EUAA Submission: AEMC National Electricity Amendment (Improving The Cost Recovery Arrangements For Transmission Non-Network Options) Rule – Draft Determination
Emily Wood | January 30, 2025
‘… The EUAA is supportive of the Commission’s work in aligning the framework for non-network options (NNOs) arising from a Regulatory Investment Test-Transmission (RIT-T) with the framework for network options, that is by providing an ex-ante review process and allowing TNSPs to receive reimbursement of the costs in the year that it was expended. This creates a more level playing field for NNO against traditional network options.
We were concerned that with the larger scale of NNO, and the likely higher frequency of implementation, there was the potential that TUOS charges to end consumers could be quite volatile year-on-year due to TNSP’s carrying the costs for up to 2 years and then increasing TUOS to recover this at the start of the next regulatory period, which for a single large project will have little impact, however for multiple projects would make budgeting for energy costs even more difficult for large consumers.
We are in the messy middle of the transition, and we need to be strategic with rule changes to stay ahead of arising issues, rather than being reactive and creating pain for many while we await a rule change.
The EUAA is supportive of rule changes that create greater consistency across the NEM. We recognise that the Commission has done its best to align the NNO framework with those for capital expenditure through the RIT-T, and the System Security NNO framework, which is similar but different.
While we were supportive of the principle behind the original proposed rule change, we prefer the alternative rule change that the Commission proposes in its draft determination, including…’
Please download attachment to read full submission.
