Nexa Advisory welcomes the opportunity to respond to the AEMC’s Clarifying the treatment of jurisdictional policies and system costs in the ISP Draft Determination (ERC0406).
Nexa supports the Commission’s draft determination to not make a draft rule in response to this rule change request.
As outlined in our previous submission, the Integrated System Plan (ISP) remains a critical planning and system design roadmap for the National Electricity Market (NEM), and a vital tool which informs investors, policy makers and broader industry as we progress Australia’s clean energy transition.
We agree with the Commission’s finding that the existing rules provide sufficient flexibility for AEMO to consider uncertainty in the ISP, including through sensitivity analysis.
We reiterate previous asks made by Nexa and encourage the AEMC to consider these throughout relevant processes and reviews:
- AEMO should clearly identify the cost impacts of any delays in the timing of actionable projects, if expected timings continue to slip. This is critical to provide a clear signal that the failure to deliver transmission projects on time must be addressed. While this is not intended to directly inform policy decisions, it should support greater transparency on the consumer impacts of delayed transmission delivery.
- AEMO should consider whether a ‘near-end-of-life’ premium should be added to the outage rate of unreliable coal generators, given significant volatility and cost impacts of unplanned outages for these assets as they approach the end of their lives.
- There is an urgent need to better reflect the costs of augmenting the distribution network to better reflect the value of CER and how it can be used to avoid capital-intensive network augmentations. This remains a key concern which must be addressed in the upcoming Electricity Network Regulation Review.
Read our submission here: Nexa Advisory submission – AEMC Jurisdictional policies in ISP Draft Determination