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EUAA Submission: AER Values of Customer Reliability Methodology - Draft Determination

EUAA Submission: AER Values of Customer Reliability Methodology – Draft Determination

‘… We have strongly supported past AEMO and AER VCR valuation processes and look forward to being able to do so again in 2024. Our objective in objecting to the expedited process is not to get a lower VCR. Our objective is to get a robust VCR that is the result of a comprehensive engagement […]

EUAA Submission: Transmission STPIS Review- MIC & NCC

‘… Thank you for the opportunity to make a submission for the Issues Paper: Transmission Service Target Performance Incentive Scheme (STPIS) Review: Market Impact Component (MIC) and Network Capability Component (NCC). The MIC was designed to incentivise TNSPs to undertake outages when they have little to no impact on wholesale market prices (i.e. avoid planned outages […]

EUAA Submission: AEMC – Draft Determination National Electricity Amendment (Expanding The Transmission Ring-Fencing Framework) Rule

‘…The EUAA supports an equitable transition of the NEM to reach net zero-emissions.  This must be undertaken at least cost to consumers while ensuring the NEM continues to be fit-for-purpose while having full transparency in all investment justifications, including costs and tender processes.  The EUAA was concerned that without a rule change to close the […]

EUAA Submission: Transgrid Humelink – Stage 2 (Delivery) Contingent Project Application

‘…. Given the scale of what was required to transition the NEM was well known almost 10 years ago it is reasonable to believe that Transgrid (and other transmission network service providers) had (or should have had) a clear understanding of the full range of risks and costs involved and made decisions to invest in […]

EUAA Submission: Form of Regulation Review – SWQP

‘… The EUAA has been a strong supporter over many years of the Gas Market reforms that followed confirmation in the first ACCC Gas report in April 20161 that all parts of the gas supply chain were exercising market power. In the area of gas pipeline reforms, we have been strong supporter of the various […]

EUAA Submission: Capacity Investment Scheme Implementation Design Paper

‘… Recognising that the current version of the CIS has significantly expanded objectives both in scope and scale (23GW of generation and 9GW dispatchable capacity) we remain concerned that dispatchable capacity aspect of the CIS will tend to support relatively short duration storage (i.e. 2-6-hour batteries). While this may be acceptable within the context of recent […]

EUAA Submission: Changes to Reserve Level Declaration Guidelines Draft Report

‘… AEMO are proposing to change both the model for calculation of the forecasting uncertainty measure (FUM) and add an additional time of day input variable. The use of the FUM is a critical component in the declaration of a forecast lack of reserve in the short term projected assessment of system adequacy (ST PASA) […]

EUAA Submission: National Electricity Amendment (Accomodating Financability In The Regulatory Framework) Rule

‘…The EUAA support the pursuit of net zero targets but this must be achieved at least cost, not at any cost.  Additionally, we seek an equitable allocation of the costs and risks associated with the transition as all too often energy consumers are expected to carry the heavy weight of market (i.e. shareholder and/or debt […]

EUAA Submission: Draft 2024 Forecasting Assumptions Update

‘… The EUAA understands that the forecasting assumptions presented in the Draft Update are used in AEMO’s planning forecasting, i.e. the Electricity Statement of Opportunities (ESOO) and Integrated System Plan (ISP) and builds on the latest ISP related Inputs, Assumptions and Scenarios Report (IASR) published in 2023.  Therefore, while the update assumptions that come out […]

EUAA Submission: National Electricity Amendment (Enhancing Reserve Information) Rule 2024

‘…Thank you for the opportunity to make a submission for AEMC’s Draft Determination for the Enhancing Reserve Information (formerly the Operating Reserve Market) rule change.  This submission supports the submission made by EUAA Supporting Member, Shell Energy on this matter. EUAA is supportive of the AEMC’s draft determination in that: the AEMC will not proceed […]

EUAA Submission: Forecast Accuracy Report Methodology

‘… Thank you for the opportunity to make a submission under the Forecast Accuracy Report (FAR) Methodology. The EUAA understands that currently the FAR reviews the accuracy of forecasting in medium-term to planning time-frames, including the Electricity Statement of Opportunity (ESOO), Medium Term Projected Assessment of System Adequacy (MT PASA), large industrial load (LIL), demand […]

EUAA Submission: Forecast improvement Plan

‘… The EUAA understands that currently the FAR reviews the accuracy of forecasting in medium-term to planning time-frames, including the Electricity Statement of Opportunity (ESOO), Medium Term Projected Assessment of System Adequacy (MT PASA), large industrial load (LIL), demand response (DR), Retailer Reliability Obligation (RRO), the Integrated System Plan (ISP) etc. The EUAA considers that the […]

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