RE-Alliance supports the proposed New England Access Scheme as an opportunity to establish consistent minimum standards of community engagement, First Nations engagement, benefit sharing and regional participation across large-scale renewable energy projects in the New England Renewable Energy Zone (REZ).

The Scheme should give host communities greater confidence that every project granted access to the REZ will meet a clear and consistent standard of behaviour.

We broadly support the approach of applying an access scheme to the New England REZ as outlined in the consultation documents.

We make the following key comments and recommendations in relation to the proposed Access Scheme:

• Implement the Access Scheme - We support the proposed approach of applying access assessment processes and fees to new and existing network infrastructure. We believe the Access Scheme (including the Access Rights Regime and the Access Control Mechanism) will give improved confidence that appropriate community engagement and community benefits will be delivered, and help to provide a clear signal to developers and communities that projects with Access Rights or an Access Consent are those that are more likely to proceed. Eligibility for access to the network must also ensure sufficient capacity is maintained to support local farms and other rural and regional businesses to move to electrification and the use of renewable energy on site.
• Set clear minimum standards - We support the use of merit criteria to award Access Rights, noting that the proposed minimum standards for Access Consents must also be considered as the minimum standard for this process. We support the proposal that projects receiving an Access Consent must meet clear minimum requirements but believe the regional participation criteria should be made an assessable response criteria. Commitments made in relation to community benefits under merit criteria and minimum assessment criteria for Access Consents must apply from the date at which the Declaration is made and continue to be met through any project modifications.
• Strengthen draft assessment criteria - The current proposals in relation to community engagement, First Nations engagement and participation and benefit sharing should be strengthened, building on the standards already established through NSW Roadmap tenders, including the social value requirements and New England First Nations Guidelines. We discuss this recommendation in more detail below. We support the proposal to require proponents to be rated under the Developer Rating Scheme.
• Ensure commitments are enforceable - Replace discretionary language such as “endeavours” in core community, First Nations and benefit-sharing requirements with clear commitments and obligations, while retaining flexibility in how proponents deliver them in response to local circumstances.
• Ensure early community engagement - Require proponents to demonstrate an initial community and First Nations engagement approach at the access stage, followed by progressively more detailed plans as projects mature. Minimum First Nations engagement requirements should incorporate the New England First Nations Guidelines and align with the principle of Free, Prior, and Informed Consent (FPIC) as reflected in Capacity Investment Scheme (CIS) Tender 10.
• Improve transparency - Require appropriate information on community, First Nations and benefit-sharing commitments, and progress against those commitments, to be published through the Access Scheme Register. Ensure communities are consulted when there are substantive changes to the Declaration that may affect them and any community benefits the Access Scheme may provide.
• Ensure appropriate scheme duration and benefits - Ensure Community and Employment Benefit Program (CEBP) contributions continue for the operating life of projects where this extends beyond the term of the Access Scheme.

Read more in our full submission.