{"data":{"id":"sbm37f6814f140d5986511c3","short_id":21,"created":"2025-09-19T05:18:23.508Z","space_id":"spc373b7e8fdc7876bf315e6","project_id":"prj3737dfec9a5ee2d441175","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"Tesla","upload-a-submiss_9dbd27":"fil37f680fc559c35dfab967"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil37f680fc559c35dfab967":{"id":"fil37f680fc559c35dfab967","bucket":"files-au-climate","remote_path":"climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/DCCEEW_Interoperability_Submission.49f11165.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3737dfec9a5ee2d441175/submission/spc373b7e8fdc7876bf315e6/DCCEEW_Interoperability_Submission.49f11165.pdf","filename":"DCCEEW Interoperability 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: T1 Technical Standards for Consumer Energy Resources (CER) Interoperability\n\nTesla welcomes the opportunity to contribute to the development of technical standards for CER. As one of the world’s leading energy innovators, we view interoperability not as an end in itself, but to deliver value to consumers.\n\nWe support the Department’s approach that reflects the importance of defining a function, service, or task, to be delivered by a standard as a first principle and places consumers at the centre of decisions relating to\nCER technical standards. We also agree that in the evolving CER space, prescribing a set of technical standards without consultation on device requirements and use cases can risk unintended consequences tailoring delivery to a specific purpose without considering the interrelationship of multiple requirements across multiple devices.\n\nOur position is clear: vertical integration has too often been misjudged. Far from undermining consumer choice, it provides efficiencies that customers actively value, delivering seamless experiences, superior reliability, and more cost-effective performance. When consumers invest in advanced technologies such as\nTesla Powerwall, vehicle charging solutions, or access to our Supercharging network, they do so with the expectation of premium service. Interoperability must respect that choice: enabling baseline consistency in delivering a service, while preserving the ability of providers to innovate above the line. Our concern is not alignment with global standards, but ensuring sequencing and harmonisation remain paramount so that costs are not unnecessarily passed through to consumers.\n\nWe support in principle the establishment of a performance baseline. But interoperability should not be confused with homogenisation. Proprietary tools and differentiated services are not threats; they are the drivers of customer value. Consumers benefit most when standards safeguard minimum common capability but leave room for providers to offer differentiated, best-in-class experiences.\n\nThe largest barrier to efficient interoperability in Australia is not competition between retailers or OEMs, but the 13 different DNSPs interpreting standards like CSIP-AUS differently. Each bespoke interpretation forces duplicative engineering, adding substantial costs and delivering inconsistent outcomes for consumers. This\nis where inefficiency lies, in monopoly divergence, not competitive innovation. Unless addressed through national harmonisation, consumers will carry the burden of inefficiency in perpetuity.\n\nThe consultation paper emphasises switching as a key measure of consumer benefit. Tesla agrees switching should be possible and we enable it today, both as a licensed retailer and through partnerships with providers such as Amber, AGL, and Engie. However, switching is not the highest-value outcome in a high-CER environment. Consumers cannot switch away from 40% of their bill in network costs. Real savings are increasingly coming from empowering households to take ownership of their energy through solar, storage, and optimisation tools. Switching metrics can also be misleading, counting forced transfers when customers move house, or short-term reactions to tariff reforms. New metrics are needed that reflect the true value customers derive from CER - lower bills, resilience, and seamless integration into markets and networks.\n\nInternational experience shows sequencing matters. In the UK, rushing to mandate device-level schemas before harmonising distribution service operator (DSO) requirements created complexity, slowed innovation, and undermined customer value. Australia can avoid these pitfalls by:\n\n1. Harmonising DNSP/DSO response requirements nationally, starting with a single interpretation\nand application of CSIP-Aus.\n\n2. Setting a baseline capability floor, while leaving space for OEMs and aggregators to differentiate\nand compete.\n\n3. Positioning DNSP control as an emergency-only measure, used in rare occasions with\nconsumers empowered to delegate routine orchestration, if they choose to do so, to their chosen\nprovider.\n\nThe consultation paper also does not adequately address governance. Interoperability will only succeed if governance arrangements clearly allocate roles, responsibilities, and accountability across DNSPs, AEMO,\nOEMs, and retailers. Without this, even the best-designed technical standards risk fragmented outcomes.\n\nTesla’s philosophy is simple: put consumers at the centre, empower competitive markets to innovate, and hold monopolies accountable for reducing costs and complexity through consistency. Standards should guarantee fair access, security, and transparency, but never level down innovation. Our integrations build on standards to deliver superior reliability and consumer experiences, not to bypass them. By focusing on harmonisation of interfaces that communicate objectives and grid needs (not control) and preserving competitive differentiation above it, Australia can build an interoperability framework that delivers:\n\n• Consistent, reliable system integration\n\n• Freedom for consumers to choose providers and premium experiences\n\n• Faster, lower-cost innovation that accelerates the clean energy transition\n\nDefining success in interoperability must also evolve. It cannot mean opening every device and function to every actor in an ‘everything, everywhere, all at once’ approach, which risks complexity and inefficiency. Nor should success be measured narrowly by customer switching, which is a poor proxy for households that\nnow produce, store, and trade their own energy. Success must instead be judged by whether interoperability delivers lower costs, higher reliability, and greater consumer empowerment.\n\nOur feedback has been informed through relevant global experience and direct feedback from our policy counterparts in North America and Europe to inform our recommendations on minimum CER device requirements, applicable technical standards and priority gaps to be considered by Energy Ministers. Should you wish to engage further, please reach out. Tesla looks forward to working with policymakers, industry, and consumers to deliver an interoperability framework that strengthens consumer outcomes, enables scalable VPP participation, and positions Australia as a global leader in consumer-centric energy transformation.\n\nKind regards,\n\n%REDACTED_TEXT%\n\n3\nResponse to questions\n\nQuestion 1: Should the capacity for consumers to switch energy service providers (churn) be prioritised and what are the impacts?\n\nTesla supports consumer choice as a foundation of a competitive energy market but cautions against equating interoperability solely with churn. The consultation paper rightly identifies switching as an attribute of interoperability. However, switching rates alone are an imperfect measure of consumer benefit. Many recorded switches occur when households move premises or react to temporary tariff changes, rather than reflecting dissatisfaction or genuine competition. Interoperability should not be designed around switching as its singular benchmark. In a high-CER world, consumers are not passive buyers but active participants, generating, storing, and trading energy. Metrics of success must reflect this reality by focusing on consumer empowerment, resilience, and value creation, rather than churn statistics.\n\nThe real value for consumers, especially in a high CER environment, lies in owning technologies that deliver consistent bill savings, resilience, and seamless integration into energy markets. Vertical integration is often misunderstood here: it is not a threat to choice but an efficiency driver. When consumers buy a Tesla\nPowerwall, EV, or access the Supercharger network, they are exercising choice, selecting a premium ecosystem where hardware, software, and services are tightly integrated to provide a superior experience.\nMandating lowest-common-denominator device requirements risks stripping away this value.\n\nTesla customers already can and do switch. Tesla holds its own retail licence in Australia from the AER and the ESC, while also partnering with multiple retailers such as AGL, Amber, and Engie. But switching is not the highest-value outcome in a high-CER environment. Switching remains a valuable feature and Tesla supports it, but it is only one measure of competition. Interoperability reforms must also track broader consumer benefits: lower bills, reliability, resilience, and seamless integration.\n\nImportantly, consumers cannot switch away from the substantial rising network costs, which remain a large driver of higher bills. What they can do is take ownership of their usage through solar, storage, and intelligent optimisation. Standards that enable this optimisation, rather than treating churn as the singular benchmark will maximise consumer benefit.\n\nTesla’s position is therefore that consumer empowerment, not churn, should be the priority metric for interoperability. Consumers should have the freedom to choose differentiated providers and products, including vertically integrated ones, without being forced into homogenised solutions. That is exactly what our distributed intelligence throughout our products and services do, mould outcomes according to customer preferences while also ingesting information from the market, local network conditions and weather forecasts to deliver the best possible outcome.\nQuestion 2: What are your views on interoperability hierarchy via the vehicle and an EVSE? Do you think the EVSE should take precedence over the vehicle or vice versa?\n\nThe consultation paper correctly identifies the challenge of multiple signals reaching both the EV and the\nEVSE. In practice, the most effective approach is not a rigid hierarchy but a performance baseline that ensures coherent operation across both devices, while leaving room for OEMs to innovate above it.\n\nTesla recommends at this time that any ISO 15118 and OCCP both remain a hardware-ready requirement.\nPerformance-based standards continue to be most appropriate (i.e., focusing on reliable charging of EVs and positive EV driver experience). Prior to selecting a communication protocol, it is important to understand the objective that is trying to be achieved via utilising a specific protocol, whether that is managed charging,\nPlug and Charge, or some other vehicle grid integration strategy. Here, international lessons are instructive.\nThe California Energy Commission has emphasised “ISO 15118-ready” chargers. But crucially, they recommended a phased adoption to avoid premature lock-in, noting inconsistencies between ISO 15118-2 and ISO 15118-20 implementations; Australia can adopt a similar approach. Additionally, if OCPP is required, compliance with either 1.6 or 2.0.1 should be allowed. In this way, interoperability hierarchy is managed through baseline coordination, while product integration and innovation continue to enhance consumer experience.\n\nTesla also requests further consideration of specific use-cases for any standards requirement. It is important to differentiate between light-duty vs medium/heavy-duty applications as well as AC vs DC charging. In all cases, it is important to first establish the objective of why a standard protocol is beneficial, any associated costs and prior to implementation, that an adequate implementation timeline be considered so as to not create unnecessary barriers to the industry during this time of rapid expansion. We request considerations of the various charging use-cases and applications of charging protocols rather than applying a broad requirement without clearly defined benefits to EV drivers.\n\nQuestion 3: Should minimum device/system requirements be applied to EV Level 1, Mode 1 and Mode\n2 charging technologies, as per discussion in the section above?\n\nTesla agrees with the consultation paper’s position that non-smart devices, such as Level 1 and many Mode\n1/2 chargers, should remain out of scope. These devices provide only basic charging functionality and cannot practically deliver the communication, modulation, or orchestration that interoperability requires.\nIncluding them would risk unnecessary compliance costs without delivering proportional consumer benefit.\nInstead, standards should focus on devices where interoperability delivers real system and consumer value, advanced AC (Mode 3) and DC (Mode 4) chargers, home batteries, and flexible loads. This is consistent with international practice. Where minimum requirements are introduced, they must be carefully sequenced.\n\nBy focusing only on advanced devices and sequencing requirements thoughtfully, Australia can deliver interoperability that lowers costs and increases consumer value, without imposing unnecessary burdens on legacy devices or stifling innovation in premium ecosystems. Globally, regulators have avoided mandating\nOCPP or ISO 15118 conformance for legacy devices; instead, they have prioritised ‘ready’ hardware for\n\n5\nfutureproofing. Australia should adopt this proven sequencing approach, avoiding premature mandates that could drive unnecessary costs.\n\nQuestion 4: Should minimum device/system requirements be applied to public EVSE?\n\nTesla supports that interoperability should set a baseline, not strip away proven consumer value. So careful sequencing, that delivers the greatest consumer value at the lowest system cost should be the goal. The consultation paper notes that public charging is increasingly critical for uptake of EVs and highlights the need for national consistency across EVSE. Tesla agrees that minimum requirements should be applied to public EVSE, but only where those requirements are verified to demonstrably improve customer outcomes.\n\nWhere back-end integration is required, OCPP support could be useful for roaming and multi-provider environments in the future. However, it should not be mandatory for integrated networks like Tesla’s\nSupercharger network, which already deliver industry-leading reliability and seamless consumer experiences. Over-prescription risks levelling down consumer value. Minimum requirements for public\nEVSE should therefore focus on ISO 15118-ready hardware across connectors, phased testing as global standards stabilise and flexibility in back-end protocols, recognising that innovation and integration often deliver higher reliability than common-denominator approaches.\n\nQuestion 5: Are the device/system requirements (R1–R13) comprehensive and fit-for-purpose?\n\nThe consultation paper’s outlined R1–R13 framework covers the essential building blocks of interoperability, from disconnection and modulation through to telemetry and trusted communication. As outlined in Chapter\n4, the use case mapping identified relevant use cases and associated device/system requirements necessary, describes each requirement, its purpose and a pathway to deliver. The chapter then maps each requirement to applicable technical standards. Importantly this highlights that there are multiple pathways for delivery. As such, Tesla supports this list and broader program of work to establish a comprehensive baseline. However, during the next phase of analysis, we recommend the Department prioritise work and focus on three areas:\n\n1. Include DNSP harmonisation explicitly: the most significant interoperability barrier for global OEMs\nin Australia is not between devices, but between the 13 DNSPs who interpret standards like CSIP-\nAUS differently. Unless requirements address this, consumers will continue to bear inefficiencies.\nHarmonising DNSP implementation should therefore be treated as a foundational requirement to\nreduce compliance costs and complexities, ensuring global OEMs continue to prioritise the\nAustralian market.\n\n2. Monopoly control should be limited to emergencies: the next iteration of CSIP-AUS (v1.3) is\nconsidering pathways such as “battery extensions,” which would allow DNSPs to reach behind the\nmeter and directly control household assets. Competitive markets should remain the primary\ncustomer interface. Allowing DNSPs to directly control assets risks disempowering consumers and\nundermining retailers and aggregators who provide tailored, value-adding services. Instead, the\nsmarter and more consumer-empowering option in CSIP-AUS v1.3 is the integration of dynamic\npricing pathways, which enable customer agents to respond to network signals via incentives. This\npreserves customer choice, empowers competition, and still delivers the reliability outcomes\nnetworks need.\n\n3. Guard against homogenisation: requirements should establish a baseline of capability that defines\na set of services needed and a standard way of request those services – not direct control.\nMandating only one pathway risks stripping away consumer choice. We also caution against items\nlike the recommendation on automatic device setting updates being mandated as a blanket\nrequirement. As the consultation paper acknowledges, device configurations can be complex,\nand AEMO’s own reporting shows installers are improving compliance over time. A more\nmeasured approach, with engagement and testing, is needed to avoid unintended consequences\nfor consumers and reserving their agency.\n\nOverall, the R1–R13 framework is a strong starting point, but should be framed as a floor, not a ceiling, ensuring space for proprietary innovation and differentiated services that consumers actively value.\nAustralia should focus on ensuring baseline capabilities, while leaving optional profiles to be adopted as technology and consumer needs mature. To build confidence in the practicality of R1–R13, we recommend DCCEEW convene a dedicated workshop with OEMs, perhaps with the Clean Energy\nCouncil’s OEM Working Group, to walk through each requirement in detail. This would ensure the standards are workable, technically grounded, and avoid duplication.\n\nQuestion 6: Are there any gaps in requirements coverage or application?\n\nYes.\n\nThe consultation paper’s mapping of device/system requirements is comprehensive, but we again emphasise three critical gaps in requirement coverage and application. We appreciate the approach to look at CER devices, however this work cannot proceed without consideration of what those devices are connecting to and how we measure success of interoperability.\n\nAs such, the first is DNSP/DSO harmonisation. Devices cannot be truly interoperable if monopoly networks apply inconsistent interpretations of CSIP-AUS. Standards must require national consistency to eliminate duplication and confusion. The most significant interoperability barrier for global OEMs in Australia is not between devices, but between the 13 DNSPs who interpret standards like CSIP-AUS differently. Unless requirements address this, consumers will continue to bear inefficiencies. Harmonising DNSP implementation should therefore be treated as a foundational requirement to reduce compliance costs and complexities, ensuring global OEMs continue to prioritise the Australian market.\n\nAEMO noted in ‘Learnings from industry implementation of emergency backstop mechanisms for distributed resources’ report that some OEMs, including Tesla, have elected to adopt communications\n\n7\npathways that utilise direct to device controls by incorporating active CER management in the firmware of the device. In these utility-to-CER pathways such as ours, CER devices are directly connected to DNSP systems and the OEM’s role is in the design of firmware which implements active CER management.\n\nThe OEMs who have chosen this pathway have likely done so to deliver real solutions to the minimum system load issues being faced across the NEM, in a way that reduces risks of scalability “bottlenecks” during an at-scale activation of a backstop during emergencies. However, it also has particularly high up-front costs and effort which has additional challenges around resourcing. Something that has been significantly exacerbated when having to be done several times to integrated with several different between DNSPs. As other international markets start to develop similar tools, 13 different interpretations in a market as small as\nAustralia really becomes untenable. As AEMO pointed out, designing device firmware for future scalability, and managing updates, are also important considerations in this analysis. Reliable and robust platforms for\nOEMs are crucial and effort in this space to future-proof good customer outcomes should not be disregarded.\n\nThe second is the trajectory of CSIP-AUS itself. Proposals under the next iteration of CSIP-AUS v1.3, such as “battery extensions” risk normalising direct network control of household assets. Monopoly control should be limited to emergencies. Allowing DNSPs to directly control assets risks disempowering consumers and undermining retailers and aggregators who provide tailored, value-adding services. Instead, the smarter and more consumer-empowering option in CSIP-AUS v1.3 is the integration of dynamic pricing pathways, which enable customer agents to respond to network signals via incentives. This preserves customer choice, empowers competition, and still delivers the reliability outcomes networks need.\n\nThe third gap lies in how success of this interoperability workstream is measured. An ‘everything open to everyone’ model is neither practical nor consumer-centric, and switching is not an appropriate metric for\nCER households. Standards must develop metrics that track outcomes such as savings, resilience, and seamless integration, measures that better reflect the benefits interoperability should unlock. By closing these gaps, interoperability can become not just a compliance exercise but a driver of consumer value.\n\nQuestion 7: How should vendor-specific platforms be considered in the interoperability framework?\n\nThe consultation paper raises concerns about proprietary systems limiting consumer choice. Tesla submits that this view misjudges vertical integration. Proprietary platforms are not barriers but enablers: they deliver efficiencies, reliability, and consumer experiences that majority of the other common-denominator approaches cannot.\n\nFor example, Tesla’s product stack, spanning EVs, Powerwall, Superchargers, and optimisation, ensures seamless operation across hardware and software layers. Consumers actively choose this integrated experience for the value, simplicity and for the best-in-class performance it provides. To frame this as lock- in overlooks the agency of consumers and the value they derive from enacting this choice.\nThe role of standards is therefore not to dismantle proprietary ecosystems, but to ensure a baseline that allows grid participation, while respecting differentiated service models. This aligns with international perspectives: California defines “ISO 15118-ready” chargers in ways that ensure security and compatibility but does not compel OEMs to surrender proprietary features. Similarly, OCPP is recognised as a useful tool but not the sole mandated pathway, leaving space for networks like Tesla’s to deliver superior reliability.\nAustralia should adopt the same principle:\n\n• Baseline openness\n\n• Respect for differentiated ecosystems\n\n• Harmonisation of the services needed at the DNSP layer, not homogenisation of OEM value\npropositions.\n\nThis ensures consumers benefit both from open competition and from premium integrated products that deliver the very performance outcomes interoperability seeks to unlock.\n\nQuestion 8: Which requirements should be prioritised for standards development, and why?\n\nThe consultation paper highlights the need to identify which requirements are most urgent for standards development. Tesla’s position is that the priority should not be device features in isolation, but rather the foundational elements that reduce consumer cost and complexity at scale. Chief among these is harmonisation of grid-facing requirements, particularly through a single, nationally consistent implementation of CSIP-AUS. Today, 13 DNSPs interpret and apply CSIP-AUS differently, forcing OEMs and aggregators to build multiple variants of the same functionality. It also tips the scale for global OEMs on the opportunity cost of directing investment to enter new markets or being forced to redirect resources to remain in Australia. This is currently making a once very attractive market less competitive on the global stage and more difficult with each passing day to prioritise. This duplication is also ultimately driving up costs for all OEMs and therefore their consumers, undermining the very efficiency interoperability seeks to unlock.\n\nIn parallel, requirements that enable secure communications and trusted pathways should be prioritised.\nThese ensure that signals from markets or networks can be received and acted upon reliably, without eroding consumer confidence in the safety and security of their devices. Similarly, requirements that underpin dynamic modulation in response to grid conditions (R2, R3) deserve early focus, as these functions are essential to integrating CER into markets and supporting reliability.\n\nBy contrast, requirements that focus narrowly on switching should not dominate early priorities. While switching is important, its consumer benefit pales compared to the cost savings, reliability, and innovation enabled by harmonised DNSP requirements and robust communications. In short, the highest priority should be building the infrastructure of consistency and trust, upon which device-level interoperability can then flourish. Device-level standardisation alone cannot overcome system-level fragmentation. We should not start moving the target until we resolve the paramount issues of implementation of CSIP-AUS as the first\n\n9\nphase pushed through by emergency backstop. Unless we get the fundamentals right, we risk losing sight of delivering promised value for customers in a high CER environment.\n\nQuestion 9: How should alignment with international standards be considered?\n\nInternational alignment is important, but it must be pursued with strategic selectivity. The consultation paper acknowledges that Australia imports all its light vehicles and is therefore deeply influenced by global standards. Alignment with international standards should therefore be pursued where it reduces cost and enhances interoperability, but always with a lens of consumer value and sequencing. Australia’s objective should not be to adopt every overseas schema, but to harmonise selectively and avoid the mistakes of jurisdictions that rushed into prescriptive device-level standards before stabilising utility requirements.\n\nQuestion 10: What are the risks of not having national alignment and interoperability?\n\nThe consultation paper itself makes clear the risks of a fragmented approach: higher costs, stranded assets, and reduced consumer trust. Tesla agrees wholeheartedly, but stresses that the greatest risk does not lie in\nOEM differentiation, but in the continued divergence of monopoly DNSP requirements. Without national alignment, each DNSP will continue to impose its own interpretation of standards like CSIP-Aus. This not only multiplies costs but also undermines consumer confidence, as households in one state may enjoy seamless CER integration while those in another face unnecessary barriers to integration.\n\nAnother risk is that over-prescription of device-level requirements, if not harmonised with grid-facing standards, could produce a “lowest common denominator” outcome. This would strip away consumer choice and penalise those who select integrated products for their superior performance. International experience demonstrates this risk vividly. In the UK, mandatory device-level schemas were introduced before harmonising system operator requirements, leading to complexity, delay, and reduced innovation.\nAustralia can avoid this risk by sequencing reforms in a way that reflects global lessons.\n\nFinally, the consumer risk of inaction is that inefficiencies will simply be passed through to customers.\nFragmented DNSP requirements, duplicated engineering, and lowest-common-denominator device mandates all translate directly into higher bills. The goal of interoperability should be to deliver the opposite, lower costs, greater reliability, and differentiated consumer experiences. Without national alignment and flexibility for a managed approach to interoperability, consumers will bear the costs while innovation is stifled.\n\nQuestion 11: Should the standard require CER devices to meet “zero export” or “zero generation” requirements?\n\nTesla supports a zero export requirement as the most practical and consumer-centred approach. As the consultation paper notes, CER devices may need to curtail their impact on the grid under certain\ncircumstances. From a household perspective, “zero export” is clear and intuitive, it preserves the ability to self-consume solar and storage energy even when export is constrained. By contrast, a “zero generation” requirement would deny households the use of their own clean energy, penalising those who have invested in solar and storage to reduce bills and improve resilience.\n\nThis issue cannot be separated from the ongoing evolution of CSIP-AUS v1.3. One of the foundational principles of interoperability must be that customers retain control over their own assets, which sit behind their meter. Monopoly DNSPs should only ever have access in genuine emergency events. Proposals in\nWestern Australia, where Synergy’s battery rebate is contingent on “battery extensions” that allows a network to reach into the home and directly control assets undermine consumer choice and remove all value from the competitive market propositions for customers to exist.\n\nWhereas the more sophisticated and consumer-empowering option within CSIP-AUS v1.3 is the development of dynamic pricing integrations. These allow customer agents (retailers, OEMs, or aggregators) to respond to network signals through price incentives, rather than blunt monopoly command- and-control. This preserves consumer autonomy, ensures assets remain under the delegated control of the customer’s chosen service provider, and still delivers the system security outcomes networks require.\n\nTesla therefore supports standards that align with zero export as the appropriate baseline, while ensuring\nCSIP-AUS v1.3 evolves in ways that keep consumers in control. Dynamic pricing pathways should be the preferred model for the NEM, with direct DNSP control restricted to emergency backstops only. This balances grid security with consumer empowerment, avoiding an approach that would strip away value from households investing in advanced CER.\n\nQuestion 12: How should interoperability standards address potential risks of vendor “lock-in”?\n\nThe consultation paper raises the concern that proprietary systems could restrict consumer choice. Tesla believes this risk is overstated and often misunderstood. Proprietary platforms are not synonymous with lock-in; they are often the very means by which consumers access seamless, reliable, and differentiated experiences. When households choose to purchase an integrated ecosystem, such as Tesla’s Powerwall,\nEVs, and Supercharger network, they are exercising choice, not losing it. The efficiencies of integration, from optimised performance to simplified user experience, are precisely what many consumers value most.\n\nTesla’s approach is far from lock-in, it ensures consumers benefit from world-class reliability, while still retaining their right to switch providers if they choose. Whereas when each DNSP enforces its own bespoke implementation of standards, consumers are effectively locked into their local network’s interpretation, facing higher costs and fragmented experiences. By contrast, OEMs and aggregators compete nationally and globally, providing consumers with options.\n\nStandards should therefore focus on ensuring an integration baseline, guaranteeing that consumers can delegate control to their chosen provider, and that grid-facing signals are handled consistently, while\n\n11\nallowing OEMs to innovate above that line. In this way, standards safeguard consumer rights without levelling down the premium features and seamless performance that integrated products offer.\n\nQuestion 13: What are the costs and benefits of the proposed approach to interoperability?\n\nThe consultation paper identifies both potential benefits (consumer empowerment, competition, grid stability) and costs (compliance, hardware upgrades, potential reduction in innovation). Tesla agrees with the benefits but urges policymakers to properly diagnose the true sources of cost. The overwhelming inefficiencies today primarily stem not from proprietary OEM platforms, but from DNSP fragmentation and overlapping regulatory requirements. Each time an OEM or aggregator must redesign for a different DNSP interpretation of CSIP-AUS, those costs are ultimately borne by consumers.\n\nBy contrast, integrated and differentiated OEM services often reduce costs by streamlining performance and removing friction. Tesla’s integrated architecture, for example, avoids the need for multiple hand-offs between hardware, software, and service providers, delivering a more reliable and cost-effective experience for consumers. Far from being a cost, such integration is a driver of value. The benefits of a managed interoperability framework are therefore substantial:\n\n• Lower system costs, by harmonising DNSP/DSO requirements nationally\n\n• Greater consumer value, by preserving space for OEMs to innovate and differentiate above the\nbaseline\n\n• Accelerated innovation, by ensuring standards do not freeze the market into lowest-common-\ndenominator compliance\n\nThe costs of the proposed approach, if poorly designed, would come from premature or excessive standardisation that strips away consumer choice and compels OEMs to provide functions for no additional value. Australia can avoid this by sequencing reforms correctly: first harmonising DNSP/DSO requirements, then layering baseline device requirements, while leaving space for competition and integration above the line. Done well, the benefits of interoperability will far outweigh the costs, delivering a system that is more affordable, reliable, and empowering for consumers.","size":220357,"redacted":[{"index":6583}],"meta":{"name":"DCCEEW_Interoperability_Submission.49f11165.pdf","local_path":"files/9Iu9BQVzWMEs0YFT7tubgJvF.pdf"},"config":{}}}}}