Summary

  • AEMO’s draft treats visibility and dispatch participation as different tools; it does not propose putting every flexible resource through one mandatory sequence.
  • The separate pre-dispatch sensitivity would initially remain unpublished. Phase 1 would test whether it improves market information and how it could be published in Phase 2 without compromising the base price signal.

A forecast can become part of the market

Households with batteries, storage aggregators and large industrial loads can respond to wholesale prices outside central dispatch. Their combined response may change between events. AEMO says that when material behavior is coordinated but not visible in advance, forecast error can weaken pre-dispatch and dispatch decisions, complicate reserve planning and raise costs. Those are the risks set out in a consultation paper, not a finding that a particular incident produced them.

The harder design question is circularity. Participants use pre-dispatch prices to decide when to charge, curtail or shift consumption. If the forecast incorporates their expected response, the resulting price estimate may alter the behavior being forecast. AEMO proposes keeping the base pre-dispatch run as the central price signal and creating a separate sensitivity that shows how conditions could differ if material price-responsive behavior occurs. It would not be published initially, but would give AEMO additional decision-useful information about demand, prices, reserves and operating conditions.

In Phase 1, AEMO would test whether it improves market information, whether submitted information is accurate enough to use, how uncertain information should be derated, and how the sensitivity could be published in Phase 2 without compromising price signals.

Four tools, not four compulsory steps

The September 2026 paper proposes four visibility and participation modes. Observational visibility uses existing or historical information to improve statistical understanding. Predictive visibility would supply forward-looking information for coordinated, material portfolios; more than 30 MW is an initial indicator under discussion, not a settled obligation. Operational visibility could apply to resources that are large, flexible or otherwise significant in real time; more than 100 MW is an example, not a final threshold. Dispatch-integrated visibility could use existing or future scheduling, dispatch or registration mechanisms.

AEMO describes these as tools, not a ladder every resource must climb. The draft does not switch them all on at launch. It proposes a first phase to improve forecasts, make better use of existing data and test selected information channels. A later predictive duty would depend on whether data can be used in operations and produce measurable benefits. Operational obligations would be considered if growth and coordination left a material visibility gap.

This makes the draft a decision architecture as much as a data proposal. It reserves authority to activate stronger duties but places evidence, stakeholder feedback and consumer value between capability building and compulsion. AEMO asks whether thresholds should start high and be lowered only if adverse impacts persist, how aggregation should count, and whether the responsible party should be a site operator, aggregator, retailer or financially responsible participant.

Where accountability should sit

An obligation attached to a meter may miss the party that coordinates a portfolio. A rule attached only to a registered participant may make that participant accountable for behavior it cannot observe. The answer depends on who controls the response, who holds useful data, and whether AEMO can validate it in time to improve a forecast. The consultation expressly asks stakeholders to test those choices.

The same test applies to consumer value. Visibility can improve system decisions, but reporting systems and compliance have costs. AEMO proposes to build evidence before activating detailed obligations and asks how that value should be assessed. Submissions are due by 5 pm AEDT on 13 October 2026; the operator plans final recommendations to Energy Ministers in December. The framework remains a draft, not a current reporting rule.

The outcome to watch is whether a stage gate is operationally meaningful: a defined accuracy threshold, tested data quality, demonstrated effect on forecasts and an explicit comparison of consumer benefit with the cost of participation. Without those records, a temporary visibility tool can become a permanent duty by inertia. With them, the NEM can distinguish resources that matter to system operation from those that merely respond to a price.

Sources