EUAA Submission: AEMC National Electricity Amendment (Bringing Early Works Forward To Improve Transmission Planning) Rule 2024
Emily Wood | July 4, 2024
‘…We believe that any improved cost estimates should be delivered at an AACE Class 3 or better, or else the early works do not save consumers’ costs and only leads to the TNSP transferring risk to consumers. Likewise, saving time on long-lead time items only benefits if the TNSP can manage the rest of the project timelines to achieve the desired energisation date. To-date, TNSPs have not been able to deliver these outcomes from CPAs after the RIT-T process, and we have severe reservation that bringing the CPA process forward to be run in tandem with the RIT-T or ahead of the RIT-T process will deliver the desired outcomes. Having an AACE Class 3 or better cost estimate and real project timelines with strict deadlines is standard practice amongst our members.
In practice, from our observations to date, Early Works CPA is simply another form of accelerated depreciation for the TNSP. The proposed rule change is likely to increase the amount and timing of costs brought forward…’
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