Nexa Advisory welcomes the opportunity to respond to the AEMC’s Integrated distribution system planning (IDSP) Directions Paper.
Nexa has consistently argued that the DAPRs are no longer fit‑for‑purpose in a system that needs integrated, state‑wide planning. DNSPs possess monopoly access to critical network data, including locational information and hosting capacity constraints which is critical to the deployment of CER.
We are concerned that the proposed seven-year implementation window opens this work to considerable risk which may result in the completed framework completely missing the policy intent.
We do not believe the AEMC’s proposed IDSP approach adequately addresses the near-term imperative to improve transparency of CER hosting capacity and other network data.
To achieve the intended objectives of this rule change, we recommend the AEMC to:
- prioritise near-term, interim solutions – such as immediate reforms to the DAPR template or through the introduction of ‘mini-DAPRs’ to enable achieve network information transparency for C&I CER, EV and EVCI uptake, demand-side response and flexibility services;
- work with AEMO to build on their approach of implementing the DSF Information Guidelines – with a view of long-term alignment with the IDSP;
- leverage the upcoming Review of the ISP to improve how the ISP incorporates CER and demand-side factors; and
- work with the AER to minimise ongoing, duplicative changes to performance reporting requirements.
Read our submission here: Nexa Advisory submission – AEMC IDSP Directions Paper