The Australian Competition and Consumer Commission (ACCC) recently released a Consultation paper on data access models for energy data.[1]
The Consumer Data Right (CDR) regime, provides individuals and business with a right to conveniently access specified data in relation to them that is held by businesses. It is intended to improve consumers’ ability to compare and switch between products and services and thereby increase competition. It is currently being rolled out in the banking sector but has been scheduled to roll out in the telecommunications and energy sectors for a while now.
By Dr Drew Donnelly, Compliance Quarter
A key difference between roll-out in the banking and energy sectors is the diverse range of entities that hold relevant information in the latter sector, including retailers, distributors, embedded network operators and the market operator (AEMO). In some respects, this makes the choice of data access model in the energy sector more complex.
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Types of data
There is a range of data that is proposed to be subject to the CDR in the energy sector. This includes:
- National Metering Identifier (NMI) Standing Data. This substantial dataset logged in the market operator’s MSATS system contains a range of identifying information and information relating specifically to the connection including NMI, network tariffs, transmission node identities, average daily load and the presence of controlled loads;
- Customer Provided Data. This is any data submitted by the customer themselves;
- Metering Data. This data, collected by Metering Data Providers (MDPs) records the actual energy use at the premises;
- Billing Data. This data is held mainly by the retailer;
- Product Data. This is general information relating to energy products/plans;
- Distributed Energy Resources Register. This relates to equipment like solar energy resources or batteries that are connected to the grid.
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The three models
The dispersion of energy information across different entities means that there are several broad models being considered for implementation.
- Model 1: the AEMO centralised model – AEMO would be the sole data holder of a centralised data set and would provide CDR data directly to accredited data recipients.
Figure 1: https://www.accc.gov.au/system/files/ACCC%20consultation%20paper%20-%20data%20access%20models%20for%20energy%20data.pdf., p26.
- Model 2, the AEMO gateway model – AEMO would provide a gateway function to facilitate the transfer of data from data holders such as retailers, distributors and AEMO itself to accredited data recipients.
Figure 2: https://www.accc.gov.au/system/files/ACCC%20consultation%20paper%20-%20data%20access%20models%20for%20energy%20data.pdf, p29.
- Model 3, the economy-wide CDR model – existing data holders (for example, retailers) would be responsible for providing CDR data directly to accredited data recipients.
Figure 3: https://www.accc.gov.au/system/files/ACCC%20consultation%20paper%20-%20data%20access%20models%20for%20energy%20data.pdf, p31.
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Comment
There is a range of advantages and disadvantages to each model that are canvassed in the paper itself. Some important general points to note include:
- The first or second options would require significant changes to the National Electricity Law, National Energy Retail Law, associated rules and regulations and jurisdictional legislation to alter the role of AEMO and its access to information;
- It is an open question how and when customers sold energy in an embedded network by an exempt on-seller/authorised on-seller would get access to their data as their data is not held by AEMO or market participants. Current plans to further regulate embedded networks do not include a proposal for retailers/embedded network service providers to collect the same data on embedded network customers as traditional retail customers;
- The CDR will not initially apply to gas data-sets but it is intended that the regime will extend in this direction in the future.
Submissions on the paper are due 22 March at https://www.accc.gov.au/focus-areas/consumer-data-right-cdr/energy-cdr/consultation-on-energy-data-access-models.
[1] See https://www.accc.gov.au/system/files/ACCC%20consultation%20paper%20-%20data%20access%20models%20for%20energy%20data.pdf.
