Submission to the NEM Wholesale Market Settings Review
Aligning market settings, policy and programs with consumer outcomes in a decarbonised National Electricity Market (NEM)
From Solar Citizens Prepared by DER Specialist Dr Gabrielle Kuiper
This submission commends the NEM Review Panel’s extensive work to consider the future of short, medium and long-term procurement of supply and essential system services in the National Electricity Market (NEM). At the same time, it argues the Panel’s Draft Report remains too anchored in traditional ‘spot market’ thinking rather than starting from the customer and behind-the-meter (BTM) resources.
This submission criticises the draft for insufficiently addressing demand-side resources, particularly hot water systems, which present an enormous flexible demand opportunity. Referencing UTS research, it highlights billions in potential savings through electrifying and
making domestic hot water flexible—up to 22GW/45GWh/day, equivalent to over two-thirds of NEM peak demand by 2040 under the rapid electrification scenario. Expansion of demand-side thinking, including lessons from international ‘demand flexibility’ markets, is urged.
The submission further advocates for the expansion of the Wholesale Demand Response Mechanism (WDRM) to aggregations of small users and the use of non-static baselines for measuring demand reductions.
Read the full submission + supporting documents
a) Australia needs more efficient, smarter home hot water systems, Dr Gabrielle Kuiper, August 2024
b) NEM Reform: Unlocking the demand side in future energy markets, Dr Gabrielle Kuiper, July 2025