperability_Confidential.495cb45d.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/AGL_Response_to_Technical_Standards_for_CER_Interoperability_Confidential.495cb45d.pdf","filename":"AGL Response to Technical Standards for CER Interoperability - Confidential.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\nSubmissions via DCCEEW website portal\n\n12 September 2025\n\nConsultation Paper – National Consumer Energy Resources (CER) Roadmap – Technical Standards for\nCER Interoperability – T1\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 national technical regulatory framework for CER.\nAGL supports the CER Roadmap’s vision where CER becomes an integral part of Australia’s secure, affordable and future electricity systems, delivering benefits and equitable outcomes to all consumers. CER interoperability will play an important role in enabling this future.\nAGL supports the ‘first principles’ approach taken by DCCEEW to consider CER device requirements. As the energy mix changes, many energy consumers will change too. Diverse customer preferences will drive the need for a broad suite of products and services. Some customers may choose to accept third-party coordination of their devices, while others will seek to retain control of their assets but will respond effectively to the right incentives (e.g., event-based rewards or simple, actionable and fair price signals). Interoperability requirements\n– and if necessary, the associated interoperability standards – will need to be able to meet consumer needs and preferences as a first principle. They should support scalability, industry innovation, and competition.\nBetter interoperability offers the opportunity for improved product choice and customer experience. However, cost-effective, scalable and flexible interoperability solutions can be developed without adoption of standardised communications pathways – for example, via Application Programming Interface (API) integration. Where standardisation is sought, Australia should seek to align with international requirements in first instance.\nAGL supports the collaborative and transparent development of Australia-specific interoperability standards, where these can be voluntarily adopted by industry. However, mandatory adoption of local standards should be carefully balanced against the of risks limiting innovation and consumer choice. Where consumer protections are needed, existing regulatory frameworks, such as Australian Competition and Consumer law, may be better suited to ensure these protections are preserved rather than bespoke technical requirements.\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\n%REDACTED_TEXT%\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\nQuestion 1 - Should the Consumer churn is already possible at a retailer level. VPP customers can\ncapacity for consumers to churn service providers and choose from a range of compatible products.\nswitch energy service There are some limitations in market systems (e.g., complexity to update\nproviders (churn) be National Meter Identifiers enrolled for Frequency Control Ancillary Services\nprioritised and what are the participation), but these do not prevent a customer from churning.\nimpacts?\nAt an original equipment manufacturer (OEM) level, interoperability standards\ncould play a role in dictating the minimum functionalities expected of CER.\nAGL is supportive of the principle of achieving a minimum level of consistency\nacross OEMs, as this can improve consumer choice and stimulate market\ndevelopment and competition. However, this needs to be balanced against the\nrisk of higher consumer costs if prescriptive requirements led to OEM exit and\nfewer options for consumers. Many OEMs in the Australian market are global\nand have a choice about whether to prioritise building for Australian markets or\nlarger international markets. Addressing churn may improve consumer\nconfidence, but it would not address other barriers which limit the transition to\nan ‘interoperable’ CER ecosystem – for example, customer reluctance to\naccept external control of their assets.\nWhile interoperability requirements can be used to support a minimum level of\n‘openness’, the extent of these should be carefully considered against the\nimpacts on innovation and consumer choice. For example, DCCEEW could\nseek to prioritise minimum requirements that allow CER to be orchestrated,\nwithout necessarily enabling customers to access and change operational\nsettings.\nAustralia’s CER market is rapidly evolving and highly competitive, so the risk of\nvendor dominance is likely low in the short-term. Where consumer protections\nare needed, existing regulatory frameworks, such as Australian Competition\nand Consumer law, may be better suited to ensure these protections are\npreserved rather than technical requirements. If these are not found suitable,\ntechnology requirements could be considered but these would ideally not be\nbespoke requirements for the Australian market.\n\nQuestion 2 - What are your There are advantages and disadvantages to both approaches, but it may be\nviews on interoperability preferable for EVSE (Electric Vehicle Supply Equipment) to take precedence.\nhierarchy via the vehicle\nAdvantages associated with EVSE precedence include:\nand an EVSE? Do you\nthink the EVSE should take - EVSE are the first connection point into the electricity network\nprecedence over the - EVSE is responsible for ensuring the power delivery is safe, within\nvehicle or vice versa? limits and compliant with network regulations\n- EVSE tend to have smart charging capabilities as a default, provided it\nis running a supporting Open Charge Point Protocol (OCPP), that can\nbe adjusted based on external signals to balance the supply load, in\nco-ordination with an electric vehicle’s (EV) preferences\n- EVSE precedence could help limit instances where EVs ‘bypass’ the\nchargers’ instructions.\nA key disadvantage of this approach is affecting vehicle battery performance\nand warranties. However, this could be potentially resolved through direct\nagreements between EVSE and EV manufactures. Additionally, EVSE can\noverride EV’s preferences which may result in a poor driver experience and\ninconsistent charging behaviour.\n\n3\nQuestion Response\n\nQuestion 3 - Should No. These requirements should not apply to EV Level 1 (Mode 2 and 3) minimum device/system chargers at this stage.\nrequirements be applied to\nEV Level 1, Mode 1 and\nMode 2 charging technologies, as per discussion in section 4.1?\n\nQuestion 4 – Should AGL does not oppose these requirements if they are consistent with minimum device/system international applications – e.g., OCPP.\nrequirements be applied to\nHowever, minimum service requirements should take into consideration public EVSE?\ndependence on network conditions, and signals (e.g., constraints) that might\nbe applied by the network and which would affect the EVSE service.\n\nQuestion 5 - Are there any The analysis seems comprehensive.\nCER device types or use cases not adequately captured in the 13 identified requirements?\n\nQuestion 6 - Are there any The analysis seems comprehensive.\nother standards that can support each identified requirement?\n\nQuestion 7 - In the mapping The analysis seems comprehensive.\nexercise in Table 5.14, do you agree with the identified gaps? Are there existing standards that could fill these identified gaps?\n\nQuestion 8 - Do you have Further standards should only be pursued when it’s evident the gap is causing views on the prioritisation of material issues. Injecting standards prematurely into CER products and further standards work to services will not necessarily increase deployment.\naddress the identified gaps? Some of the aims of this paper, such as increasing the uptake of CER\norchestration, will not necessarily be addressed by the creation of\ninteroperability standards if they do not address material gaps such as\nconsumer acceptance for these types of products.\n\nQuestion 9 - How can Australia should seek to align with international requirements. Mandatory\nAustralia align with adoption of local standards risks reducing consumer choice by locking-out international standards products from the Australian market.\nwhile maintaining flexibility\nAGL supports the collaborative and transparent development of Australia- for local conditions?\nspecific interoperability standards but not their mandatory adoption unless\nthere is a critical system need. If these standards can help support product\ndevelopment and offer value to consumers, then they are likely to be\nvoluntarily adopted by industry.\n\n4\nQuestion Response\n\nAs noted in the cover letter, cost-effective, scalable and flexible interoperability\nsolutions can be developed without adoption of standardised communications\npathways – for example, via API integration.\n\nQuestion 10 - Are there any Generally, broad access to CER data can exacerbate privacy and cyber risks associated with the security risks. Where information is sought on consumers’ CER, it will be identified requirements, important to ensure this is supported by customer acceptance (either through such as remote updating of the creation of the right incentives or through effective engagement from device settings? industry and governments) and underpinned by the appropriate data privacy\nmeasures. While indirectly related to the requirements, the level of information\ncollected from consumers should not go beyond what’s strictly necessary for\nsystem and network management and should be underpinned by the\nappropriate management of personally identifiable information.\nFurthermore, not all functionalities may be needed for each device at a site.\nOne asset with functionality per site may be sufficient to support the outcomes\nsought in this paper.\nSome of these requirements could also be challenging for EVSE which are not\nV2G compatible (as V2G EVSE must adhere to AS/NZS 4777.2 in Australia).\nSpecific risks identified include:\n- R-8 (monitor site-level power generation and loads) – This functionality\nmay be achievable for inverter-based systems adhering to AS/NZS\n4777.2 but not for other types of CER.\n- R-11 (local CER to CER coordination) – This poses a risk of\nunnecessarily complex CER coordination if there are multiple devices\nreceiving / sending information and which have the potential to make\n‘decisions’ on consumers’ energy usage.\n\nQuestion 11 - Modulating AGL’s preference is for this to be implemented via zero export, as this has the power in response to grid lowest impact on consumers.\nconditions or an external signal can be implemented through zero generation or zero export. Is there a preference for either of these approaches or both?\n\nQuestion 12 - What are the Refer to question 1.\nrisks of supplier (OEM) lock-in under current standards, and how might these be mitigated?\n\n5\nQuestion Response\n\nQuestion 14 - What are The existing processes could be subsumed within the national technical potential pathways to regulatory framework (as part of function 1) and occur in close consultation accelerate the standards with industry.\ndevelopment and\nThe process should prioritise the adoption of international standards to avoid modification processes?\nimpacting consumer choice. Appropriate lead time should be given to industry\nto adjust to new obligations.\nWhere Australia-specific standards are being developed, DCCEEW / the\nregulator should ensure there is a balanced representation of interests and\nexpertise as part of this process.\n\nQuestion 15 - The design of The existence of 4 different pathway facilitates integration from different\nCSIP-AUS has 4 possible technology providers at lower cost. AGL's preference is for these alternative pathways (native, gateway, pathways to be retained as CSIP-Aus is already mandated for emergency cloud, cloud/gateway). Only backstop implementations across several jurisdictions and is being utilised by the native pathway enables networks to implement dynamic operating envelopes. Further restrictions in its consumers to switch application could create additional costs on consumers and limit product providers. Do you have choice.\nviews as to the merit of the\nMore broadly, these are some of the risks and benefits associated with alternative pathways for\ndifferent communication pathways:\nCSIP-AUS?\n• Native pathways have improved plug-and-play flexibility, which can\nenable consumers to switch providers without hardware change. It also\navoids proprietary gateways or cloud dependencies.\n• Gateway pathways are a practical solution that can offer simplified\nintegration for OEMs and aggregators, but do introduce some vendor\nlock-in risks. They are also more prone to interoperability\nfragmentation.\n• Cloud pathways are scalable for aggregators and OEMs. However,\nthey can obscure control transparency for consumers and complicate\ncompliance with standards. This could potentially be mitigated through\nconsumer protections, rather than technology requirements.\n• Cloud / gateway pathways may combine the drawbacks of both cloud\nand gateway devices, potentially leading to higher cost and complexity,\ngreater risk of interoperability failure and limited consumer\ntransparency.\n\nQuestion 16 - What are the [Confidential: 150 AGL customers have been trialling a customer-centric Home benefits or disadvantages Energy Management System (HEMS) which empowers consumers to optimise of facilitating control of a their household energy consumption and participate in demand response and physical device or via the load shifting programs, enabling customers to achieve further savings off their cloud? energy bills.\nThe trial was enabled through API-driven interoperability with a $0 upfront\napproach which reduced barriers to entry. Unlike other in-market HEMS\nofferings that require hardware upgrades or complex installations (with costs\nranging from $1,500 to $2,000) and which don’t use native OEM APIs, AGL’s\nHEMS trial delivered optimisation capabilities at no additional costs to\ncustomers beyond their existing asset setup.]\nAGL’s broader views on the benefits and disadvantages of cloud-based versus\nphysical device control are outlined overleaf.\n\n6\nQuestion Response\n\nCloud-based control\nBenefits:\n• Scalability and flexibility: Cloud platforms allow for rapid scaling,\nremote updates, and integration with third-party services.\n• Centralised orchestration: Enables aggregated control of fleets (e.g.,\nEV chargers, home batteries) for grid services, demand shaping, and\nenergy optimisation.\n• Data-driven insights: Cloud systems can collect and analyse usage\ndata to optimise performance and personalise customer experiences.\nDisadvantages:\n• Dependency on connectivity: Cloud control requires stable internet\naccess; outages can disrupt functionality.\n• Vendor lock-in: Proprietary cloud platforms may limit interoperability\nand consumer switching.\nPhysical device control\nBenefits:\n• Direct, low-latency control: Commands are executed locally, reducing\nreliance on external networks and improving responsiveness.\n• Enhanced consumer autonomy: Consumers retain control over their\nhardware, which supports switching providers and can avoid vendor\nlock-in.\n• Resilience to outages: Local control can continue functioning during\ninternet disruptions, which is valuable in remote or disaster-prone\nareas.\n\nDisadvantages:\n• Complexity in coordination: Managing multiple devices across different\nbrands and protocols can be technically challenging and costly.\n• Limited scalability: Physical control requires on-site infrastructure and\nmaintenance, which can hinder rapid deployment or upgrades.\n• Higher upfront costs: Installation and configuration of physical control\nsystems often involve significant capital expenditure.\n\n7\nQuestion Response\n\nQuestion 17 - What are the Site-Level Interoperability benefits and disadvantages\nBenefits: of applying interoperability standards at a site versus a • Simplified compliance: Standards applied at the site level reduce device level? duplication. A single smart device (e.g. battery or EMS) can coordinate\nother devices, avoiding the need for every device to meet all\nrequirements.\n• Lower cost and complexity: OEMs can avoid embedding full\ncompliance into every device, which reduces manufacturing and\ncertification costs.\n• Practical orchestration: Site-level control allows for holistic energy\nmanagement, especially in mixed-device environments (e.g. solar +\nEVSE + battery), which is common in commercial and residential\ndeployments.\nDisadvantages:\n• Limited granularity: Site-level standards may not capture device-\nspecific behaviours or capabilities, which can hinder advanced\norchestration or diagnostics.\n• Risk of single point failure: If the coordinating device fails, the entire\nsite may lose interoperability functionality.\n• Reduced portability: Devices may not be interoperable when moved to\nanother site unless reconfigured or re-certified.\nDevice-Level Interoperability\nBenefits:\n• Enhanced flexibility and portability: Devices can be moved between\nsites or networks without losing functionality, supporting consumer\nswitching and modular upgrades.\n• Granular control and diagnostics: Enables precise orchestration,\ntelemetry, and fault detection at the individual device level.\n• Future-proofing: Devices with built-in interoperability can adapt to\nevolving standards and use cases (e.g. V2G, dynamic pricing).\nDisadvantages:\n• Higher cost and complexity: Each device must meet full compliance,\nincreasing development, testing, and certification burdens for OEMs.\n• Risk of fragmentation: Without strong standardisation, device-level\nrequirements can vary widely, leading to inconsistent performance and\nconsumer confusion.\n• OEM resistance: Manufacturers may resist open standards that reduce\ntheir control over device ecosystems, leading to “walled garden”\nscenarios.\n\nQuestion 18 - What lessons AGL’s submission to the NSW Emergency Backstop Mechanism consultation can be drawn from the provides a detailed perspective on this question. In summary, the current approach to CSIP- implementation of CSIP-Aus across networks is not trivial and there is a high\nAUS in terms of testability risk of non-compliance, technical challenges, and in some instances, poor and conformance? customer experience. Harmonisation of requirements across and within\njurisdictions is essential to facilitate industry’s adoption of Australian-specific\nstandards. Testing and conformance requirements may also not be suitable for\nlarger systems – e.g., commercial and industrial (C&I) installations – and\nshould be adapted to reflect the actual design and operation of these systems.\n\n8\nQuestion Response\n\nQuestion 19 - What are the Native pathway net benefit and cost\nNet Benefits: implications of adopting different standards • Consumer switching: Enables seamless provider churn without pathways (e.g. native vs hardware changes.\nadapter/HEMS-based)? • Lower long-term cost: Avoids proprietary lock-in and stranded asset\nrisks.\n• Regulatory alignment: Supports future standards accreditation models.\nCost Implications:\n• Higher upfront OEM compliance costs: Devices must meet full protocol\nand performance standards.\n• Testing and certification burden: Requires robust validation\nframeworks, which may increase time-to-market.\nAdapter/HEMS-based pathway\nNet Benefits:\n• Lower OEM compliance burden: Standards applied at the HEMS level\nreduce duplication across devices.\n• Rapid deployment: Easier to retrofit legacy devices via protocol\nadapters or cloud-based HEMS.\n• Flexible orchestration: HEMS can coordinate multiple devices and\noptimise load across a site.\nCost Implications:\n• Higher integration complexity: Requires robust site-level coordination\nand may introduce single-point-of-failure risks.\n• Ongoing operational costs: Cloud services, software updates, and data\nmanagement add recurring costs.\n• Potential consumer lock-in: Proprietary HEMS platforms may limit\nswitching and interoperability.\n\nQuestion 20 - What are the AGL is broadly supportive of the adoption of OCPP 2.0.1 as its adoption is benefits and costs mature across the market. Some of the challenges raised by the paper (e.g.\nimplications of requiring all lock-in into third party vendors) have been resolved in earlier versions of\nEVSE (both uni-directional OCPP.\nand bidirectional chargers)\nAGL agrees that OCPP 2.0.1 has better security features than OCPP 1.6J, and to support OCPP 2.0.1 and\nwould help EVs and EVSE to talk to each other in a standard way, making\nISO 15118-20 to promote\nfeatures like Plug & Charge and vehicle-to-grid (V2G) easier to use\nV2G use cases?\nImplementing OCPP 2.0.1 and ISO 15118-20 requires more sophisticated\nhardware (currently costs more than $8,000) and software in both the EVSE\nand the electric vehicles themselves. Government incentives and support for\nresearch and development will be crucial to mitigate the costs of these\nrequirements and to accelerate the realisation of a truly smart and interactive\nEV network.\n\n9","size":205957,"redacted":[{"index":2885}],"meta":{"name":"AGL_Response_to_Technical_Standards_for_CER_Interoperability_Confidential.495cb45d.pdf","local_path":"files/Hn-BW9_poV31apqnyA55Tcl5.pdf"},"config":{}}}}}