EUAA Submission: National Electricity Amendment (Enhancing Reserve Information) Rule 2024

EUAA Submission: National Electricity Amendment (Enhancing Reserve Information) Rule 2024

Emily Wood | February 8, 2024

‘…Thank you for the opportunity to make a submission for AEMC’s Draft Determination for the Enhancing Reserve Information (formerly the Operating Reserve Market) rule change.  This submission supports the submission made by EUAA Supporting Member, Shell Energy on this matter. EUAA is supportive of the AEMC’s draft determination in that:

  • the AEMC will not proceed with a potentially costly Operating Reserve Market;
  • the AEMC is proposing that state of charge and maximum storage capacity of batteries, aggregated by region, will be published in close to real-time and following trading by dispatchable unit identifier (DUID), to align with existing post-trading day publications and that energy constraints on other scheduled plant (hydro, gas and coal) would be aggregated by region and published daily; and
  • The AEMC will not change Frequency Control Auxiliary Services (FCAS) procurement processes, including regional and proposed sub-regional procurement frameworks without a separate rule change process.

However, we are disappointed that the AEMC will not pursue expanding AEMO’s requirements to report on forecast accuracy of Lack of Reserve (and other) forecasts to improve transparency and provide a feedback loop directly to AEMO and consumers demonstrating either areas of forecasting that need improving or that the forecasting is meeting NEM requirements.  This would also be a useful tool to ensure that all market participants continue to act in good faith at all times…’

Please download attachment to read full submission.


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