EUAA Submission: Participant Derogation – ERC0320, ERC0322
Emily Wood | December 3, 2020
‘Much of Australian manufacturing industry has been built on the availability of internationally competitive and reliable electricity supply. This international competitiveness has been severely challenged in recent years due to a range of factors including rising gas and coal prices, the sometimes chaotic transformation of energy markets and climate policy uncertainty.
The EUAA recognise the need to comprehensively evaluate the best pathways to a decentralised and decarbonised electricity system including the challenges that come with the retirement of thermal plant and the integration of new and emerging technologies. This is becoming increasingly important as governments seek to put in place ambitious climate change objectives such as net zero emissions by 2050.
In this regard, we support the development of the ISP as a guide for future investment and see it having the potential to play a key role in facilitating this transition pathway at the most efficient cost to consumers. However, the ISP has moved beyond being a plan to guide investment decisions to a plan that directs investment decisions, largely driven by the desire of COAG Energy Ministers to make the ISP actionable.
While on the surface this seems a worthwhile objective, it is not without significant risks. In particular we should not be sacrificing sound governance practices, such as diminishing the role of the AER, removing important checks and balances in the independent economic assessment process or transferring risk to consumers in order to achieve an expedited result…’
Please download attached to read full submission.