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Primary Frequency Response under Normal Operating Conditions

Market National Electricity Market
StageFirst Stage
ConvenorAEMO NEM
Accepting submissions?No
Submissions close06/12/2019

Australian Energy Market Operator (AEMO) is conducting a consultation on proposed amendments to the Causer Pays Procedure and the Market Ancillary Services Specification (MASS) to complement Rule Changes related to the provision of Primary Frequency Response (PFR).

This consultation is being conducted under clauses 3.15.6A(k) and 3.11.2(b) of the National Electricity Rules (NER), in accordance with the Rules consultation requirements detailed in rule 8.9 of the NER. 


AEMO has recently submitted two proposals to the Australian Energy Market Commission (AEMC) requesting to amend the NER to facilitate the provision of PFR by Generators under normal operating conditions.  The first proposal aims to remove disincentives and inconsistencies in the NER that are impeding the provision of more PFR in the NEM under normal operating conditions. The second proposal relates to mandatory PFR requirements for all scheduled and semi-scheduled Generators. AEMO’s proposals, and the AEMC’s Consultation Paper can be found at on the AEMC's website under Proposed Rules to better control power system frequency.

Amongst other changes, Rule Change Proposal ERC0263 (Removal of disincentives to primary frequency response) proposes to amend clause 3.15.6(k) to align the requirements of the Causer Pays Procedure with the intent of the ‘causer pays’ process, as stated in clause 3.15.6A(k)(1).  

AEMO has published a marked-up consultation draft of the Causer Pays Procedure with this notice, and an Issues Paper on the MASS. The proposed changes are:

  • The Causer Pays Procedure will specify requirements for the provision of PFR that, if met by a Generator, will result in that Generator not receiving a negative ‘causer pays’ factor.
  • The MASS should be altered so that the Contingency FCAS requirements do not incentivise a delay in the delivery of PFR. 

This consultation will be limited to the changes identified in this notice, and the draft Causer Pays Procedure.  In the coming months, AEMO intends to:

  • Carry out a more extensive review and consultation on the Causer Pays Procedure; and
  • Redraft the MASS and consult on various other changes associated with that document.

9 January 2020 - Update on progress of consultation on AEMO Procedures

AEMO appreciates the time and effort parties have spent in making submissions to Stage One of this consultation on amendments to the Market Ancillary Services Specification (MASS) and the Regulation Contribution Factor Procedure (Causer Pays procedure). A total of 10 submissions were received and have been published on the consultation page. This provides an update on progress on these consultations and a revision of the timetable.


Submissions raised some matters relating to the treatment of PFR in the MASS that require additional evaluation and analysis in order for AEMO to reach a well considered draft determination. Therefore AEMO is postponing the date of publication of the Draft Report and Determination until approximately 6 February 2020. An updated indicative timetable is given below. The is revised timetable will still ensure that the MASS is updated well before the expected commencement of the National Electricity Rule amendments to implement mandatory primary frequency response on 4 June 2020.

Causer Pays

As flagged in the consultation notice, the proposed changes to the Causer Pays procedure were contingent on the AEMC making a rule on ERC0263 “Removal of disincentives to primary frequency response”. The AEMC has deferred a draft determination on this rule to 24 September 2020. Therefore AEMO is halting further consideration of the matters flagged under this Causer Pays consultation until a later date to be advised. 

The dates in this revised timetable below apply only to the MASS consultation.

Updated timetable for consultation

Process stage
Indicative date
Closing date for submissions in response to this notice of first stage of consultation
6 December 2019
Publication of Draft Report and Determination
6 February 2020
Closing date for submissions in response to the Draft Report and Determination**
26 February 2020
Publication of Final Report and Determination
6 April 2020

** Submissions provided after the closing date will be considered on a case-by-case basis.

Consultation documents

AEMO invites comments on the proposed changes contained within the Notice of First Stage of Consultation, amended Causer Pays Procedure and MASS Issues Paper. These documents are provided below.

Submissions in response to the Notice should be forwarded to AEMO by 5:00pm (Melbourne time) on Friday 6 December 2019.

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