EUAA Submission: AER Basslink Consultation Paper – Commencement & Process Paper Amendment
Emily Wood | May 31, 2024
‘… 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 considering whether Basslink should become a TNSP, AER also need to consider whether it would become regulated or remain unregulated. In this regard, consideration should be given to the future competitive state of transfer capability between Victoria and Tasmania once Marinus Link is operating. Specifically, will moving to a regulated asset status provide Basslink a degree of consumer supported protection from Marinus Link.
- The disbursement of tariff allocation between Victoria and Tasmania has many nuances due to population differences and may create inequitable outcomes.
- If regulated, a Regulated Asset Base (RAB) will need to be decided that considers the real value associated with Basslink. For example, we would reject any approach that sought to value the asset on “replacement value” basis rather than written down value.
- Likewise, the Maximum Allowed Revenue (MAR) will need to be considered, which is affected by the equitable allocation of the revenue stream and the RAB.
- The additional opportunity to consult on this matter through the proposed AER position Paper and public forum will allow EUAA and other stakeholders to better consider the application.
- The consequential delay in the AER publishing its final decision from 15 December 2024 to 28 February 2024 will not significantly impact APA…’
Please download attachment to read full submission.
