We thank the Australian Energy Market Commission (AEMC) for the opportunity to comment on the Draft Report into Transmission Planning and Investment Review (TPIR)- Stage 3.
We have several overarching comments. The AEMC seeks through its strawperson approach to analyse three proposed ways to speed up the existing approach which involves the Australian Energy Market Operator (AEMO) undertaking the Integrated System Plan (ISP) and then the project proponents undertaking the RIT-T and the AER approving the final expenditure through the contingent project process.
It should be noted that in several jurisdictions State Governments are implementing alternate approaches which bypass the RIT-T altogether.
We note that discussion in the AEMC’s TPIR Stage 3 paper is confined to actionable ISP projects and alternatives are being used by State Governments for Renewable Energy Zone (REZ) projects in Queensland and REZ Network Infrastructure Projects and Priority Transmission Infrastructure Projects as defined in NSW, not actionable ISP projects.
RE-Alliance considers that these options or variations on them should also be considered by the AEMC. It may be that an altogether different approach may be superior to improvements to the existing national framework arrangements.