It’s not “Test vs. Monitor” but “Test and Monitor” when it comes to your GCP.

“We have a testing regimen in place in line with our GCP – why do we need to monitor?”

Because the AER says you have to.

Under NER Clause S5.2.5.13, generating systems must maintain automatic voltage and reactive power control capabilities. Field testing validates compliance at a point in time but, when we’re using technologies which can have their performance changed through the click of a button, what is the plant doing the rest of the time?

We see this all the time. Over a two-week period at a large-scale NEM connected project, the COMET platform detected and analysed four significant voltage events – including both temporary under-voltage conditions and reactive power droop responses during network disturbances.

Each event was automatically assessed against S5.2.5.13 requirements: rise times, settling times, droop characteristics. All were compliant, but here's the critical point: without continuous monitoring, these events would have gone undetected and unassessed until the next scheduled test, which is scheduled in three years' time.

It is not ideal to wait until the next major grid disturbance to check manually if your plant behaved in an appropriate manner. Maybe a case of "too little too late"? For good reason, the AER is clear on this: "Reactive or ex-post assessments cannot be solely relied upon and need to be complemented with an ongoing monitoring and testing regime."

Testing is essential, but it gives you a snapshot. Continuous monitoring captures grid events in all operating conditions, helps detect performance degradation early, creates a documented compliance audit trail and enables engineering team to be proactive, rather than reactive. All of which materially mitigate your compliance risk - a comprehensive and complementary monitoring and testing regime is essential!

With civil penalties reaching $10M for GPS non-compliance, not to mention the impacts on social license and asset value… The question is NOT if, but rather how to best implement your continuous compliance management strategy.