Nexa Advisory welcomes the opportunity to respond to the Australian Energy Regulator’s consultation paper on the 2027 review of the Customer Export Curtailment Value (CECV) methodology.
Nexa supports improving the way the value of consumer energy resources (CER), exports and flexible demand is reflected in energy-system decisions. The CECV should, however, remain a means to an end: supporting efficient decisions in the long-term interests of consumers. It should not become a mechanism that makes additional network expenditure easier to justify, nor should its application create a presumption in favour of a particular approach to controlling or orchestrating customer-owned CER.
Importantly, the existence of a methodology for valuing curtailed exports should not itself normalise ongoing curtailment. The CECV should assist decision-makers to compare the available options for integrating CER efficiently, including network augmentation, improved operating practices, flexible export arrangements, tariffs and competitively provided flexibility.
Key recommendations
Nexa recommends that the AER:
- ensure that CECVs remain solution-neutral and do not create a presumption in favour of persistent export restrictions, distribution network service provider (DNSP) -controlled orchestration or network augmentation;
- distinguish between a DNSP’s role in defining transparent technical network limits and the commercial orchestration of customer-owned CER within those limits;
- require claimed benefits to be real, realisable by electricity consumers and free from double counting, and make clear how gross system value translates into benefits for consumers;
- apply a common marginal-cost framework to avoided curtailment and flexible demand, while recognising that demand shifting requires an intertemporal counterfactual rather than being treated simply as demand reduction;
- adopt a fit-for-purpose approach to the zero floor, retaining it where appropriate to the CECV’s application and allowing negative values where necessary to reflect marginal system costs;
- keep avoided or deferred network expenditure separate from the regional wholesale CECV, with transparent and sufficiently locational estimates developed by DNSPs under consistent AER guidance;
- retain emissions as a separately published value profile;
- require expenditure proposals to demonstrate genuine additionality against an efficient business-as-usual (BAU) case, including relevant tariffs, operating envelopes and other measures that can make better use of existing hosting capacity;
- retain the full half-hourly CECV series, supplemented where useful by simpler summary information;
- retain Option 1 for applying CECVs, subject to appropriate alignment between the assumptions underlying the CECVs and DNSP alleviation profiles; and
- support the AER developing in-house CECV modelling capability, with annual re-estimation the default where this becomes reasonably low-cost.
Read our full submission here: Nexa Advisory submission – AER 2027 Review of the CECV methodology