EUAA Submission: Thermal Generator Variable Heat Rates
Emily Wood | August 7, 2020
‘As energy users we have no material view on thermal generator heat rates, but wanted to use this process to respond to your general invitation to comment on the updated cost benefit analysis.
We recognise the difficulty faced by project proponents in such a challenging and highly volatile environment and appreciate that many assumptions and key inputs used in the original RIT-T application have and are likely to continue, to change. This clearly represents risk for project proponents but it represents even greater risks for consumers who will be faced with paying “full weight” for assets that may not deliver the stated benefits, that could experience lengthy periods of low utilisation or in the case of Renewable Energy Zones, a degree of stranded asset risk if renewable energy projects are not repowered at the end of their 20 year asset life.
In the absence of a shared cost framework or direct government support to help manage some of these costs and risks, consumers are left with no choice but to focus heavily on key financial and risk aspects of the project. In the case of EnergyConnect we are particularly concerned about the continually increasing capital cost and constantly changing net market benefits.’
Please download attached for full submission.