Guidance for representing wholesale-passthrough retailer plans in CDR Energy (Amber Electric case study)

[purcell-lab]

Description

Wholesale-passthrough retailers (Amber Electric, Flow Power, Energy Locals, Localvolts, Powerclub, GloBird Wholesale) are CDR data holders. The current schema is not a natural fit for the contract structure these retailers actually offer customers: a network-passthrough plus wholesale-spot pass-through plus stable adders plus a fixed retailer margin, where the wholesale component varies on five minute basis.

Today, Amber's Brisbane (Energex) records in the AER product API include 23 distinct plans, many of which carry (estimate) or (estimate only) in displayName because the schema has no other way to communicate that the unitPrice is a model output rather than a contracted price. Sample records:

Plan ID	displayName	Supply (c/day)	Usage (c/kWh)
AMB1042863MRE1@EME	Amber Plan	113.59	31.24
AMB1043497MRE1@EME	Battery + Solar: Variable Wholesale Prices (estimate)	95.99	14.95
AMB1043503MRE1@EME	Solar Only: Variable Prices (estimate only)	95.99	23.99
AMB1043533MRE1@EME	No Feed-In: Variable Prices (estimate only)	113.59	22.37

Amber held a CDR participation exemption until 31 May 2025 (Amber CDR FAQ) reflecting the difficulty of mapping their plan structure to the schema. As DNSPs roll out two-way tariffs across the 2025–2030 regulatory control period (Energex's Residential Two-Way Tariff Trial commencing 1 July 2026 is the first), the wholesale-passthrough segment becomes increasingly important to the CDR-enabled comparison estate.

Intention and Value of Change

This issue does not propose a schema change. It proposes that the DSB request the AER publish a guidance note specifying how wholesale-passthrough retailers should publish CDR records within the existing schema, prior to (and separate from) the additive schema work tracked in #722 and #723 #722 (timeOfUseFeedInTariff[]) and #723 (priceComponents[]).

The proposed guidance approach:

1. Each unique combination of DNSP × eligible network tariff × customer type × FiT eligibility × controlled load eligibility is published as a separate CDR EnergyPlanContract record.
2. pricingModel and tariffPeriod[].timeOfUseRates[] mirror the underlying DNSP gazetted tariff structure (e.g., Energex NTC6900 windows for Amber's Brisbane TOU records).
3. Each rates[].unitPrice is the sum of:
   • the gazetted DNSP energy charge for that window
   • the trailing 90-day load-weighted mean of the AEMO regional reference price for the matching window
   • declared stable pass-through adders (market charges, environmental certs, hedging)
4. dailySupplyCharges is the sum of DNSP NUOS fixed + metering + (monthly subscription ÷ days).
5. additionalFeesInformation declares methodology, window-end date, AEMO source, retailer price-cap (e.g. Quarterly Bill Guarantee), and a pointer to the retailer's live-price API.
6. Plans are republished quarterly with new plan IDs per existing AER conventions.

Why this is workable today:

• The 90-day window over QLD1 in 2023–2025 ranged from 4.2c/kWh to 16.8c/kWh — a 4× range, not 100×.
• Amber's Quarterly Bill Guarantee caps the customer's annualised cost at DMO + 9% for the QLD reference customer.
• The wholesale component is computable from public AEMO NEMWeb data — any auditor can reproduce it.

Area Affected

• Procedural / guidance, not schema.
• Touches AER Retail Pricing Information Guidelines and the wholesale-passthrough data-holder cohort.

Change Proposed

The DSB would formally request the AER consider issuing a guidance note covering the structure above, with content blocks specifying:

• definition of "wholesale-passthrough retailer"
• mandatory content blocks in additionalFeesInformation
• averaging window (90 days proposed; 180 days as alternative for retailers with quarterly reconciliation cycles)
• publication cadence (quarterly recommended; monthly permitted)
• treatment of regional reference prices (QLD1, NSW1, VIC1, SA1, TAS1)
• the set of DNSP × tariff combinations a retailer must publish — Amber alone covers approximately 30 DNSP tariffs nationally
• reconciliation tolerance between published average and realised invoice — proposed: ±10% on a quarterly look-back is "compliant", >10% triggers republication

Voluntary first 12 months; mandatory thereafter via amendment to the Retail Pricing Information Guidelines.

The schema-level work (timeOfUseFeedInTariff[], priceComponents[], dynamicPricing) tracked in sibling issues is complementary, not a substitute. The guidance note can land at AER cadence (~6 months) while the schema work follows the DSB Decision Proposal cadence (~12–18 months).

Background and supporting material

This issue is raised because the wholesale-passthrough gap is operational today (Amber publishing 11 of 23 Brisbane records with (estimate) disclaimers) and addressable today using only existing schema fields plus declared methodology — without waiting for a schema cycle. The full submission, including detailed worked examples for the Energex 2026-27 Residential Two-Way Tariff Trial and complete CDR JSON, is available in the gist linked below.

Acknowledging this may be more naturally directed to the AER than the DSB — raised here to flag the gap to the standards-maintenance community and to enable cross-referencing with the schema-side changes proposed in the sibling issues.

Submitted by Mark Purcell (Purcell.id.au), energy sector consultant. Submission attributable.

Full submission: https://gist.github.com/purcell-lab/5208deccb058fb96c79099f7029821e2

[purcell-lab]

Note on access model. The CDR Energy generic plan endpoints (GET /energy/plans, GET /energy/plans/{planId}) are unauthenticated public APIs — no ADR accreditation, no consent flow, no customer linkage. The representation problem raised here is therefore a public reference-data problem: comparator sites, researchers, HEMS vendors and AI agents can all consume these endpoints today, and the schema gaps described affect every downstream consumer of that data equally. Improving plan representation has broad public-good value beyond the accredited-recipient ecosystem, and reinforces the case for keeping the CDR Energy plan schema aligned with adjacent operational schemas (e.g. RTDA) so that the same offer does not need to be expressed in two divergent shapes.

[ready-energy]

This is a high priority issue to address a major deficiency in consumers, and parties acting for them.

Crucially, this is PUBLIC end point data - you do not have to be an ADH (Authorised Data Holder) to access, use, or publish or make available a service to assist consumers, or other parties. As such it has high productivity value, and an excellent example of Data Standards creating efficiency and lower costs.

Tim Ryan
Consumer Representative
Data Standards Advisory Committee

[mattyp]

request the AER publish a guidance note specifying how wholesale-passthrough retailers should publish CDR records within the existing schema

This is the no-brainer takeaway for mine. The current spec is ambiguous on several fronts, with DH implementations being evidently inconsistent as a result. Some regulatory implementation guidance would really go a long way to ensuring consistency (and subsequent viability and quality of CDR-based products). Wholesale plans are a good example of one area this is needed.