EUAA Submission: National Electricity Amendment (Improving Security Frameworks For The Energy Transition) Rule Change 2023

This short submission supports the submission made by Shell Energy on this matter. In addition, the EUAA would like to emphasise the following points:

• The EUAA strongly recommends that the AEMC’s next step is to release for comment a new Draft Determination and not proceed directly to a Final Determination. The EUAA believes that the changes from the original Draft Determination and the current Second Directions Paper are substantial and a new Draft Determination is required to keep with consultation requirements of the NEL on Rule Changes.
• The EUAA strongly supports Shell Energy’s position that beneficiaries pay for the provision of Essential System Security (ESS) services, and not consumers. EUAA’s supports rule changes to improve the efficiency of markets, improve system security and where the costs and risks are allocated to those best able to manage them, and who benefit from them. The current proposed rule change will improve system security and allow more inverter-based resources (IBR) to access the NEM, providing a clear beneficiary to the Rule Change. Having the IBR beneficiary pay sends a clear market signal to IBR generators to provide ESS services through an efficient, low-cost mechanism….’

Please download attachment to read full submission.