EUAA Submission: AEMO ST PASA Replacement Project - Generator Recall Process
EUAA Submission: AEMO ST PASA Replacement Project – Generator Recall Process
‘…Thank you for the opportunity to make a submission under AEMO’s ST PASA Replacement Project – Generator Recall Process. This submission supports the submission made by Shell Energy on this matter. In addition to this, the EUAA emphasises the following points: • We agree that there are potential significant benefits with the proposed rule change […]
EUAA Submission: AEMC National Electricity Amendment (Bringing Early Works Forward To Improve Transmission Planning) Rule 2024
‘…We believe that any improved cost estimates should be delivered at an AACE Class 3 or better, or else the early works do not save consumers’ costs and only leads to the TNSP transferring risk to consumers. Likewise, saving time on long-lead time items only benefits if the TNSP can manage the rest of the […]
EUAA Submission: AEMC National Electricity Amendment (RRO Exemption For Bi-Directional Units) Rule 2024
‘…Under current RRO obligations, retailers, large energy users and, notably, bi-directional units (BDU) with annual electricity consumption (from charging from the grid) above 10GWh per annum, are liable entities to the RRO. However, BDU provide other services, including contingency and regulation Frequency Control Ancillary Services (FCAS) lower services (including the new 1 second very fast […]
EUAA Submission: NDCCEEW Review Of Long Duration Storage (Part 6 Of The Electricity Infrastructure Investment Act 2020)
‘… The EUAA is a strong advocate for stable government policies that encourage investment without government unduly limiting technical capability or capacity. The current Consultation Paper combined with the Consumer Advocate’s and NDCCEEW’s interpretation of the EII Act are creating an environment of sovereign risk, discouraging investors and limiting technical capability of the NSW storage […]
EUAA Submission: VicGrid Community Benefits Scheme Proposal
‘…The EUAA supports effective community engagement. We see it as a critical part of the transition of our energy system towards net zero. In our view, without effective community engagement we put at risk the entire transition. An effective community engagement plan should be built on best practice and, as the IAP2 Guidelines for Public […]
EUAA Submission: ESC Powercor Australia Ltd Electricity Transmission Licence Application
‘… Powercor currently holds an electricity distribution licence under the Electricity Industry Act (Victoria) 2000 (EI Act) in the western half of Victoria. The EUAA understands that Powercor has applied for an electricity transmission licence to cover the same geographic area as its current distribution licence to improve competition for the connection of customer facilities […]
EUAA Submissions: AEMO’s Draft 2024 Electricity Consumption and Demand Side Participation Forecasts
‘…AEMO has created models for electricity consumption and DSP as inputs into the 2024 Electricity Statement of Opportunities (ESOO) and presented these to the FRG. While we agree or have no opinion on most of the modelling and the assumptions behind those models, we have prepared this submission to recommend amendments to some assumptions as […]
EUAA Submission: Draft Reference Service Proposal, Form of Revenue Control & Tariff Structure SA Distribution Network 2026/27 To 2030/31
‘….We support the current classification and agree that the energy policy context in South Australia means there is no need for an abolishment service. Proposed Tariff Approach We support continuation of the price cap form of regulation and consider this preferable to either a revenue cap or hybrid approach…..’ Please download attachment to read […]
EUAA Submission: Draft Amendments To Transmission Efficiency Test & Revenue Determination Guidelines For Non-Contestable Network Infrastructure Projects
‘…. The EUAA supports the AER developing a Position Paper in the first 60 days after submission by the Network Operator, instead of a Draft Determination, or as per ISP contingent projects, no report. We believe that the timeframe required to develop the Position Paper while allowing for consultation and a determination does not allow […]
EUAA Submission: AER Review of Cost Benefit Analysis & RIT Application Guidelines
‘…. The EUAA recognises that the ISP is (currently) a transmission transition plan to enable the replacement of coal fired power generation with Variable Renewable Energy (VRE). It is therefore appropriate that the ISP calculates the emissions reduction potential for both the proposed transmission network and the generators that will connect to it in the […]
EUAA Submission: AER Basslink Consultation Paper – Commencement & Process Paper Amendment
‘… The EUAA makes this short submission supporting AER’s revised timeline with additional consultation in the Basslink Commencement and Process Paper. APA’s application to convert Basslink from a Market Network Service Provider (MNSP) to a prescribed Transmission Network Service Provider (TNSP) is a complex process that requires additional consideration and consultation. We consider that: In […]
EUAA Submission: Directlink Revenue Proposal 2025-30
‘… The EUAA participated in most of the stakeholder meetings and engaged with APA at all stages of their preparation of the proposal. This was a considerable and very welcome improvement in stakeholder engagement compared with that which was done for the current regulatory period reset. There was a genuine effort put into ensuring wide […]