EUAA Submission: AER Enhanced Wholesale Monitoring & Reporting Guideline – Issues Paper
EUAA Submission: AER Enhanced Wholesale Monitoring & Reporting Guideline – Issues Paper
‘…Thank you for the opportunity to make a submission under the Australian Energy Regulator’s (AER) Enhanced Wholesale Market Monitoring and Reporting Guideline. While the Issues Paper covers both electricity and gas, our particular focus is on the east coast gas market given it has substantially less transparency to consumers than the National Electricity Market. The […]
EUAA Submission: DCCEEW Electricity & Energy Sector Plan – Discussion Paper
‘… We support governments setting policies to drive the transition to net-zero, but governments need to be seen to be supporting the transition financially instead of transferring the costs and risks to consumers. We are concerned that at some point in the not-too-distant future, consumers will be unable or unwilling to continue funding the transition. […]
EUAA Submission: AER Values Of Customer Reliability Methodology – Draft Determination
‘… In our earlier submission on this matter[1], we set out our reasons for not supporting the proposed expedited process with particular focus on the proposed methodology for residential and small business customers. We are generally happy with the direct cost methodology being used for customer with demand >10MVA, though we would appreciate the opportunity […]
EUAA Submission: National Electricity Amendment (Providing Flexibility In The Allocation Of Interconnector Costs) Rule (ERC0383)
‘…The EUAA is aware of issues related to fairness and equity for consumers in allocating interconnector costs for new interconnectors, particularly Marinus Link. Utilising the existing NER cost allocation methodology, Victorian and Tasmanian consumers would pay a similar gross amount. When these similar amounts are disbursed amongst the individual consumers, an individual Tasmanian consumer would […]
EUAA Submission: AEMC Draft Determination – National Electricity Amendment (Unlocking CER Benefits Through Flexible Trading) Rule (ERC0346)
‘… The EUAA sees benefits in creating consistency in the regulation of the services that are currently being supplied through third parties (such as FRMP’s) with those that already exist for retailers. The EUAA understands that Consumer Energy Resources (CER) refers to many different technologies that may be utilised differently with different price signals. These include […]
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) […]