{"data":{"id":"sbm3a5bdfbc3c3724319255a","short_id":53,"created":"2026-01-16T07:48:45.244Z","space_id":"spc38bf5a4130666a5ccd765","project_id":"prj38bdad552e555e1c7f990","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"Tesla","upload-a-submiss_9dbd27":"fil3a5bdfabba7cdf4a94b89"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3a5bdfabba7cdf4a94b89":{"id":"fil3a5bdfabba7cdf4a94b89","bucket":"files-au-climate","remote_path":"climate-au/p/prj38bdad552e555e1c7f990/submission/spc38bf5a4130666a5ccd765/Tesla_SSO_submission_redacted.9d0794d8.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj38bdad552e555e1c7f990/submission/spc38bf5a4130666a5ccd765/Tesla_SSO_submission_redacted.9d0794d8.pdf","filename":"Tesla_SSO_submission_redacted.pdf","transcribed":"Tesla Motors Australia, Pty. Ltd.\n\n546 Gardeners Road\nAlexandria NSW 2015\nAustralia\n\n21 November 2025\n\nRetail Markets Section\nDepartment of Climate Change,\nEnergy, Environment & Water\n\nRE: Solar Sharer Offer Consultation Paper 2025-26\n\nTesla welcomes the opportunity to provide a comprehensive submission in response to the Solar Sharer\nOffer (SSO) Consultation Paper. As an organisation operating across energy storage, retail, and orchestration, Tesla has ongoing, real-time insight into customer behaviour, network constraints, CER integration challenges, and regulatory architecture across Australia and global markets. The SSO touches every one of these domains.\n\nTesla strongly supports the ambition behind the Solar Sharer Offer: extending the benefits of abundant daytime solar, while supporting system efficiency and improving affordability. This objective is deeply aligned with the long-term evolution of Australia’s energy system toward a decentralised, flexible, renewable-led architecture where all households benefit from CER, regardless of ownership. However, good intentions do not automatically translate into effective policy outcomes. The SSO is being introduced into a complex, interacting system that includes:\n\n• network tariff reform at different levels of maturity\n• DMO 8, which substantially changes how standing offers are capped\n• retailers’ hedging and cost recovery obligations\n• consumer behaviour, diversity and equity considerations\n• the rapid expansion of CER orchestration, virtual power plants (VPPs), EV adoption, and flexible\nloads\n• constraints within local networks, particularly around voltage rise and hosting capacity\n\nThe SSO therefore cannot be assessed or implemented as a simple “three free hours” offer. It is, in reality, a structural reform that will influence and be influenced by the entire distribution system, the operation of the energy market, the design of retail pricing frameworks, and the financial viability of retailers. Tesla’s overarching conclusion is that the SSO can be implemented successfully, but only if 3 conditions are met:\n1. Network tariffs must be aligned, in substance and structure, with the SSO window\n2. The DMO benchmark must explicitly incorporate the cost of the SSO, or retailers will be structurally\nunable to recover costs without cross-subsidies\n3. The SSO must not be implemented as a rigid prescription, but instead allow pathways for\nfunctionally equivalent, dynamic or orchestrated solutions that achieve equal or better load shifting\nand affordability outcomes\n\nIf government, DNSPs, retailers, and regulators work together on these foundations, the SSO could become an equitable and efficient reform that helps Australia benefit from its abundant solar resources. If these foundations are not put in place, the SSO risks producing unintended inequities, retailer losses, technical constraints and public confusion. Tesla’s overarching recommendations naturally result from the analysis throughout the submission:\n\n1. Adopt the AER Statement of Expectations (provided in Appendix A) to align DNSP tariffs and\nretailer practices during the transition.\n\n2. Allow retailer flexibility to deliver the SSO through functionally equivalent structures, including\nstaggered windows, dynamic windows, algorithmic assignment, or automation-linked products.\n\n3. Align DNSP tariffs with the SSO, ensuring the SSO materially reflects lower system costs.\n\n4. Integrate an explicit SSO allowance into DMO 8 to avoid retailer under-recovery and inequitable\ncross-subsidy structures.\n\n5. Deliver a national communications campaign that makes the SSO’s value proposition clear, honest\nand effective.\n\n6. Integrate evaluation metrics into the annual DMO cycle to track load shifting, affordability, network\nimpacts and customer outcomes.\n\n7. Enable future evolution of the SSO toward dynamic, digitally orchestrated, system-responsive\nstructures.\n\nThis is a reform that speaks directly to Australia’s strengths of decentralised generation, high rooftop solar penetration, and a rapidly electrifying demand base. But goodwill alone is not enough. If implemented simplistically, the SSO risks producing new inequities, retailer under-recovery, consumer misunderstanding and network instability. If implemented thoughtfully, with tariff alignment, retailer flexibility, suitable protections, transparent evaluation, and a coordinated education effort, the SSO can be a cornerstone reform that accelerates the transition while supporting the households who need it most.\n\nTesla provides this submission to ensure the policy delivers on its intent and becomes a durable part of\nAustralia’s energy transition.\n\nSincerely,\n\nEmily Gadaleta\nSenior Energy Policy Advisor\nAppendix A – Tesla submission\n\nThe Solar Sharer Offer is designed to extend the benefits of abundant daytime solar generation to all households. Tesla strongly supports this ambition. The structural shift toward daytime solar dominance is one of the defining features of the Australian electricity market. Minimum demand records have been broken repeatedly across several NEM jurisdictions, and rooftop solar accounts for well over one-third of total renewable generation nationally.\n\nIn this context, enabling more households to consume electricity during periods of surplus solar generation is both sensible and necessary. Doing so improves system efficiency, reduces negative wholesale pricing excursions, supports DNSP voltage management goals, and helps ensure that the benefits of the energy transition are shared broadly across customer groups.\n\nHowever, the SSO as proposed is not simply a consumer affordability measure. It is a structural instrument that sits atop a retail price regulation framework (the DMO), relies on underlying network tariffs designed by\nDNSPs, interacts with two-way export pricing reforms, influences retailers’ hedging strategies, affects the economics of market and standing offers, and shifts physical load patterns across the distribution network.\nIt also interacts with broader changes in consumer electrification, including battery uptake, EV charging, electrified heating, flexible loads and VPP participation. The SSO therefore needs to be implemented with a deep understanding of:\n\n• the DMO architecture and its constraints\n\n• DNSP tariff diversity and the lack of alignment across regions\n\n• the technical limitations and hosting capacity of distribution networks\n\n• customer heterogeneity, including households that cannot meaningfully load shift\n\n• the economic viability of retailers operating within a capped standing offer environment\n\n• the opportunity to integrate CER orchestration and automation rather than rely solely on behavioural\nload shifting\n\n• the need to preserve room for retailer and technology-led innovation\n\n• the fairness implications for solar and CER customers subject to export charges\n\n• the long-term need for dynamic or system-responsive load shifting windows rather than rigid, static\nones\n\nThe SSO cannot be evaluated in isolation. It must be designed within this ecosystem. This is not a question of whether the SSO is desirable; it is a question of how it can be delivered sustainably, equitably and coherently across the national grid. The remainder of the submission is structured accordingly.\n\n3\n1. Policy intent and structural change\n\nThe Government’s policy intent behind the SSO is clear, compelling and strongly aligned with the direction of the Australian energy system. The rationale is straightforward: Australia has an abundance of low-cost, zero-marginal-cost solar generation in the middle of the day. The SSO is intended to extend the benefits of this abundant resource to these households by providing a three-hour daily window of free electricity usage during the daytime solar peak.\n\nFrom a system-wide perspective, this intent aligns with growing evidence that load needs to be shifted into daytime periods in order to avoid deepening minimum demand challenges, mitigate reverse power flows, reduce the scale of future network augmentations, and promote optimal utilisation of existing assets. Public datasets, including analysis produced by the Clean Energy Council on the role of rooftop solar in overall generation mix, reinforce the scale of the opportunity - daytime solar is already the backbone of distributed renewable energy in the NEM.\n\nHowever, the structural challenge lies in translating this vision into an operationally coherent, economically sustainable and customer-equitable mechanism. The SSO is not a simple retail promotion; it is a mandated feature layered onto a regulated standing offer, underpinned by network tariffs that vary widely across\nDNSPs, and introduced at a time when the DMO itself is undergoing significant structural reform.\n\nAdditionally, the SSO’s impacts will not be uniform across households. Some will be able to meaningfully shift appliance use, EV charging or heating/hot water loads into the free period, whereas others, including shift workers, renters with low ability for appliance control, households with medical loads, or those with inflexible usage patterns, will not substantially benefit. For those households, the SSO may provide limited benefit or could even result in higher overall bills if non-free hours are priced higher to compensate for the free window.\n\nFurthermore, the SSO risks reshaping system load profiles in ways that DNSPs may not be technically equipped to manage unless the reform is supported by coordinated tariff design. Synchronous increases in midday load, particularly from EV chargers, resistive electric heating, water heaters and other appliances, have the potential to cause voltage issues or exacerbate hosting capacity constraints.\n\nThe SSO is therefore a structural policy reform that must be grounded in the real conditions and limitations of Australia’s energy system. It must work with and not against the DMO, DNSP tariff reform, CER orchestration trends, and emerging export pricing frameworks. Tesla’s analysis finds that without appropriate guardrails, the SSO could unintentionally undermine affordability for inflexible households, create retailer under-recovery risks, distort CER investment signals, and introduce technical stress into already constrained distribution networks.\n\nThese risks are not arguments against the SSO. Rather, they are arguments for designing it thoughtfully, with regulatory mechanisms, tariff alignment, customer suitability protections, and open pathways for smart, dynamic and orchestrated alternatives. The SSO can succeed, but only if the policy is grounded in system realities.\n2. Interaction with DMO 8\n\nThe SSO will operate within the DMO framework, which is itself undergoing a major shift under DMO 8. This evolution of the DMO has profound implications for the SSO because the DMO determines the maximum allowable average unit revenue retailers can recover from standing offer customers.\n\nDMO 8 is expected to minimise or eliminate competition allowances and reduce headroom for retailers. This design is intended to ensure that standing offers are priced close to efficient cost, minimising “loyalty tax” implications for customers. However, in the context of a mandated free usage window, this poses structural challenges. When a retailer supplies energy during a free period, the retailer still pays:\n\n• network charges\n\n• wholesale energy costs (including hedging costs)\n\n• market fees\n\n• risk premiums\n\n• customer service and operational overheads\n\nIf the SSO price structure requires the retailer to supply energy at zero cost during certain hours but the\nDMO cap prevents the retailer from adjusting non-free hours sufficiently to recover these costs, the retailer is placed in an economically untenable position. Retailers cannot operate loss-making standing offers indefinitely. Without an explicit SSO cost allowance built into the DMO benchmark, retailers face three unsustainable pathways:\n\n1. Retailers absorb losses - not viable beyond a short period, as margins on standing offers are already low.\n\n2. Retailers compensate by raising prices on market offers - this creates a cross-subsidy where inflexible customers, who can’t load shift, fund the SSO for flexible households. This contradicts the policy’s equity objective.\n\n3. Retailers reduce investment in innovation and service to preserve minimal margins - this would undermine broader CER orchestration goals.\n\nNone of these pathways are compatible with the long-term sustainability of the SSO. The only workable solution is for the DMO benchmark itself to recognise and incorporate the cost of the SSO’s free window.\nThat is the SSO cannot succeed if it structurally contradicts the DMO architecture. Alignment must be achieved through a clear, transparent SSO allowance in DMO 8 and future determinations.\n\n3. DNSP tariffs as enabling platform for SSO success\n\nA retail product with a free usage window cannot function economically unless the underlying network tariffs support daytime consumption. Network tariffs are the foundation upon which retail tariff structures sit. Retailers pay network charges on every unit of energy consumed in the free window, even if the retail\n\n5\nprice is zero. If DNSP tariffs do not reflect lower costs in the middle of the day, the SSO becomes fundamentally misaligned with the cost of supply.\n\nTesla’s initial analysis demonstrates below that network tariff diversity across Australia is extremely high.\nSome DNSPs have developed sophisticated solar sponge tariffs with near-zero daytime usage rates; others have conventional time-of-use tariffs with only marginal daytime advantages; others are in the middle of export tariff implementation; some are still exploring DER-aligned tariff reform; and some have made limited progress.\n\nFor example, SA Power Networks already applies a clearly defined solar sponge window (typically 10:00–\n15:00) with materially lower charges that directly support daytime load shifting. Essential Energy offers a\nSun Soaker tariff with a similar mid-day low-cost window (around 10:00–15:00) designed to capture periods of high rooftop PV export. In contrast, Energex in South-East Queensland provides only a standard ToU structure, where the daytime period is priced as a shoulder with no significant discount. These real tariff differentials demonstrate both the opportunity and the challenge of the SSO: while some DNSPs already provide the economic foundation for a free midday retail product, others do not, reinforcing the need for tariff alignment. Without alignment, the SSO effectively becomes a cross-subsidisation mechanism, retailers offering the free window must spread costs into peak hours or fixed charges, both constrained under the DMO, or move them into market offers. This risks pushing cost burdens onto customers who cannot load shift.\n\nThe key conclusion is that network tariffs are not aligned consistently enough to support a single, national\nSSO design. We therefore recommend that network tariff alignment be treated as a precondition for SSO implementation. DNSPs must have an expectation to come to the table, not merely a theoretical signal through the DMO instruments to align their tariffs with daytime load-shifting objectives. This is one of the primary reasons Tesla recommends an AER Statement of Expectations later in this submission at Appendix\nB.\n\nSome initial tariff insights include:\n\n• The strongest “daytime cost signal” environment is in SAPN territory, where network charges are\nexplicitly geared to encourage midday consumption (solar-sponge). That makes the SSO most\ncommercially viable there, all else equal.\n\n• In NSW (Ausgrid, Essential, Endeavour) the network tariff environment is in transition, particularly\nwith the introduction of two-way export pricing. This complicates the SSO free-window economics\nfor retailers.\n\n• In QLD (Energex) and parts of VIC (Jemena, AusNet) where daytime discounts are weaker or less\nclearly defined, the SSO will rely heavily on other mechanisms (such as DMO cost allowances or\nretailer cost recovery design).\n• Because the SSO is a national policy being rolled out via standing offers, the lack of tariff alignment\nconsistency means the commercial and equity risk for retailers and consumers will vary widely by\njurisdiction.\n\n• For the SSO to be viable and equitable, network tariffs must either: (a) provide clear daytime cost\nadvantages aligned with the free window, or (b) the regulatory framework (via the AER) must\nprovide an adjustment or allowance recognising the higher network cost exposure.\n\n4. SSO time window analysis\n\nOne of the most important design considerations for the SSO is whether the three free hours should be fixed nationally, be fixed but differ by DNSP, be staggered, be dynamic and system-responsive, or be variable per household, assigned algorithmically by the retailer.\n\nDNSPs have repeatedly raised a consistent concern, that incentivised load shifting could induce new voltage or thermal constraints even in the middle of the day. Voltage rise is still a dominant constraint across many suburban and semi-rural feeders. If a large number of households begin consuming energy during the daytime free window, the voltage may swing rapidly and interact unpredictably with rooftop solar exports.\n\nThe solution is not to abandon the SSO, but to implement it in a way that accounts for feeder-specific conditions. Tesla recommends that any SSO implementation should consider how to:\n\n• allow retailers to stagger windows\n\n• allow retailers to offer functionally equivalent alternatives\n\n• require DNSPs to publish their sponge window structures in simple terms\n\n• coordinate SSO windows with export pricing windows\n\n• avoid rigid uniformity across entire jurisdictions\n\nSome initial options analysis:\n\nOption 1: Fixed windows (e.g., 11 am - 2 pm)\n\nA strictly fixed window would be the simplest to communicate. However, it poses several risks in that it may not align with local solar production peaks, it may not align with DNSP tariff structures, it could create synchronisation and voltage risks, and it may deepen inequity for households whose usage cannot shift into that exact period. Ultimately, uniformity is elegant politically but suboptimal technically.\n\nOption 2: DNSP-specific fixed windows\n\nA DNSP-aligned window would allow retailers to match free periods with network sponge or low-Day DUoS windows. SAPN’s 10 am–3 pm structure is one clear example of a window that the SSO could align with.\nBut in areas like Ausgrid or Energex, where the DUoS structure is not sharply differentiated during the day,\n\n7\nselecting a DNSP-specific three-hour window may still cause synchronisation effects without underlying\nDUoS support.\n\nOption 3: Staggered windows\n\nA staggered window approach is highly aligned with how DNSPs think about spatial load management.\nHowever, would be incredibly difficult to implement across all DNSPs and all retailers to coordinate and implement. Additionally, communicating to each customer when they have 3 free hours if allocated on post code level would be cumbersome.\n\nHowever, this approach reduces voltage swing and thermal risk while maintaining the policy’s load-shifting benefits. For example:\n\n• A retailer could assign different SSO windows to different households based on postcode, feeder\ncharacteristics, or substation load indices.\n\n• Households on constrained feeders could receive different windows from those on unconstrained\nfeeders.\n\n• Retailers could balance load across their portfolio to avoid sharp synchronisation impacts.\n\nOption 4: Dynamic windows (future evolution)\n\nTesla’s long-term view is that load-shifting incentives could ultimately become dynamic, reflecting real-time solar availability, DNSP operating envelopes, wholesale price signals, congestion forecasts, and VPP optimisation algorithms.\n\nA dynamic SSO window is not feasible for the initial implementation, the market architecture is not ready.\nBut it should be considered as a future pathway, especially if innovative retailers are able to offer different services or value streams moving forward.\n\nOption 5: Individually assigned windows (future evolution)\n\nThis approach allows maximum precision but creates massive communication and customer risks. If one household receives 11–2, and their neighbour receives 12–3, confusion may result. Yet from a technical standpoint, this is the most advanced option and could be permissible if the SSO regulations allow\n“functionally equivalent structures.”\n\n5. Enabling retail flexibility and functionally equivalent products\n\nThe SSO, as proposed, risks being interpreted narrowly by regulators or market participants, for example, as a mandatory requirement that every standing offer include exactly three hours of free usage at a fixed time. Tesla strongly cautions against such rigidity. Retailers must retain the flexibility to design functionally equivalent products that achieve the SSO’s objectives while managing cost recovery, customer suitability, equity considerations, technical constraints and innovation incentives.\nUnder a principles-based design, an SSO product should be considered “functionally equivalent” if it demonstrably meets the policy’s core objectives:\n\n1. Provides materially free or near-zero-cost consumption during periods of high daytime solar\ngeneration\n\n2. Delivers real load shifting into the middle of the day\n\n3. Does not increase evening or peak demand\n\n4. Does not expose customers with inflexible usage patterns to disadvantage\n\n5. Does not create unacceptable local network risks\n\n6. Is transparent, predictable, and easily understood by customers.\n\nIf a retailer can meet these principles using a different structural design, whether that be staggered, algorithmic, dynamic, conditional, controlled-load, orchestration-linked, or hybrid, the product should be permitted. Mandating only one way to achieve these outcomes creates risk; enabling multiple ways to achieve them creates resilience.\n\nFunctionally equivalent structures are not loopholes; they are integral to ensuring that the SSO does not destabilise the system or undermine innovation. Rigid structures would exacerbate synchronisation risks and distort the market. A flexible, principles-based design, with retailer discretion to meet the SSO’s intent, is essential for aligning technical, economic and equity outcomes.\n\n6. Customer equity and education on the SSO\n\nAt its core, the SSO is designed to advance energy equity, to ensure households who cannot install rooftop solar are not left behind in an energy system increasingly shaped by distributed energy resources. But the\nSSO creates a new set of equity risks that must be addressed directly if the policy is to succeed as a fairness mechanism rather than inadvertently create new inequities. The most important equity principle is simple, a household should not be penalised for being unable to meaningfully load shift. Yet without careful design, this is precisely what could occur.\n\nLarge cohorts of customers, shift workers, families, renters, low-income households who rely heavily on evening heating or cooking, medically vulnerable customers with daytime loads that are inflexible, will not be able to shift substantial consumption to the free window. For these households, the SSO could be functionally irrelevant. Worse, if peak rates need to increase in order to fund the SSO (and if the DMO does not include a specific SSO allowance), these households may end up paying more for essential energy.\n\nIf the SSO is not integrated into the DMO methodology, retailers could be forced into shifting the cost of the free period onto peak rates, fixed charges or market offers. This would create a cross-subsidy structure where flexible households benefit greatly, inflexible households subsidise them, and retailers lack room to maintain innovation or investment. This is the opposite of what the SSO intends.\n\n9\nBy including a specific SSO allowance in the DMO benchmark, the AER can prevent this inequitable outcome and ensure all households share equitably in the costs of social policy, while everyone also shares in its benefits.\n\nA further equity layer concerns CER customers, particularly in NSW where two-way export pricing will coincide with the SSO. Rooftop solar customers paying export charges during the same midday period in which SSO customers receive free usage may perceive this as inequitable. The risk is not hypothetical: public perception of fairness is central to the long-term social licence of energy reform. Explicit communication, transparency on export revenue use, and tariff alignment are essential to ensure DER customers do not feel disadvantaged.\n\nAdditionally, the public narrative around the SSO risks becoming overly simplistic, early media commentary and the Ministerial announceable has already focused on “three free hours of power every day”, creating a serious risk of misinterpretation. The SSO is not universally beneficial. Its value is conditional upon one’s ability to load shift during the window, underlying network tariff, appliance control architecture, household routine and occupancy, and whether the household has CER.\n\nWithout a targeted communications strategy, many households may wish to adopt the SSO believing it guarantees bill savings, only to find that their overall bills increase if they remain evening-heavy in usage.\nThis would undermine trust not only in the SSO but in broader energy reforms.\n\nTesla strongly recommends that government develop and fund a national consumer education campaign.\nThe SSO can be highly beneficial, but only if customers understand it.\n\n7. Evaluating the SSO effectiveness\n\nEffective evaluation is essential to ensure the SSO delivers on its objectives. We recommend that evaluation be directly integrated into the annual DMO reporting cycle. This will ensure a consistent national mechanism for monitoring affordability, retailer viability, and overall market trends. Evaluation metrics should be narrative-based rather than purely quantitative and should include:\n\n• the level of load shifting achieved during the free window,\n\n• network impacts, including voltage stability and hosting capacity indicators,\n\n• the impact on wholesale market dynamics,\n\n• the uptake and viability of functionally equivalent SSO structures,\n\n• customer confusion or dispute trends,\n\n• the interactions between SSO consumption patterns and export charges.\n\nThe initial SSO design understandably emphasises simplicity and clarity. However, the future of energy pricing is dynamic, not static. As capabilities expand, as VPPs scale, and as device control becomes more widespread, the energy system will be increasingly characterised by automated, orchestrated load shifting\nrather than behavioural load shifting. In the future, the SSO could evolve into a more sophisticated instrument that allows retailers to dynamically adjust SSO windows based on DNSP operating envelopes and supports grid-scale optimisation that aligns with real-time renewable availability.\n\nA durable SSO design must therefore be flexible enough to evolve. Rigid prescriptions will limit this evolution. A principles-based approach will enable it. These metrics will enable ongoing refinement and ensure the SSO continues to align with the broader evolution of the NEM toward dynamic, flexible, CER-rich operation.\n\n11\nAppendix B – Suggested Draft AER Statement of Expectations: Solar Sharer Offer\n\nA Statement of Expectations outlines the AER’s expectations of both distribution network service providers\n(DNSPs) and electricity retailers in delivering the Solar Sharer Offer (SSO). Its purpose is to promote consistent, transparent and consumer-protective implementation of the SSO. The Statement responds to the unique challenges of a mandated free-usage window within a regulated price framework and seeks to ensure the SSO operates economically, technically and equitably across all NEM jurisdictions.\n\nThe Statement would not be legally binding. It expresses the AER’s regulatory position and good-practice expectations to guide DNSPs and retailers during the introduction and operation of the SSO, similar to the statement delivered during the COVID-19 pandemic.\n\n1. Expectations of DNSPs\n\n1.1 Tariff Alignment\n\nDNSPs are expected to structure residential network tariffs so that the cost of supply during the SSO window reflects periods of high solar availability, lower marginal network utilisation, and the underlying objective of daytime load shifting.\n\n1.2 Technical Constraint Management\n\nDNSPs are expected to identify areas where synchronous daytime load increases may exacerbate voltage rise, thermal limits or hosting-capacity constraints, and work with retailers to manage these risks through staggered windows or other mechanisms.\n\n1.3 Transparency and Data Sharing\n\nDNSPs should provide retailers with timely and accessible information on network tariff structures, tariff changes, and any relevant constraint patterns at feeder or zone-substation level.\n\n1.4 Tariff Stability During Transition\n\nDNSPs are expected to maintain stability in daytime and peak tariff structures during the first two years of\nSSO implementation, and avoid abrupt changes unless they clearly support customer outcomes and are communicated transparently.\n\n2. Expectations of Retailers\n\n2.1 Delivery of the SSO\n\nRetailers are expected to deliver the SSO in a manner consistent with the policy intent of extending the benefits of abundant daytime solar to households without rooftop PV and who have the capacity to load shift. Retailers should ensure customers understand the free window and the pricing of non-free hours.\n\n2.2 Retailer Flexibility in Designing Functionally Equivalent Offers\nThe AER expects retailers to have flexibility to deliver the SSO through functionally equivalent structures, provided these arrangements demonstrably meet the same policy objective of shifting consumption into periods of high daytime solar availability without exposing customers to detriment.\n\nThe AER will consider such structures compliant if they deliver materially similar or improved load-shifting and affordability outcomes relative to a fixed free window.\n\n3. Joint Expectations for DNSPs and Retailers\n\n3.1 Customer Education and Clarity\n\nDNSPs and retailers should support clear, consistent, and accessible public communication about:\n\n• the purpose of the SSO,\n• when and how the free window applies,\n• interactions with CER export pricing (where applicable),\n• how customers can load shift safely and effectively,\n• when the SSO may not be suitable for certain households.\n\n13","size":225113,"redacted":[],"meta":{"name":"Tesla_SSO_submission_redacted.9d0794d8.pdf","local_path":"files/uU1D3CR28cMLjDQolz_sqAOM.pdf","transcribe_error":null,"transcribe_status":null},"config":{}}}}}