Nexa Advisory welcomes the opportunity to share our views and insights on AEMO’s Demand Side Factors (DSF) Information Guidelines.
We agree with the overall premise to improve the transparency of distribution network data to inform both joint system planning by AEMO, and to support investment decisions by third-party Consumer Energy Resource (CER) providers – such as CER aggregators, and Electric Vehicle Charging Infrastructure (EVCI) providers.
We consider that the benefits of transparent DSF information include: lower system costs (the competitive market can propose non‑network solutions), faster deployment of CER and public EVCI, more credible ISP assumptions and stronger consumer trust.
As such, the primary objective of this DSF Guideline should be to improve transparency over network data.
DNSP data provided to inform DSF Information must be made public to support competitive third-party investment by CER aggregators and EVCI providers.
We encourage AEMO to work with the AEMC and DNSPs to consider how reporting duplication can be minimised across these channels if implemented. This would minimise compliance burden and improve data quality and consistency across the National Electricity Market (NEM).
The introduction of interim updates or ‘mini-DAPRs’ that focus on emerging issues such as CER integration, EV uptake and flexibility services would address this duplication, consolidating these channels into one. This should be consistent and relevant across DNSPs.
We also encourage AEMO to publish underlying network data as soon as practicable, rather than at the next ISP milestone. Additionally, AEMO should work with the AEMC and DNSPs to determine the best channel through which this information can be shared more regularly.
Read our submission here: Nexa Advisory submission – Demand-side factors guidelines