EUAA Submission: Murraylink Electricity Transmission Revenue Proposal 2023-2028
Emily Wood | May 10, 2022
‘…The EUAA has been a member of the Murraylink Electricity Transmission Interconnector Stakeholder Engagement Group from its inception. APA has sought to engage in a productive and open way throughout this process. The fact that it is a relatively small asset with a correspondingly small impact on consumer bills makes it difficult to get engagement from consumer advocates pulled in many different directions by many other issues that have a much larger impact on their final bills. Nevertheless, APA should be recognised as having made a genuine effort to engage, even if the response was sometimes limited.
This submission focusses on the major issue for engagement that emerged in late 2021 with the news about the limited future availability Insulator Gate Bipolar Transistors (IGBTs). APA has engaged well on this issue since it became known – a stakeholder engagement session in January 2022 on the issue and the current engagement on the terms for appointing an economic consultant to help provide analysis that will support the selection of the preferred option for addressing obsolete IGBTS.
APA proposes that once all the available IGBTs are used, it will be necessary to replace the valve room at an estimated cost of $30m. This is proposed as a contingent project, subject to the following trigger events occurring:
- completion of a required Regulatory Investment Test – Transmission
- approval of the project by the EII Board
- the stock of spare IGBTs falling to a minimum level to enable confidence that they are likely to last until the replacement is complete (currently estimated at 72).
We agree with the comments in the AER’s Issues Paper around the engagement the AER expects APA to undertake on future options given the IGBT availability (p.17):
- identify the risk to be addressed
- explore the costs and benefits of a range of credible options to address that risk, and
- arrive at a solution that reflects consumer preferences identified through that engagement.
So far APA’s engagement has assumed that there is a continued role for Murraylink after the end of life of the IGBTs. The EUAA would propose that to meet the AER’s engagement requirements, APA will need to engage with consumers on more fundamental questions…..’
Download attached to read full submission.
