The Final Determination on ‘National Electricity Amendment (Unlocking CER benefits through flexible trading) Rule 2024’

October 4, 2024

In a previous article, we had covered the what the ‘DRAFT National Electricity Amendment (Unlocking CER benefits through flexible trading) Rule 2024’ was proposing, as the final determination was made on the 15th of August, we have decided to revisit the topic and point out any differences to the draft and the proposed timeline of implementation.

The proposed live date for what the new rule is proposing is the 2nd November 2026.


What are the differences between the final determination and the draft?

A few changes and clarifications have been made between the two documents, some of which are from stakeholder feedback, these include:

  • NMI Service Provider Role: Initially, DNSPs were proposed to establish and maintain NMIs. The final determination assigns this role to a new accredited NMI service provider, reducing costs and implementation time. This role is equivalent to an embedded network manager role and would be provided to a contestable party.



  • Large Customer Eligibility: The final rules clarify that large customers can aggregate loads across multiple sites to meet the threshold for flexible trading, which was not explicitly detailed in the draft.



  • De-energisation Rules: The final determination prohibits separate de-energisation of secondary settlement points (SSPs – Secondary Settlement Points) to protect vulnerable consumers, a change from the draft rules.



  • Technical Requirements: Stakeholders provided feedback on metering requirements, such as the need for meters to have alternative data access methods (e.g., smartphone apps) and concerns about flow limits and accuracy. The final determination retains the draft position but incorporates stakeholder feedback to ensure practical implementation this includes ensuring that meters are accurate and capable of handling the required flow limits without compromising performance.




  • Market Participant Roles: Stakeholders expressed concerns about the complexities of compliance with dynamic operating envelopes and the allocation of tariffs. The final determination addresses these concerns by outlining clear roles and responsibilities for market participants.




Timeline of Implementation

As this is a fairly big change, there will be different stages of implementation, as such, we have provided a timeline of events below. Please note that the timeline in the ‘Final Determination’ is still a draft and will have to be finalised by the 30th September 2025. Please note that the ‘Final determination’ was a month late, so it is likely the below will be delayed.

  • 15th August 2024: Final determination made.



  • 29th August 2024: removal of the requirement for meters to have a visible display (to accommodate in-built meters with displays on an app).



  • 30th September 2025: AEMO guideline and procedure changes.



  • 31st May 2026: arrangements related to type 9 metering.



  • 1st November 2026: arrangements related to meter types 8A and 8B, SSPs, and changes to the NERR and retail contracts (the live date).


No other details are provided beyond this.


Any further questions?

If you do have any further questions or just want to discuss the determination, please get in touch at hello@vpppartners.com.


Previous article: Link

The Final Determination: Link


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April 10, 2025
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April 10, 2025
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April 10, 2025
Here at VPP Partners we are always thinking about all things energy. The energy transition and all the moving parts are complex and looking for ways to demystify the challenges and help overcome them is one of our key drivers. Recently, VPP Partners's Energy Specialist Lachlan Ryan built a model to answer a question that he had been toying with for some time. The question was along the lines of “There must be a way to create a graph that would show the required spread between charge and discharge for a BESS in the wholesale electricity market for different capital costs to meet a desired financial metric”. It was believed that this would help to demonstrate a few different aspects relating to batteries in the NEM: Understanding Capex Requirements: Enabling the quick identification of the capex ranges required to get reasonable project returns based on expected charge and discharge prices. Highlighting Value Stacking: Highlighting that value stacking with other value streams is likely needed to meet the required financial returns. Value streams and contracting: Understanding your value streams and the potential importance of contracting your assets to firm up revenue. Trading capabilities: The requirement for competent trading capabilities to realise as much value as possible from the market. Key Assumptions The model itself had several assumptions that are highlighted as follow: Target internal rate of return (IRR): 12%, 15%, 18% Round trip efficiency (RTE): 85% (losses applied to charge cycle) Annual degradation rate: 3% Depth of discharge (DoD): 90% Cycles per day: 1.5 Project duration: 15 years Interest rate: 0% (self-funded model) The Challenge of Real-World Charging Prices A critical assumption in this model is that the battery charges at $0/MWh, which means the spread is equal to the discharge price. However, in real-world scenarios, the battery won't always charge at $0/MWh, and due to the round-trip efficiency (RTE), the actual required spread isn’t straightforward. For example: A 1MWh BESS charging at $0/MWh and discharging 0.85MWh (with 85% RTE) at $100/MWh results in a margin of $85/MWh. If the battery charges at $100/MWh and discharges at $200/MWh (maintaining a $100/MWh spread), the margin drops to $70/MWh. To achieve the same $85 margin, you would need to discharge at $217.6/MWh. This led to a redefined the problem: Instead of calculating the required spread, the result was required profit per MWh for all discharged energy. This model created the graph ‘Required Profit vs Cost of BESS’, where the x-axis is the capital cost of the battery system, and the y-axis is the required $/MWh profit required for all the discharged energy.