EUAA Submission: Participant Derogation – ERC0320, ERC0322
EUAA Submission: Participant Derogation – ERC0320, ERC0322
‘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 […]
EUAA Submission: Transparency of Unserved Energy Calculation
‘The EUAA write to support the overall direction of this rule change to bring increased transparency to the measurement and reporting of USE. However, we share ERM’s concerns around the intent of the proposed addition of…’ Please download attached to read full submission.
EUAA Submission: CAPM and Alternative Return on Equity Models
‘Our members are highly exposed to movements in both gas and electricity prices and have been under increasing stress due to escalating energy costs. These increased costs are either absorbed by the business, making it more difficult to maintain existing levels of employment or passed through to consumers in the form of increases in the […]
EUAA Submission: National Transmission Planner Costs
‘The EUAA supports this rule change to bring clarity to the process for recovering National Transmission Planner (NTP) costs and enable the policy intent of the ISP rules to be achieved. Our purpose in making this submission is to highlight the significant increase in NTP costs in recent years given AEMO’s preparation of the Integrated […]
EUAA Submission: AEMO Electricity Fee Structure
‘The EUAA agrees with the AEMO that significant changes in the NEM since the last review of the fee structure means it is appropriate to undertake this review. While we acknowledge that this review is not about the annual budget and fees, it cannot be separated from that. A necessary pre-requisite for a fee structure […]
EUAA Submission: Distributed Energy Resources Integration
‘We agree with the Commission’s, and the rule change proposers’ views that the current regulatory framework needs to be continually updated to promote the efficient investment in, and operation of energy services. The EUAA congratulates the proponents of the three rule change proposals for addressing what is becoming a major issue in electricity markets. The […]
EUAA Submission: Renewing AEMO’s Engagement Model
‘We welcome the opportunity to respond to the Renewing AEMO’s engagement model discussion options paper (options paper) and commend AEMO on recognising that their past approach to stakeholder engagement is no longer fit for purpose and that change is required…’ Please download attached for full submission.
EUAA Submission: RSIG, MTPASA, EAAP
Amendments to the Reliability Standard Implementation Guidelines, MT PASA Process Description and Energy Adequacy Assessment Projection Guidelines Consultation Draft Determination and Report ‘… As we noted in our earlier submission on this matter, we continue to be concerned about the conservatism used by AEMO in its forecasting methodology. This has a large impact on the […]
EUAA Submission: System Services Rule Changes
‘We welcome the opportunity to respond to the System Services Rule Changes Consultation Paper (Consultation Paper) and appreciate the work being carried out by the AEMC and ESB to synthesise the many parallel policy and regulatory processes currently underway. It is clear that the rule change requests discussed in the Consultation Paper cross paths with […]
EUAA Submission: Thermal Generator Variable Heat Rates
‘As energy users we have no material view on thermal generator heat rates, but wanted to use this process to respond to your general invitation to comment on the updated cost benefit analysis. We recognise the difficulty faced by project proponents in such a challenging and highly volatile environment and appreciate that many assumptions and […]
EUAA Submission: Regulatory Treatment of Inflation
‘This submission begins with some general comments including discussions with the Consumer Reference Group. It then responds to the specific questions asked by the AER in its Discussion Paper. On the basis of the evidence presented so far, we see no reason to change from our position of support for the AER’s Final Decision in […]
EUAA Submission: Draft Guidelines to make ISP Actionable
‘As we noted in our previous submission on this matter, the EUAA recognises the need to comprehensively evaluate the best pathways to a decentralized and decarbonised electricity system. The challenges that uncertainty on the timing of thermal plant retirement, increasing extreme weather events and the integration of new and emerging technologies, all require sophisticated analysis […]