CASE STUDY: EUAA Successfully Influences AEMC’s Integrating Price Responsive Resources (IPRR) Draft Determination
Emily Wood | January 20, 2026
BACKGROUND
In 2024/25 AEMO had become increasingly concerned about its ability to effectively balance the grid due to the enormous volume of Consumer Energy Resources (CER) such as rooftop solar and batteries being deployed. These resources sit behind the customer meter and are therefore essentially invisible to the market. AEMO also considered other energy hungry equipment such as pool pumps and reverse cycle air conditioners and the potential role they could play in times of high demand.
For industry, AEMO were looking at what degree of flexibility is available via commercial scale refrigeration and industrial heating, ventilation and air conditioning (HVAC) systems.
Due to its requirement to keep the lights on, AEMO understandably wanted more visibility and control of ‘invisible’ equipment that either generates electricity or consumes large volumes of energy.
MARKET RULE CHANGE PROPOSAL
The AEMC proposed a rule change to give AEMO more visibility and control over Consumer Energy Resources (CER) – rooftop solar, air conditioners, pool pumps, commercial refrigeration and anything else that can be switched on and off with little economic impact.
AEMO asked for a range of actions to be included in the rule change including compulsory metering of devices, control of the devices from the NEM control room and strict requirements for participants.
EUAA ACTION
Concerned about the negative impacts (including increased cost) on commercial and industrial customers of AEMO’s requests in the proposed rule change, the EUAA provided feedback via a submission with its rationale along with other suggestions that would still meet AEMO needs without the impact on large C&I.
In response, the AEMC’s first phase of the rule change process (Integrating CER into the NEM), determined that additional NEM meters would be beneficial in large energy user premises and that large energy users could engage a second financially responsible market participant (FRMP) – a retailer, aggregator or demand response agency.
EUAA’s view was that this still appeared to lead to poor outcomes for large energy users so we continued our dialogue with AEMC.
The AEMC’s second phase of the CER rule change (Integrating Price Responsive Resources into the NEM), influenced AEMC to develop a very flexible CER rule, with most of the EUAA’s recommendations making their way into AEMC’s Draft Determination.
OUTCOME
Through our advocacy with the AEMC, the EUAA has been able to influence the outcome of a rule change that will still benefit AEMO but will not have dramatic negative impacts on large C&I.
The AEMC’s proposal now provides a level of simplicity and flexibility for C&I consumers while maintaining the veracity required by AEMO.
Changes that were adopted as a result of EUAA advocacy include:
1. It is 100% voluntary to participate
2. Making the rules under the Unlocking CER benefits through flexible trading rule change optional for CER participants. This means that it is now optional to install a secondary National Meter Identifier (NMI).
3. Has enough flexibility built into the proposed rule to allow different operational and functional models for different Voluntary Scheduled Resources (VSRs) and Voluntary Scheduled Resource Providers (VSRPs):
- will be the aggregate NMI response for participants (i.e. some NMIs may increase consumption, while others decrease consumption and the net impact will be used to determine if the participant has complied with dispatch instructions).
- Has flexibility in the level and timing of participation through: Voluntary deactivation for up to 7 days, allowing for maintenance activities; Voluntary hibernation for up to 18 months, allowing for seasonal participation; or Deregistering as a VSR if choosing to exit the IPRR.Registered participants in dispatch mode will have their Reliability and Emergency Reserve Trader (RERT) liabilities waived for the period spent in dispatch mode (RERT liabilities will resume during deactivation or hibernation and on deregistration).
- Registered participants in dispatch mode will have their Reliability and Emergency Reserve Trader (RERT) liabilities waived for the period spent in dispatch mode (RERT liabilities will resume during deactivation or hibernation and on deregistration).
- Participants can also participate in other markets, for example FCAS and RERT.
- Participants can receive Frequency Performance Payments, but will be exempt from Primary Frequency Response.
- That a one-time fund of $50 million will be available from 2027 until 2031 for approximately 100-200 foundation participants.
- That AEMC considered and rejected the Visibility Mode proposed by AEMO on the basis that it creates an extra barrier to participation.
- Most Importantly, and something we have been advocating for a while, is AEMO and AER now have operational reporting requirements to improve forecasting which will reduce forecasting mistakes, which can require directions and is costly for consumers.
The EUAA considers that the AEMC has struck a good balance between the rule change requested by AEMO and the needs of the market, including commercial and industrial (C&I) consumers as advocated by EUAA.
This is an example of the work done by the EUAA to benefit members. To find out more about what we do, or to enquire about becoming a member, please contact kyllie.mcmullen@euaa.com.au