EUAA Submission: ESB Post 2020 Market Design Issues Paper
EUAA Submission: ESB Post 2020 Market Design Issues Paper
‘…it is with a strong sense of Deja Vu that we welcome the opportunity to make a submission to the Energy Security Board (ESB) Post 2025 Market Design Issues Paper. There seems to be striking similarities between the work being done on a post 2025 market design and the Finkel Review that was completed in […]
EUAA Submission: Consultation RIS – Gas Transparency
The information asymmetry that exists between the gas supply chain and gas users is an issue the EUAA has been highlighting for many years. Eventually it was recognised by the ACCC in its seminal report on the East Coast Gas Supply in April 2016. This report provided much impetus for the detailed reform program now […]
EUAA Submission: Wholesale Demand Response Mechanism Rule
The EUAA is very supportive of the approach taken by the AEMC in its Draft Rule Determination of the Wholesale Demand Response Mechanism (QDRM). The facilitation of efficient demand response is a key part of ensuring a secure and reliable NEM as it transitions to a lower carbon generation mix as well as enabling all […]
EUAA Submission: National Electricity Amendment (Transparency of New Projects) Rule
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: Draft Financial Reporting Guideline for Light Regulation Pipeline Services
We were a strong supporter of the Vertigan reforms that set up the information disclosure and arbitration framework for unregulated pipelines. We support this draft financial reporting guideline for light regulation pipelines for the same reasons. Download the attached submission to read full details.
EUAA Submission: ADGSM Review
‘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: Regulatory Sandbox Arrangements to Support Proof-of-Concept Trials
The EUAA strongly support the direction the Commission is heading in developing the sandbox toolkit. The sequential three stage trial components – regulatory guidance to regulatory waiver to a new trial rule making – are a logical progression in seeking to facilitate proof-of-concept trials. The framework presented in the paper provides a transparent view of […]
EUAA Submission: AEMC CoGaTI Access and Directions Paper
We welcome the opportunity to make a submission to the Coordination of Generation and Transmission and Investment (COGATI) – Access and Charging Directions Paper. The EUAA are not opposed to new network assets being built to facilitate new generation, for interconnectors to be built that allow market participants greater access to the market and to […]
EUAA Submission: Transmission Loss Factors
We are of the view that the proposed transmission loss factor rule changes potentially shifts considerable risk and costs to consumers. This outcome is at odds with a long-held EUAA position that seeks to ensure the risks and costs associated with energy markets are equitably shared amongst participants. We are also of the view that […]
EUAA Submission: Energy Security Board – Converting the ISP into Action
We are supportive of a more centralised approach to whole of system planning that the ISP seeks to achieve. We believe the ISP is a useful investment guide that can shape investor decisions. However, again we are concerned with what we perceive to be a desire to elevate the ISP above the existing regulatory checks […]
EUAA Submission: Reliability Panel Review of the RERT Guidelines 2019
The EUAA welcomes the opportunity to make a submission on the changes to the RERT Guidelines following the recent very comprehensive AEMC RERT review. The EUAA has been a strong supporter of the AEMC’s final rule determination on RERT. In particular we support the explicit linking of the RERT procurement trigger and volume to the […]
EUAA Submission: For consultation – Draft Interim Forecasting Best Practice Guidelines
As the Guidelines consultation paper states, the role of AEMO’s reliability forecasts assumes a new level of importance under the Retailer Reliability Obligation. The AER validation of an AEMO reliability request could result in liable parties acquiring a substantial number of firm contracts that eventually results in substantial additional costs being passed through to consumers. […]