EUAA Submission: AER System Security Network Support Payment Draft Guideline
Emily Wood | October 30, 2024
‘… The EUAA supports AER’s role in ex-ante reviews of draft system security network support payment contracts to ensure that system security investments by TNSP’s are prudent and efficient.
We do, however have concerns with the Draft Guideline as it currently reads.
Firstly, the option Consultation on an application at part 3.4 of the Draft Guideline seems at odds with Part 1.4 Confidentiality.
It would appear to us that consultation will be worthless due to the requirement for redaction of commercial-in-confidence material in the draft contract. We consider that the AER needs to think about what they will be consulting on with stakeholders. Potentially this might be a draft determination rather than the redacted application. Whichever way that the AER proceeds on the consultation process, AER needs to ensure that the consultation is worthwhile for stakeholders and not a “tick-a-box” approach…’
Please download attached document to read fulll submission.
