The Australian Aluminium Council (the Council) welcomes the opportunity to comment on the Consultation Paper on the Market Visibility Framework (MFV or the Paper).
The Council supports the proposed Phase 1 Capability Development and Validation of the MFV. However, the Council considers that further work is required before mandatory Mode 2 or Mode 3 obligations are applied to large industrial loads and does not support mandatory Mode 4 dispatch-integrated participation for these loads. Any additional visibility obligations should be proportionate to an identified forecasting or operational need, recognise information already available to AEMO and network service providers, avoid unnecessary costs or duplication, preserve appropriate incentives for investment in demand-side flexibility, and protect commercially sensitive industrial information.
