We thank the Australian Energy Market Commission (AEMC) for the opportunity to comment on the Transmission Planning and Investment - Stage 2 Draft Report (the Draft Report).
We note that the AEMC has focussed its thoughts on four reform aspects in the Draft Report:
- Financeability concerns;
- Social licence concerns;
- Cost recovery arrangements for planning activities; and
- Improving the workability of the feedback loop.
Our brief comments on each reform area are below. See our full comments in our submission.
RE-Alliance recommends that further iterations of this report should draw on consultation with the Government, the Australian Energy Market Operator (AEMO) and the Clean Energy Finance Corporation (CEFC), who will be administering the Rewiring the Nation Fund.
Social licence concerns
RE-Alliance is encouraged that the AEMC has recognised social licence as a key issue for consideration in the Review.
We recommend that the AEMC and the Australian Energy Regulator (AER) consider the concept of a Guideline and consult with jurisdictions and assess whether it would be more useful than each individual jurisdiction implementing separate arrangements.
We hope that the Final Report is guided by the Government’s announced priorities and any further development in this area between now and then.
Cost recovery of planning activities
RE-Alliance agrees with the AEMC that the current arrangements could cause some confusion and uncertainty in cost recovery arrangements for both transmission companies and the AER.
We recommend that AEMO and the CEFC, who will be administering the Rewiring the Nation Fund, give consideration to funding preparatory activities for actionable ISP projects.
Improving the workability of the feedback loop
RE-Alliance agrees with the AEMC that aligning the feedback loops with the publication of a draft or final ISP will improve workability. Further, we agree with the AEMC that Option 2 which involves aligning the feedback loop and project assessment conclusions report (PACR) exclusion window between the final inputs, assumptions and scenarios report (IASR) and draft ISP, with feedback loop requests permitted any other time in the ISP cycle is the preferred option. Aligning the feedback loop with the draft ISP would give more time for the feedback loop to operate. Further delays to the RIT-T process should be avoided if at all possible.