Matters under consultation 
Following an AEMC rule change made on 7 March 2024 (Clarifying mandatory primary frequency response obligations for bidirectional plant), AEMO consulted on required updates to the Primary Frequency Response Requirements in accordance with clause 4.4.2A of the National Electricity Rules.
The following changes have been made to the PFR requirements:
- The terminology has been updated to include terms “Affected Provider”, “Affected Unit”, “Deadband” and “IRP” to align with the rule change, the first part of which will take effect from 3 June 2024 alongside the commencement of the Integrated Energy Storage Systems (IESS) Rule.
- Section 2.3 has been revised to reflect further changes that will come into effect from 8 June 2025.
- Section 6.6 clarifies that Affected Units will not be required to provide PFR (though may choose to) when managing plant within State of Charge (SoC) limits.
- Following feedback from stakeholders after the publication of the draft PFR requirements documents, Section 2.3.2 has been updated to clarify that an Affected Unit may also provide PFR (but is not required to do so) when idle (at rest at 0 MW).
Consultation process 
Under NER 4.4.2A(e) AEMO may make minor or administrative changes to the Primary Frequency Response Requirements. The proposed changes are considered to be minor or administrative in nature and are primarily required to ensure the Primary Frequency Response Requirements are consistent with the National Electricity Rules, as amended by the Clarifying mandatory primary frequency response obligations for bidirectional plant rule.
AEMO made these changes available for feedback and comment by stakeholders for 10 business days. The changes will be effective from 3 June 2024 to align with the IESS Rules, unless otherwise specified in the document.
AEMO invited stakeholders to:
- provide feedback and comments on the accompanying change-marked documents; and
- identify any unintended adverse consequences of the changes.
Stakeholders were invited to submit written responses via email to pfr@aemo.com.au, by 5.00pm (AEST) on 24 May 2024.
Two submissions were received which suggested the following:
- The amount of mandatory PFR from a bi-directional unit enabled in the regulation FCAS markets only should be limited to the regulation FCAS enablement level.
- The provision of PFR should not be required outside defined State of Charge (SoC) limits.
The table below contains AEMO’s comments to the submissions.
|
Suggestion |
AEMO’s comments |
|
1 |
This proposed change to the PFR Requirements is intended to ensure consistency with the new Rule. Limiting the provision of PFR to the regulation FCAS enablement level represents a material change to the PFR requirements and was not a feature of the AEMC’s rule change (Clarifying mandatory primary frequency response obligations for bidirectional plant rule). Further consideration, and more comprehensive consultation, would be required as the PFR requirements currently do not specify any explicit limits on the PFR response. |
|
2 |
AEMO understands that some participants would prefer that SoC limits for PFR provision be clearly defined. However, AEMO acknowledges that provision of PFR may vary over the SoC range and this is considered when assessing the compliance of Affected Units against their PFR requirements. AEMO also notes that Section 6.6 already states that provision of PFR is subject to managing the safety or stability of the Affected Unit. Equivalent limits for the provision of PFR are not explicitly defined for other facilities (e.g. thermal or hydro) and AEMO has not seen any evidence that this has been problematic. AEMO will consider this further in future consultation on the PFRR. As noted above, this proposed change to the PFR Requirements is intended to ensure consistency with the new Rule. Further consideration, and more comprehensive consultation, would be required to make this change in the PFRR. |