EUAA Submission: ESB Post 2020 Market Design Issues Paper
Emily Wood | September 30, 2019
‘…it is with a strong sense of Deja Vu that we welcome the opportunity to make a submission to the Energy Security Board (ESB) Post 2025 Market Design Issues Paper. There seems to be striking similarities between the work being done on a post 2025 market design and the Finkel Review that was completed in June 2017.
While many of the Finkel Review recommendations have either been implemented or are in the process of being implemented, given the highly disjointed nature of the policy response to date (at both state and federal level), the core issue of the best approach to managing the “Energy Trilemma” of price, reliability and emissions, remains largely unresolved. When this is combined with an ever-accelerating transition of our energy system, new risks and challenges for all market participants continue to be created.
Running parallel to the issues raised in this discussion paper are a number of significant processes that continue to evolve including the AEMO Integrated System Plan (ISP) and the AEMC Coordination of Generation and Transmission Investment (COGATI), the AER Value of Customer Reliability (VCR) review and the proposed Wholesale Demand Response Market.
These major reform processes continue to move ahead while other recommendations from Finkel Review and ACCC Retail Electricity Markets Review continue to be rolled out.
All of this parallel work will drive significant change in energy markets at a time when the post 2025 model, which has to be finalised by end of 2020, is occurring including 5-minute settlement, retailer reliability obligation, wholesale demand response market and outcomes from the current AEMC COGATI program including nodal pricing and transmission hedges.
While we acknowledge that the ESB has also recognised these parallel work programs we want to emphasise the importance of timing and coordination of the various reforms being considered. We would be disappointed to see further confusion created by overlapping agendas and poor coordination.’
See attached submission for full details.