Submission to Technical Standards for Consumer Energy Resources Interoperability (T1)

The Clean Energy Council (CEC) welcomes the opportunity to provide feedback to the Department of Climate Change, Energy, the Environment and Water’s (DCCEEW) Technical Standards for Consumer Energy Resources (CER) Interoperability Consultation Paper.

The CEC supports in principle the establishment of a performance baseline to guide interoperability requirements across the CER ecosystem. A Framework prototype can support a more informed outcome for minimum performance standards for interoperability as it can:

• Provide clarity on regulatory design and expectations: The National Technical Regulatory Framework prototype lays out functions, roles, interfaces, and necessary boundaries. Without such a prototype, stakeholders in the interoperability paper risk ambiguity in how performance requirements will be applied, who will enforce them, and how trade‑offs are handled.
• Generate stronger stakeholder engagement: A prototype allows external stakeholders, including OEMs, service providers, network operators and consumer groups to review what the proposal might look like in practice, and comment meaningfully. This leads to better design, more realistic performance requirements and fewer unintended consequences.
• Better align across T1 & T2 priorities in the CER Roadmap: The CER Roadmap sets out two linked priorities: T1 (interoperability technical standards) and T2 (national technical regulatory framework). A prototype in T1 would help ensure design of the standards anticipates the regulatory regime in T2, making implementation smoother and costs lower.
• Improve risk mitigation: Prototyping allows testing of assumptions (technical, economic, operational). It assists to reveal interoperability challenges (communication, data security, device control rights, switching between providers and local interactions) before requirements are fixed or mandated.