EUAA Submission: ESB Post 2025 Market Design Consultation Paper
EUAA Submission: ESB Post 2025 Market Design Consultation Paper
‘We welcome the opportunity to make a submission to the Post 2025 Market design Consultation Paper (Consultation Paper) and acknowledge the significant amount of work undertaken by all of those involved with the ESB. The active and increasing level of direct intervention by Commonwealth and State Governments has meant it has been difficult to respond […]
EUAA Submission: Fast Frequency Response
‘The Commission’s draft rule determination is to make a draft rule that is consistent with the solution proposed by Infigen Energy. This short submission supports the AEMC’s Draft Determination: That is consistent with the Infigen rule change request to introduce both a very fast raise service and a very fast lower service, and Applying the […]
EUAA Submission: Powerlink Queensland Revenue Proposal 2022-2027
‘…Powerlink’s Proposal provides an excellent perspective on the rapidly changing business and operating environment faced by electricity networks in the National Electricity Market. While it presents the proposed revenue requirement for the 2022-27 period, this is seen in the context of what needs to be done in that period to ensure it meets stakeholders needs […]
EUAA Submission: Tranche Two Issues Paper
‘Our comments in this submission cover some, but not all, of the questions posed in the Issues Paper. Our main recommendations are around the need for a governance framework that allows increased transparency and ability for consumer engagement. This is crucial for consumers to be confident that the Roadmap will indeed meet its aim of […]
EUAA Submission: Project Energy Connect Revised Application
‘…Project Energy Connect (PEC) is a 60-70 year asset that consumers will be paying for over its entire life. We have real concerns that a combination of technological change and policy initiatives at a State level could result in it becoming a stranded asset prior to the end of its technical life. Given this, the […]
EUAA Submission: ACCC Review of LNG Netback Price Series
‘… We welcome the opportunity to provide a submission on the calculation of the LNG netback price series. The publication of the series has provided much needed transparency around what the ACCC describes as ‘an indicative reference price’1. The ACCC sees it as a ‘relevant price marker in negotiations for domestic supply’ subject to some […]
EUAA Submission: Review of the Reliability Standard & Guidelines
‘…In summary, the EUAA does not see any need to review the Reliability and Standard setting guidelines prior to the regular review of the reliability standard and settings. Regular reviews in the past have shown that the current form of the settings is the best approach to an energy only market and we do not […]
EUAA Submission: Financeability of ISP Projects
‘The EUAA strongly supports the Draft Rule Determination of the Commission to not make the proposed participant derogation. We are pleased to see the Commission supporting our contention in our submission on the Consultation Paper that we were not convinced that the current regulatory framework causes financeability issues for ISP projects. Our members would not […]
EUAA Submission: ESB Renewable Energy Zones Consultation Paper
‘…The EUAA welcome this opportunity to make submission to the Renewable Energy Zones Consultation Paper (Consultation Paper) and commend the ESB on their commitment to stakeholder engagement. We also recognise the efforts by the ESB to better coordinate the establishment of Renewable Energy Zones (REZ) in previous consultations in late 2020. We appreciate the complexity […]
EUAA Submission: Regulation of Actionable ISP Projects
‘The EUAA very supportive of the development of this guidance note. We have been critical of the poor record AEMO and TNSPs have in the estimation of capex for major projects across the whole ISP/RiT-T/Contingent Project Application (CPA) ‘supply chain’. Given the intent of the note is to: “…promote the efficient delivery of actionable ISP […]
EUAA Submission: AusNet Services Electricity Distribution Determination for 2021-26
‘The Energy Users’ Association of Australia (EUAA) is the peak body representing Australian commercial and industrial energy users. Our membership covers a broad cross section of the Australian economy including significant retail, manufacturing, building materials and food processing industries. Combined our members employ over 1 million Australians and pay billions in energy bills every year […]
EUAA Submission: Reliability Forecast Guidelines Issues Paper
‘Our overall concern about the approach AEMO is taking is that it is, in many cases, effectively forecaster and arbitrator of whether stakeholder concerns about its forecasting methodology are valid. This is simply illustrated by this process, where AEMO, rather than the AEMC in a rule change situation, is assessing the veracity of submissions that […]