EUAA Submission: Draft 2020 Integrated System Plan

EUAA Submission: Draft 2020 Integrated System Plan

Emily Wood | February 21, 2020

‘The EUAA welcomes this opportunity to comment on the Draft 2020 Integrated System Plan (ISP) and congratulate AEMO on the improvements to stakeholder engagement in recent months. We encourage AEMO to continue to evolve its approach to stakeholder engagement as a means of improving understanding of the ISP and building stakeholder trust in the outcome.

However, the ISP has moved beyond being a plan to guide investment decisions to a plan that directs investment decisions, largely driven by the desire of COAG Energy Ministers to make the ISP actionable. While on the surface this seems a worthwhile objective, it is not without its risks. In particular we should not be sacrificing sound governance practices, such as diminishing the role of the AER or removing important checks and balances in the independent economic assessment process in order to achieve an expedited result.

With the ISP, AEMO are engaged in a high stakes process that seeks to balance the risks of not acting quickly enough to enable a smooth transition of the energy market and acting too quickly or taking actions that may prove unnecessary where consumers may be forced to pay for underutilised or stranded assets. This task is made more difficult by the rapid pace of technological change and a volatile political environment…’

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