Submissions
EUAA Submission: National Gas Amendment (Extension Of The DWGM Dandenong LNG Interim Arrangements) Rule 2025
‘… We support an extension of current Dandenong LNG Interim Arrangements to cover the period between the end of the current arrangements in December 2025 and the commencement of the permanent gas reliability and supply adequacy (RSA) rules in the East Coast Gas System (ECGS). Without this extension, we can foresee the predicted southern regions peak […]
EUAA Submission: NSW Transmission Planning Review – Option Paper
‘… The transition to a low carbon energy system is proving to be exponentially more challenging than was first anticipated, even more so in NSW as the Roadmap seeks to accelerate the largest transformation in the NEM. From our experience, the planning and coordination of multiple entities involved in the transition is difficult to engage […]
EUAA Submission: Allowing AEMO To Accept Cash As Credit Support – Draft Rule
‘…Thank you for the opportunity to make this brief submission to the Allowing AEMO to accept cash as credit support, Draft Rule. The EUAA are supportive of the draft rule. In our submission to the Consultation paper (ERC 0403) we stated our support for this rule change because: • If this rule did not proceed […]
EUAA Submission: AEMO ST PASA Replacement Project – Procedure Consultation
‘… At the EUAA, we support the design of rules, legislation and procedures that achieve efficient, cost effective and equitable outcomes for networks, developers and consumers. In the energy sector under most circumstances, this is best achieved through a national approach and a sharp focus on the NEO. From our perspective, this has not been […]
EUAA Submission: AEMO Security Enablement Procedures – Consultation Paper
‘… Unfortunately, we believe that the proposed rule change and procedure will not result in unbundling of the essential system services but will continue to rely exclusively on AEMO’s continued use of regional generation EUAA SUBMISSION: AEMO SECURITY ENABLEMENT PROCEDURES – CONSULTATION PAPER| 8 MAY 2025 Page 2 of 6 bundles. This means that the […]
EUAA Submission: AEMO Budget 2025-26
‘…In the past we have been very critical of the approach AEMO has taken to the development of its budget, particularly when we were informed about the $106m deficit after the event. We are pleased to report that AEMO has made some improvements in both its engagement approach and transparency around its level of cost […]
EUAA Submission: National Electricity Amendment (Including Distribution Network Resilience In The NEM) Rule
‘… Thank you for the opportunity to make a further submission on the Victorian Energy Minister’s proposed resilience rule change. In our previous submission on the Consultation Paper, we argued that the long-term interests of consumers are best served by: Not including expenditure factors in the rules as proposed by the proponent, but Requiring a […]
EUAA Submission: SA Electricity Development Plan
‘… We understand that having firm capacity in the market means that “somebody” will need to make payments to the firm capacity owners so that the capacity is available when required, and approve of the SA and Federal Government’s foresight (through the Renewable Energy Transformation Agreement – RETA) to use SA as a test-bed for […]
EUAA Submission: NEM Wholesale Market Setting Review Initial Consultation
‘…The EUAA supports the pursuit of net zero targets and a lower emissions stationary energy sector. As we transition from a highly centralised generation system dominated by dispatchable thermal generators to a highly decentralised system dominated by Variable Renewable Energy (VRE) a number of key challenges are becoming apparent that include: • Traditional dispatchable fossil […]
EUAA Submission: Victoria’s Renewable Gas Directions Paper
‘… At the EUAA, we support the design of rules, legislation and procedures that achieve efficient, cost effective and equitable outcomes for networks, developers and consumers. As the proposed Victorian Industrial Renewable Gas Guarantee currently stands, it does not achieve these outcomes as it is trying to achieve a cost reduction for a limited group […]
EUAA Submission: AER Electricity Transmission Network Service Providers Service Target Performance Incentive Scheme Proposed Amendments
‘… The EUAA supports the design of incentive schemes in order to achieve efficient, cost effective and equitable outcomes for networks and consumers. If an incentive scheme is no longer working, the EUAA encourages re-designing the incentive scheme so that it functions as it was intended. With a changing NEM, this may require regular updates […]
EUAA Submission: AEMC National Electricity Amendment (Improving The Cost Recovery Arrangements For Transmission Non-Network Options) Rule – Draft Determination
‘… The EUAA is supportive of the Commission’s work in aligning the framework for non-network options (NNOs) arising from a Regulatory Investment Test-Transmission (RIT-T) with the framework for network options, that is by providing an ex-ante review process and allowing TNSPs to receive reimbursement of the costs in the year that it was expended. This creates […]