Finally!! … A Major Review that sees (more closely) what’s actually been happening with Demand Response!

In reviewing the draft Report from the Nelson Review, it was a pleasant surprise to read statements (p83/239) such as this:

Extensive engagement by the Panel with C&I users, their retailers and aggregators demonstrates that a significant amount of demand response is already occurring.’

 

Why is such a statement such a surprise (and, indeed, a pleasant surprise)?

Well, it’s certainly not because this is anything new in the NEM:

1)   … indeed:

(a)  for 20 years or more, there has been a sizeable amount of demand response occurring.

(b)  and (my sense is that it’s) been increasing in more recent years

2)  We know this (at least in part):

(a)  because we’ve been assisting energy users with a particular form of Demand Response (type 2 in the diagram below) for over 20 years.

(b)  We reflected on this (over 6 years ago … back on 3rd January 2019) when we wrote ‘Some highlights on our Demand Response journey (to 31 Dec 2018)’at which time over 15 years into our journey of assisting energy users.

 

Why was it not so widely recognised in the past?

However this was not as widely understood as it should have been … and, unfortunately (my sense has been for many years) that:

1)  some stakeholders saw it in their own commercial self-interest to propagate misleading statements about the state of Demand Response in the NEM:

(a)  i.e. in order to advocate for some changes to NEM Rules to open up opportunities for their business model;

(b)  witness Barrier (1d) in the follow on article ‘Real Barriers we’ve experienced in the growth of Demand Response in the NEM’ that we also wrote over 6 years ago (on 7th January 2019).

2)  It seems to me that the perverse ‘success’ of these motivations was compounded when some commentators and journalists fell for those misleading statements – hook, line and sinker.

… witness Barrier (1e) in the same article.

That’s what prompted several articles over time about this, such as:

1)  On 25th November 2017 in ‘It’s complete baloney to claim that there’s “less than 1%” of peak demand in the NEM that is currently providing Demand Response’.

2)  And on 5th March 2019 we wrote about ‘Villain #5d – obsessing about Negawatts, when the real objective is (broader) Demand Response’

(a)   as one example of a broader theme of Villain #5

(b)  which we defined back in 2019 as not focusing on the real problems (a.k.a Villain no5) ….

WattClarity-Villain-no5-WrongFocus-600

So let’s celebrate someone seeing it more like it actually is (and has been)!

… and so that’s why it’s so pleasing to see the significant amount of demand response already occurring’ recognised in the draft report of the Nelson Review (but unfortunately Villain no5 has not been totally avoided there, in our view – more on that later).

I’m guessing that the ‘extensive engagement’ (and listening with an open mind) really helped the Nelson Review Panel members to see a fuller/clearer picture of what the underlying situation actually is … rather than either:

1)  just speaking to a smaller select group (which others seem to have done in the past).

2)  or perhaps just dismissing as ‘well they would say that’ any input provided by those who were already achieving some successes with the pre-existing forms of Demand Response.

So congratulations on that note!

 

A reminder of some of the forms of Demand Response we’ve encountered

With the comments that follow (in this article and in articles to come) it’s probably worth summarising the types of Demand Response we’ve encountered over our >20 year demand response journey in the NEM:

Remember that (as illustrated here) Demand Response:

1)  Is one of the two legs that sit under ‘Demand Management’, with the other leg relating to Energy Efficiency

2)  With the ‘Demand Response’ leg representing the different ways that an energy user might temporarily adjust their consumption in response to some incentive:

(a)  Historically, this might have been thought of in relation to reductions in load in response to some price (or other) signal;

(b)  But its important to remember (in this age of negative prices) that demand response can (and arguably should) also entail increases in consumption at other times (e.g. times of negative prices).

Here’s some of the ways that we’ve encountered over the years:

 

Type of Demand Response Approach Brief Description

Type 0) no Demand Response

For completeness, worth adding in here a “type 0” that represents all of the energy users that don’t currently participant in Demand Response of any type.

Type 1) Scheduled Load

Since the start of the NEM, there has been a registration category that of Scheduled Load.

In the early days of battery operations, they were required to registered as a pair of units:

  • An [DUID-PREFIX]G1 unit as a Scheduled generator;
  • plus an [DUID-PREFIX]L1 unit as a Scheduled Load.

… but since the IESS rule change implementation, they have been transformed into Bi-Directional Units (BDUs).

That leaves the only remaining Scheduled Loads being the pumping side of the (currently) 3 x pumped hydro units operating in the NEM … with Kidston coming before too much longer (and then others after that, we hope).

Type 2) Spot Exposure

2a) as Wholesale Market Customer

Different than the ‘Scheduled Load’ is a registration category of ‘Wholesale Market Customer’, which allows for the Market Customer to buy power directly from AEMO’s wholesale market.

In the AEMO’s current list of Registered Participants (i.e. downloaded today):

  • There are 116 entities listed as ‘Market Customer’
  • But keep in mind that …
    • this classification (also/primarily) covers those entities who buy (on spot) from the wholesale market in order to on-sell to their customers in the retail market (i.e. retailers)
    • Quickly eyeballing the list (so noting that I probably missed some) I counted 10 on the list that I’d classify as large energy users who would be consuming all of what they buy on the spot market.

2b) via a Retailer

But registering as a Wholesale Market Customer only tends to suit some of the largest energy users, in part because of the AEMO’s requirements for registering (prudentials, payment terms, etc)

It’s far more common (and has always been this way) that energy users engage some retailer to offer them some permutation of spot price pass-through in their retail contract.

In our focus at the C&I end of the spectrum, we’ve come across a wide range of types of approach, including:

  • Covering just some loads and not the whole site or portfolio;
  • Potentially only for specific periods of time (or with respect to other conditions);
  • With other types of hedging available (and sometimes used) on top.

In more recent years, we’ve seen retailers operating at a more residential level also offer spot-price pass-through arrangements for their clients.  A topical example is that of Amber Electric, which gained a mention in Jared’s article ‘Australia’s Amber Electric lands $10m investment to help UK homes control consumption’ in the Australian today – which I mention because it included the note:

‘Launched in 2017 by Mr Thompson and Dan Adams (a former Tesla and Boston Consulting Group executive), Amber has become Australia’s dominant provider of residential solar and battery automation, securing more than 40 per cent of the domestic market.’

… which is important because:

  • It highlights that Amber is a significant player in this space
  • But not the only one.

It’s worth also noting that (in speaking at the 2025 EUAA Conference) I commenced a review of this traditional form of Demand Response:

Type 3) Negawatts

3a) via a Retailer

Type 3a is different from Type 2b in that (in this instance) the retailer might have some form of agreed fixed price agreement with a retail energy user – but with this including some form of ‘call option’ (which might be firm, or not firm) that

  • gives them the ability to call on that energy user (at times of the retailer’s choosing) to ask the energy user to reduce consumption for a specified period of time
  • if the energy user is able to do this, then the energy user receives some specific benefit from the retailer for that instance of the response (which might be as simple as some percentage of the ‘avoided spot cost’ represented by the negawatt curtailment).

Type 3a has always existed in the NEM, since the start of the NEM … and there are some high profile examples of this.

3b) Centrally Dispatched

There have been two stages in the evolution of this approach:

Type 4) ‘Out of Market’ Demand Response

4a) via Reserve Trader (RERT)

For readers here on WattClarity® the most obvious type of this ‘out of market’ demand response falls under the ‘Reserve Trader’ category (a.k.a. RERT).

4b) via AEMO/Government Requests

But it’s also useful to keep in mind that a broader type of this response is the type of response that occurs when the AEMO and Governments ask the general public for some form of restraint/response at times of system stress (thankfully that happens rarely).

4c) New Forms?

Also worth noting that the Nelson Review draft report has spoken to an interest in other forms of ‘out of market’ peaking plant … though not necessarily related to Demand Response.

Type 5) ‘Dispatch Mode’ via IPRR

‘Active VSR’

On 19th December 2025, the AEMC published its Final Determination into Integrating Price Responsive Resources (IPRR) into the NEM.

(a)  There’s a category established on WattClarity about IPRR into which we’ll add articles over time.

(b)  It calls for a new ‘Dispatch Mode’ to commence in May 2027.

This reform process was formerly called ‘Scheduled Lite’.  The final determination was made by the AEMC back in December 2025 but (at least in part because commencement is >18 months away, and we have many other things to work through in the meantime) we’ve not had time to really read through the details.

But I do note in the draft report of the Nelson Review that Recommendation #2 references this change and even seems to advocate for a change to the voluntary nature of this classification?

‘Inactive VSR’

Under ‘Inactive Mode’ (or when Hibernated) no Demand Response would be provided.

 

 

But a caution about what the Nelson Review is recommending?

From p79/239 of the draft report of the Nelson Review, recommendation 2 is discussed.  This reads:

‘Recommendation 2: Energy ministers should require a broader range of price-responsive resources to be visible or dispatchable to participate in price formation’

We’ll discuss (in a subsequent article) our concerns about some of what’s recommended here…

2025-09-30-NelsonReview-Recommendation2


About the Author

Paul McArdle
Paul was one of the founders of Global-Roam in February 2000. He is currently the CEO of the company and the principal author of WattClarity. Writing for WattClarity has become a natural extension of his work in understanding the electricity market, enabling him to lead the team in developing better software for clients. Before co-founding the company, Paul worked as a Mechanical Engineer for the Queensland Electricity Commission in the early 1990s. He also gained international experience in Japan, the United States, Canada, the UK, and Argentina as part of his ES Cornwall Memorial Scholarship.

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