EUAA Submission: AEMC Reliability Rule Change - Market Price Cap, Cumulative Price Threshold and Administered Price Cap
EUAA Submission: AEMC Reliability Rule Change – Market Price Cap, Cumulative Price Threshold and Administered Price Cap
‘…The EUAA does not support the rule change as presented in the Consultation Paper (‘Paper’) because we do not consider the analysis presented by the Panel and the Commission is robust enough to justify that the changes are consistent with the NEO and the long-term interests of consumers. Specifically: The NEM is no longer an […]
EUAA Submission: Review of CBA and RiT-T Guidelines
‘…The EUAA was one of the proponents of the Material Change in Network Infrastructure Costs rule change. While our proposal covered both transmission and distribution projects, our focus was on large transmission projects, particularly ISP projects. Our original proposal in January 2021 highlighted the significant increase in ISP project costs over the course of the […]
EUAA Submission: Options To Address Gaps In Transmission Ring – Fencing Framework – Consultation Paper
‘…The EUAA supports an equitable transition of the NEM to reach net zero-emissions, constructed at least cost for a fit-for-purpose energy system while having full transparency in all justifications, costs and tender processes. The EUAA is concerned that without a rule change to close the gaps in the transmission ring-fencing framework identified by the AER, […]
EUAA Submission: Pipeline Information Disclosure Guidelines – Issues Paper
‘…The major information deficiencies in the gas transportation market have contributed to the east coast gas market being a significant distance away from achieving the National Gas Objective. The inefficiencies are obvious to our members as they seek to negotiate gas transportation agreements with many feeling as though both hands are tied behind their back. […]
EUAA Submission: AEMO Review Of Technical Requirements For Connections – Addendum To Draft Report
‘…The EUAA understands that AEMO is concerned with potential positive feedback loop contingency events, whereby a disturbance happens in the electricity network which triggers some loads to trip, further exacerbating the disturbance and causing additional loads to trip. We further understand through consultation with AEMO, that AEMO are specifically concerned about inverter-based loads (IBL) where […]
EUAA Submission: Mandatory Code Of Conduct
‘…The EUAA welcomes the Federal Government’s decision to implement the Mandatory Gas Code. It is required because our first preference – a competitive domestic gas market – is not the case now and has not been the case for many years. This market failure has required Government intervention in the form of the Mandatory Code. […]
EUAA Submission: Review of the Retailer Reliability Obligation
‘…The EUAA has been generally supportive of the RRO since its introduction. However recent events have led us to the conclusion that it is not operating as was originally intended, or at least not always in consumers’ interests. The reliability rules around the T-3 trigger are now effectively irrelevant When originally introduced the policy, intent […]
EUAA Submission: Review Of The Form Of The Reliability Standard & Administered Price Cap REL0086
‘… In summary the EUAA: Supports the current form of the reliability standard and consider the current form is still the best option in a renewables dominant grid Supports continued use of the AER VCR values to assess what consumers are prepared to pay for reliability Recommends that the Panel takes account of the impact […]
EUAA Submission: AEMO Review Of Technical Requirements For Connection Under Schedules 5.2, 5.3 And 5.3A Of The National Electricity Rules
‘…Thank you for the opportunity to make a submission under the Review of Technical Requirements for Connection Under Schedules 5.2, 5.3 and 5.3A of the National Electricity Rules Draft Paper. The EUAA acknowledges the necessity to update connection rules as new technologies are adopted by market participants. EUAA’s support is provided where rule changes are […]
EUAA Submission: Review of Interim Reliability Measure
‘…This submission does not support the extension of the Interim Reliability Measure (IRM) beyond its current expiry date of 30th June 2025. Contrary to what the Commission argues in its Draft Report, we do not consider an extension is in the long-term interests of consumers. …As the Draft paper notes, the selection of the reliability […]
EUAA Submission: VNI West Consultation Paper – Options Assessment
‘…This submission is short because we believe that the implementation of the NEVA order by the Victorian Government leaves us with virtually no ability to influence the PACR cost benefit analysis. While the NEVA order may speed up the process it does not fill us with confidence that the project will deliver net benefits for […]
EUAA Submission: National Battery Strategy Issues Paper
‘…the proposed National Battery Strategy comes at a time of escalating costs across the entire economy alongside the requirement for rapid transformation of the energy sector, including the need for batteries to provide firming capacity and other network services. For EUAA members, electricity and gas costs have risen significantly and while there is still much […]