Submissions due 8 April 2021 – WDRM Baselines Eligibility Compliance and Metrics Policy Consultation (Stage 2)

In this short article on 11th January, we noted AEMO was seeking submissions Links to Dan’s article noting the call for first stage submissions at Stage 1 of the consultation into Baseline Eligibility Compliance and Metrics as part of the WDRM (Wholesale Demand Response Mechanism), which commences 24th October 2021.

(A)  Submissions received

In response to the AEMO’s call, there were 6 submissions received, from:

1) AGL Energy on 8th Feb 2021, noting the proposed baseline method ‘has struck the right balance..

… but warns that

‘AEMO should therefore provide guidance to the industry as how registered DR units could be affected by changes to these settings, such as whether grandfathering eligibility arrangements for registered DR units will apply. ‘

… and also has comments about the shift in timing of peak pricing (as discussed on WattClarity on several occasions).

2) Enel X  on 4th Feb 2021, which seems to say that not enough detail was provided to make significant comment possible.

3) ERM Power (now Shell Energy) on 5th Feb 2021 in which they note they ‘strongly disagrees with AEMO’s proposed accuracy metric of 20 per cent for baselines under the
Wholesale Demand Response Mechanism (WDRM)’

4) Green Energy Trading on 5th Feb 2021 suggests ‘that this methodology be based upon a transparent, rules based method such as the International Performance Measurement and Verification Protocol (IPMVP).’ with the objective being to increase the amount of Negawatts that are eligible.

5) Infigen Energy on Unknown Date notes that ‘20% RRMSE threshold is relatively high, but it increases participation markedly. We accept the WDRM, but have the view that moving to a two-sided market would be preferred ‘.

6) Public Interest Advocacy Centre (PIAC) on 5th Feb 2021 ‘supports AEMO proposing an accuracy threshold of 20%, above that considered ‘good’ in the RERT.’


(B)  Draft Report and Determination

Following consideration of these submissions, the AEMO published these second stage consultation documents on 18th March 2021:

Draft Report and Determination Draft Baselines Eligibility Compliance and Metrics Policy
Clean Version

Click on the image (or here) to open.

Click on the document (or here) to open.

Further information (currently) about these AEMO processes are on the AEMO website at this location.

Submissions in response to this Notice of Second Stage of Rules Consultation should be sent by email to, to reach AEMO by 5.00pm (Melbourne time) on 8 April 2021.


(C)  Discussion on WattClarity ®

Over on WattClarity today, Linton Corbet has explored how the baseline policy would apply to some typical shapes in ‘Will your 10 out of 10 baseline be eligible?’.


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