WDRM Trial Waivers – VIOTAS and Enel X

To facilitate trials of participation by sites with multiple connection points in the Wholesale Demand Response Mechanism, VIOTAS and Enel X have sought waivers from clause 2.3.6(m)(1)(i) of the National Electricity Rules (NER). This clause only permits single connection point sites to participate in the Wholesale Demand Response Mechanism; thereby restricting participation where a site has multiple connection points. This restriction exists due to ‘gaming’, that is, because such sites could artificially lower usage at one classified connection point, while increasing it at others, resulting in being unduly paid for demand response services that were not provided.

The trial waivers provide temporary relief from this restriction, allowing VIOTAS and Enel X to test whether sites with multiple connection points can participate in the mechanism using existing baselining and settlement approaches. As part of the trials, both proponents have outlined how potential risks, including the risk of gaming and settlement impacts, will be managed through conditions relating to trial design, monitoring and reporting. These conditions are summarised below, and detailed further in the trial waiver applications and the AER’s decision documents.

The waivers are subject to a set of binding conditions designed to ensure the trials maximise learnings, while addressing issues raised through consultation and safeguarding market, system and consumer outcomes.

The conditions imposed on VIOTAS and Enel X are identical and were developed through assessment and consultation.

The trial conditions include:

• Site limits: Each trial participant is limited to a maximum of 10 trial sites to manage impacts on the wholesale market and AEMO systems.
• Phased registration: Applications to classify sites must be submitted to AEMO on a phased basis (up to 2 per week) to mitigate operational impacts.
• Site configuration transparency: Proponents must provide up-to-date single line diagrams for each site, identifying all connection points and metering arrangements, and update these where material changes occur.
• Site selection and approval: Proponents must provide detailed information about each proposed site and obtain AEMO endorsement before progressing classification. Any disputes are to be resolved by the AER.
• Performance and compliance: AEMO may declare a site non-conforming following a dispatch outcome. Proponents must notify the AER of such events and manage site participation accordingly.
• Consistent registration arrangements: All connection points at a site must be registered under the same Demand Response Service Provider , share the same baseline methodology, and have the same Financially Responsible Market Participant or retailer.
• Reporting and validation: Proponents must provide six-monthly public reports to the AER, AEMO and the AEMC, including information on participating sites, dispatch activity, performance outcomes, and key learnings.
• Early site registration: At least two sites must be classified within six months of the trial commencing to ensure timely availability of learnings.

Consumer protections: Proponents must notify site owners or operators that participation is part of a trial and outline associated risks. Embedded networks and residential electricity consumers are excluded from participation.

These conditions are set out in full in the AER’s final decision documents and are intended to ensure the trials generate robust, transparent and timely evidence to inform future reforms to the Wholesale Demand Response Mechanism.