About the Connections Reform Initiative (CRI)
In early 2020, Australian Energy Market Operator (AEMO) and the Clean Energy Council established the Connections Reform Initiative (CRI) to address concerns with delays and increasing complexity in connections to the National Electricity Market (NEM).
These complexities arise as the NEM is transforming with a greater penetration of inverter-based resources, a more diverse generation mix, and a more decentralised system.
The CRI has brought together over one hundred stakeholders from across the industry to work on a range of solutions that address the systemic concerns in the connection process.
These stakeholders include Clean Energy Council members (generators, developers, original equipment manufacturers and investors), network service providers (NSPs) and industry and market body representatives, including the Australian Energy Market Commission (AEMC), the Australian Energy Regulator (AER) and the former Energy Security Board (ESB). A senior leadership group comprising Clean Energy Council members, NSPs, AEMO and the AEMC set the CRI’s strategic direction and guide and support the implementation of priority reforms.
Neil Gibbs (from OnLine Power) was appointed as the independent facilitator to bring structure, rigour and objectivity to the process.
The CRI adopted a guiding vision for the connections process to:
- provide a connections process which is consistent, predictable and which delivers repeatable outcomes
- improve efficiency, including by reducing (eliminating) re-work, improving the quality coming into the process and addressing information asymmetry
- enable a collaborative working model between industry, AEMO and the NSPs
Connections reform roadmap
After more than seven months of collaboration, over 100 potential improvements to the connections experience were identified. They were then explored, grouped, refined and ultimately prioritised before the CRI working group recommended 11 reforms for either further detailed exploration or direct implementation.
The CRI’s leadership group endorsed the 11 reforms, as outlined in the connections reform roadmap from December 2021 linked below.
The connections reform roadmap V2 linked below illustrates the evolution of the CRI from the planning to the implementation phase.
A number of reforms identified in V2 of the road map have been implemented including:
- changes to S5.2.5.5 minimum access standards
- process to introduce changes to AEMO Guidelines
- forums and initiatives to drive collaboration
- the launch of the grid connection engineer graduate program
- a rule change for investment certainty for R1
Work on guidance on the use of Root Mean Square (RMS) and Electromagnetic Transient (EMT) tools has also been well advanced. The progress of connecting parties through the process is now regularly reported by AEMO through the connections scorecard.
Co-design and working groups
The CRI brings together stakeholders from across the industry to jointly solve complex connections challenges. We acknowledge the invaluable contributions of these businesses in allowing their people to volunteer to contribute to the CRI.
Following an expression of interest (EOI) process in early 2024, people have volunteered their time to participate in the co-design and execution of the deliverables required to progress the focus areas. Each workstream has a working group to set its strategic direction. Smaller focus groups were also established, tasked with working through the granular detail and execution of the workstream focus area. The working and focus groups have a balanced cross section of members from industry, ensuring the workstreams have a wealth of expertise to draw from to achieve positive industry outcomes.
Workstreams
Learn more about the CRI workstreams here:
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Streamlined connection process
The streamlined connection process (SCP) workstream was created to address the challenge industry faces in enabling a significant volume of new connections (as forecast by the Integrated System Plan). Under the guidance of the CRI, AEMO is project managing the review of the connection process and working with industry to co-design several focus areas within the connections process. The principles that underpin the SCP include:
● a connections process that is consistent, predictable and improves investment
● a process that is time-efficient and reduces costs, without compromising system security and operability
● fit-for-purpose scoping and assessment
● a collaborative approach between generators and developers, NSP and AEMO
● a collective commitment to problem-solving to facilitate outcomes.
The SCP is being developed through several industry working groups, project trials, industry led initiatives, in addition to ongoing process improvement. The various inputs currently being incorporated into the process are detailed below.
For more information on the SCP Trials, read more here.
In 2023 a review of commissioning practices within the NEM was completed by independent consultant, Avoca Energy. Following industry engagement and initiative reviews, the consultant reviewed and collated the feedback and learnings connected to commissioning practices. Independent consultant, DIgSILENT, was then engaged to collate the data and identify where efficiencies and/or improvement opportunities existed for incorporation into the connection process map.
The independent review of commissioning practices can be found here: Review of Commissioning Practices Document
The ideas and opportunities are being socialised across industry through various engagement channels and have formed the foundation for the focus areas of the workstream. The feedback received is continuously incorporated into the SCP Map, as the connection process is shaped through industry co-design activities.Please access the current draft SCP Map link below. The map is updated on a quarterly basis as ideas and opportunities are incorporated. Current draft SCP Map
Identified focus areas for the workstream:
The SCP workstream has progressed into the implementation phase of the initiative. As a result of industry engagement and the completion of the independent commissioning review, three focus areas were highlighted for detailed design.
● Optional pre-application phase – To explore the introduction of an optional stage prior to application, to encourage stakeholders to engage in early project collaboration with AEMO and to identify potential project issues early.
● R1 assessment – To build on the R1 investment certainty work, this focus area seeks to establish a process for an R1 connection assessment which applies a risk-based approach to assess the materiality of changes between R0 and R1 stages. It also will update the registration information resource and guidelines, as required by the AEMC’s Enhancing investment certainty in the R1 Process rule.
● Commissioning guideline – To implement changes to the commissioning process that enable plants to reach full output quickly and efficiently, without compromising system security or reliability. It will be based on a series of principles with clear testing outcomes and will provide flexibility to generators and developers.
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NER 5.3.9
The NER 5.3.9 clause sets out the regulatory change management process for assessing generating system alteration requests from generators. Following feedback from industry, it was identified by generators and developers that the clause can be difficult to interpret and apply when altering a generating system.
Under the guidance of the CRI, AEMO is project managing the NER 5.3.9 workstream, which seeks to address the NER 5.3.9 process and application challenges experienced by some generators and developers. The objective of the workstream is to reframe how the NER 5.3.9 process is applied to generating system alterations to provide a cost effective, consistent and transparent approach for all stakeholders.
In April 2023, AEMO engaged Clutch Strategic Services to undertake an independent review of the interpretation and application of the NER 5.3.9 process. The review involved understanding industry stakeholder issues and identifying potential solutions with the support of a Technical Working Group, which was made up of 26 organisations and included generators and developers, Network Service Providers, Original Equipment Manufacturers and AEMO.
You can read the final report here: Process Review of NER 5.3.9 Application – Clutch Recommendations Report
Identified focus areas for the workstream:
The NER 5.3.9 workstream has progressed into the implementation phase with a focus on three detailed design activities:
● NER 5.3.9 fact sheet – To create a factsheet about the application and interpretation of the NER 5.3.9 rules, to enhance transparency, consistency and predictability.
● Rule change – To improve flexibility and increase certainty associated with the application of NER 5.3.4A to NER 5.3.9 by reviewing application of NER 5.3.4A(b1) which requires that performance standards be as close as practicable to the corresponding automatic access standard.
● Legacy plant support – To address barriers posed by NER 5.3.9 modelling requirements to legacy plant that propose generating system alterations, particularly alterations relating to the connection of BESS behind the existing connection points.
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Original equipment manufacturer (OEM) data and modelling
Discussions held in the CRI in 2021 highlighted an opportunity to improve information fidelity, quality and consistency of original equipment manufacturer (OEM) data and models provided during the application stage of a project. Following this, the OEM data and modelling workstream was established to investigate how best to work through model related issues. At present, the CRI project team is working with the OEM data and modelling working group to identify whether an early assessment framework (EAF) process could be implemented before models are submitted during the connections process. Establishing an EAF aims to:
● improve information fidelity resulting in more realistic models and simulations
● reduce time and cost during the connections process
● create fair opportunities for all OEMs
● establish an overall trust in industry on current and emerging technologies
The workstream is currently in the ideation and development phase, co-designing with OEM representatives on the structure of the EAF, and identifying critical design considerations that need to be worked through to make the product possible. Engagement with NSPs will commence shortly for their critical buy-in and to the overall success of the EAF.
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R1 investment certainty
During discussions held in the CRI, industry raised concerns that the National Electricity Rules (NER) were unclear regarding what modelling and additional analysis could be requested of generators and developers during the ‘R1’ phase. R1 is the period between the project’s financial commitment (following the execution of the connection agreement) and the commencement of revenue (following registration and commissioning). The R1 investment certainty workstream was formed and led by the Clean Energy Council to investigate and draft a rule change request to the Australian Energy Market Commission (AEMC).
On 17 May 2023, the Clean Energy Council submitted the enhancing investment certainty in the R1 process rule change request to the AEMC. The request sought to drive investment certainty by clarifying the process and responsibilities for the assessment of a generator’s ability to meet its performance standards as a requirement of market registration – known as the ‘R1 process’.
The Clean Energy Council collaborated extensively with developers and generators, investors, network service providers (NSPs) and AEMO, as well as experts from KPMG, to understand the key challenges in the R1 process and to establish workable solutions to them.
Key elements included in the Clean Energy Council's request were to:
● provide generation applicants with more certainty on the process (including timeframes) for AEMO and NSPs to assess a generator’s detailed design and R1 modelling packages (R1 package) and for AEMO to approve the project’s registration.
● increase transparency by requiring justification from NSPs and AEMO where additional information or modelling requests were made.
● enable more efficient allocation of risks and costs between NSPs and generators to manage system security risks identified at the R1 stage.
● remove barriers to a NSP and AEMO agreeing to alterations to the generator performance standards in the connection agreement, by clarifying where such changes were likely to have no material impact on system security.
● introduce a new facilitated review process to manage intractable issues that emerge between generators, NSPs and AEMO.
● clarify the process for conditional registrations.
After making substantial changes to its draft determination and draft rule to incorporate feedback from the Clean Energy Council, AEMO and other stakeholders, the AEMC published its final rule on 27 June 2024. The final rule and determination can be found on the AEMC’s website: Enhancing investment certainty in the R1 process
The final rule:
● removes barriers to sensible revisions of a generator's performance standards.
● clarifies the obligations of all parties during the R1 process.
● requires AEMO to outline the process for assessing the capability of a generating system to comply with its agreed generator performance standards (capability assessment) in updated registration information resource and guidelines. AEMO will consult with stakeholders and update the guidelines in the SCP R1 assessment workstream. The guidelines will outline:
○ data and information to be provided to AEMO and the NSP when submitting the R1 package.
○ examples of the circumstances in which AEMO or the NSP may request additional data and information from a connection applicant, as well as examples of the types of data and information the connection applicant may provide in response.
○ how AEMO may assess, and the matters taken into account, when assessing the R1 package, and whether the connecting plant may have an adverse effect on power system security or the quality of supply for other network users.
● formalises the commencement and conclusion of the R1 process through timely notifications by AEMO.
● clarifies that AEMO can conditionally register generators and integrated resource providers. AEMO must first consult and produce guidance on when this may be appropriate through updating its registration information resource and guidelines.
● requires AEMO and NSPs to provide written reasons why additional data and information is requested during the R1 assessment. Additionally, the connection applicant may request further clarification (which AEMO or the NSP must provide within five business days of receiving that request).
● introduces a 60 business day timeframe, from the commencement of the capability assessment, for AEMO to either inform the applicant that the capability assessment is satisfactory (conditionally or unconditionally), or if not, provide an update on the next steps for the assessment.
The AEMC in its final determination notes that the registration information resource and guidelines should set out how AEMO assesses power system issues due to factors that may be external to the connection applicant’s plant. The Clean Energy Council and AEMO will work collaboratively through the CRI to explore ways for NSPs and AEMO to coordinate works which deliver lower cost solutions to system strength or other technical issues.
The rule change came into force on 11 July 2024. AEMO is required to update its registration information resource and guidelines by no later than 1 March 2025.
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Graduate program
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