Continuous monitoring is now the stated preference

Principle 2 of the Template for Compliance Programs contains a sentence we think will reshape how the NEM approaches compliance: continuous plant monitoring is the preferred approach, where practicable — and where it isn't implemented, a Registered Participant must document its reasons and put alternative regimes in place that still provide reasonable assurance.

That's a monitor-or-explain regime. And it reflects where the power system has genuinely landed.

What happened to the Notes column. In the 2019 tables, a Notes column carried the applicability qualifiers — "applies to synchronous and conventional plant", "appropriate to use where high speed monitors are available". That column is gone. The information has moved into the method headings themselves: Method 1 is continuous high-speed monitoring, with or without automated assessment tools. Method 2 is investigation of events where continuous high-speed monitoring is not practical.

The consequence is quiet but significant: your monitoring capability now determines which method you're in, and that choice is visible on the face of every table. There's no longer a footnote to hide the decision in.

Why the Panel prefers it. The guidance is refreshingly direct. Continuous monitoring:

• provides ongoing information about plant performance, including automated alerting to potential non-compliance

• reduces the need for frequent testing, letting staged tests focus on edge cases and post-plant-change validation rather than routine reconfirmation

• can be implemented in lieu of staged testing where staged tests can't practicably be conducted.

Are the suggested frequencies negotiable? Less than they used to be. Section 4.7.3 states that the recommended frequency should be considered the baseline requirement, and that departing from it requires documented reasoning under Principle 7. Note the column heading changed too — 2019's "Suggested frequency of testing" is 2026's "Suggested assessment frequency". Small edit; real shift.

Section 4.7.1 then makes the trade explicit: where continuous monitoring is in place, testing can focus on edge cases and severe conditions that don't occur in normal operation. Where it isn't, more frequent testing may be necessary.

That sentence is the commercial heart of the revision. The Template now prices continuous monitoring against test frequency, in writing.

The Panel is equally practical about the exceptions, and we think that balance is right. Retrofitting high-speed monitoring to an older thermal unit near the end of its commercial life may not be proportionate. Existing methods may already provide sufficient assurance. The principle isn't "monitor everything at any cost" — it's "monitor where practicable, and be able to show your reasoning where you don't". We've written separately about what a defensible version of that reasoning contains.

For most modern asynchronous plant, though, the practicability question mostly answers itself. High-speed metering is commonly a condition of connection, and continuous monitoring now leads as Method 1 across the clause tables — frequency response, voltage disturbances, ride-through, voltage control and more.

This is, candidly, the world COMET was built for. Across more than 30 sites and 4.5+ GW of generation and storage in the NEM, our platform ingests high-speed metering data daily, identifies power system events automatically, and assesses plant response against the registered GPS — clause by clause, with the evidence archived. It's what we mean when we say COMET moves grid compliance from once every 24 months to once every 24 hours. The Template doesn't mandate that approach — but it now clearly prefers it, and it rewards it with a lighter, better-targeted testing burden.

If your current GCP relies on periodic testing alone, the window is the moment to ask the Principle 2 question honestly: is continuous monitoring practicable for this plant? For most utility-scale renewable and storage assets, we believe the answer is yes — and the Template now expects your program to reflect that, or explain why not.

Curious what continuous monitoring would look like for your plant? Let's walk through it together — no obligation, just engineering.

Q: Does the 2026 Template require continuous monitoring?

A: Not absolutely. Principle 2 states continuous monitoring is preferred where practicable; where it is not implemented, the participant must document its reasons and implement alternative regimes providing reasonable assurance of ongoing compliance.

Q: What is the difference between Method 1 and Method 2 in the compliance tables?

A: Method 1 is continuous high-speed monitoring, with or without automated assessment tools. Method 2 is investigation of events where continuous high-speed monitoring is not practical. In 2019 this distinction sat in a Notes column; in 2026 it sits in the method headings, so monitoring capability determines which method applies.

Q: Are the suggested assessment frequencies in the 2026 Template mandatory?

A: They are framed as a baseline rather than a suggestion. Section 4.7.3 states the recommended frequency should be considered the baseline requirement, and that departing from it requires documented reasoning under Principle 7.

Q: Can continuous monitoring reduce how often I need to test?

A: Yes. Section 4.7.1 states that with continuous monitoring in place, testing can focus on edge cases and severe conditions that don't occur in normal operation, while where it isn't in place more frequent testing may be necessary.