The Clean Energy Council influences policy and practice on behalf of our members, accelerating the transformation of Australia's energy system into one that is smarter, cleaner and more consumer-focused.

An important part of our approach is responding and contributing to government- and agency-led inquiries, papers, reviews, plans and programs.

May 2017

#26 May 2017
South Australian Energy Security Target draft regulation 
Submission to the South Australian Government
The CEC's submission explains that the South Australian Government's draft regulation to implement an Energy Security Target would restrict competition and deter renewable energy deployment in South Australia. This is likely to result in broader ramifications for the South Australian economy, including a reduction in economic development and a decline in jobs in regional areas.  

19 May 2017
Five-Minute Settlement Rule Change Directions Paper
Submission to the Australian Energy Market Commission (AEMC)
The submission supports the move to align settlement and dispatch on the basis that this is a more efficient market design. However, the key to the success of the rule will be the transition and implementation.

12 May 2017
Climate Change Policies Review
Submission to the Department of the Environment and Energy
The CEC welcomes the climate change policies review and its affirmation that clear policy settings and near-term strategic settings will be required to deliver on Australia’s Paris climate agreement emissions reduction targets for 2030.

March 2017

#21 March 2017
System Security Market Frameworks Review, Directions Paper
Submission to the Australian Energy Market Commission (AEMC)
The AEMC is reviewing approaches to maintaining power system security in the context of increasing new generation technology in the NEM, and is proposing a package of reforms. The CEC’s submission provides specific feedback on the proposed reforms and urges that power system security be considered in the context of a different fuel mix.

#17 March 2017
Market Ancillary Services Specification Stage 1 Consultation
Submission to the Australian Energy Market Operator (AEMO)
The CEC's submission to AEMO recommends a major rethink of ancillary services in the NEM, and the specifications that underpin the existing ancillary services regime. 

#6 March 2017
Independent Review into the Security of the National Electricity Market
Submission to Australia's Chief Scientist, Professor Alan Finkel AO
In this submission, the CEC argues that the market is falling behind technological change and that there is a need for major reform to meet Australia’s Paris Treaty targets by 2030. Renewable energy will play a critical role in achieving this target but stable and sound policy settings are required to support investment in the sector.

February 2017

#9 February 2017
Australian Energy Market Commission's (AEMC) rule changes
Submission to the AEMC
The AEMC is consulting on two rule changes related to contestability in the energy services market. More competition in the energy services market will benefit all consumers and help to prepare our electricity system for the changes ahead. In particular, the CEC strongly supports the proposal for a ‘truncated RIT-D’ with a reduced threshold.

#2 February 2017
Electricity Network Economic Regulatory Framework Review
Submission to the Australian Energy Market Commission (AEMC)
The COAG Energy Council has tasked the AEMC to annually review the electricity network economic regulatory framework. The CEC supports the proposed approach to the review and raises three key issues.

January 2017

#31 January 2017
Transmission connections and planning rule change, draft rule submission
Submission to the Australian Energy Market Commission (AEMC)
The AEMC is finalising their rule change on contestable transmission connections. The CEC's submission supports the Commission’s proposal with a number of small changes that would clarify the rule and assist connecting generators.

#31 January 2017
Inquiry into licensing arrangements under the Electricity Act 1996 for inverter-connected generators
Submission to the Essential Services Commission of South Australian (ESCOSA)
The CEC's submission to ESCOSA's review of license conditions for wind, solar and large-scale energy storage rated above 5 MW calls for the commission to reconsider their current generator licence conditions and resist calls for onerous connection requirements unless a detailed study can be provided to demonstrate these are useful.

#19 January 2017
Distribution market model
Submission to the Australian Energy Market Commission (AEMC)
The AEMC's project on the future of the distribution market model is considering changes that would enable distribution network businesses to move from being asset owners and operators to being providers of market platforms, or for other parties to take on this role. 

December 2016

#19 December 2016
Orientation of collectors for solar heated water systems
Submission to the QLD Government
The CEC supports allowing the solar collectors of solar water heaters to be installed within 90 degrees of north.

#16 December 2016
NSW Climate Change Fund draft strategic plan
Submission to the NSW Office of Environment and Heritage
The CEC supports the draft plan and the several other positive reforms being undertaken by the NSW Government as a part of the Environmental future funding package. This submission focuses on the role that renewable energy can play in achieving the goals in the draft plan, including reverse auction design, grid connection processes and community energy benefits.

#12 December 2016
Distributed generation inquiry draft report
Submission to the Victoria's Essential Services Commission
The CEC supports a proposal to establish a market for grid services provided by distributed generators. Major opportunities exist to improve the network value of solar PV systems. 

November 2016

#28 November 2016
Above 30 kW to 5 MW Embedded Generating System Connection Standard for Queensland
Submission to Energy Queensland
The CEC lodged a submission setting out improvement to grid connection standards for Energy Queensland. With input from CEC members the submission calls for increased transparency on connection studies and reasons for changes to PV system sizes. It also notes the benefits of standardises engineering solutions and how these can increase the efficiency of many projects.

#25 November 2016
NSW Environmental Impact Assessment Improvement Project
Submission to the NSW Department of Planning and Environment
The CEC's submission emphasises the need for clarity and consistency within planning frameworks. The CEC supports the improvement project as well as the several other positive reforms being undertaken by the NSW Department of Planning and Environment. We eagerly await the release of the final wind farm planning guideline.

#4 November 2016
Energy conversion model stage 3 consultation, draft determination
Submission to the Australian Energy Market Operator
The CEC's submission requests that wind and large-scale solar farms be given an enhanced opportunity to manage their risk and participate in frequency regulation services.

October 2016

26 October 2016
SA, ACT, NSW and QLD Tariff Structure Statements
Submission to the Australian Energy Regulator (AER) 
The CEC supports moves toward more cost-reflective distribution network tariffs. In this submission the CEC calls on the AER to collect data on changes in electricity consumption of customers on the new tariffs, the technologies that enabled those changes, customer attitudes and how many customers transitioned to the new tariffs. 

#21 October 2016
Emergency over- and under-frequency control schemes
Submission to the Australian Energy Market Commission
The CEC's submission calls for emergency frequency management schemes that encourage providers to innovate and make efficient decisions. 

#21 October 2016
System Security Market Frameworks Review
Submission to the Australian Energy Market Commission
The electricity system is undergoing fundamental technological change and its rules and regulations must keep pace. The CEC's submission calls for a forward looking market that encourages new technologies to take part. This requires rules that are truly technology neutral. 

#4 October 2016
Stand-alone energy systems in the electricity market
Submission to the COAG Energy Council
The CEC recommends that stand-alone systems should be licensed. There should also be either a licensing system or an industry accreditation scheme for managers responsible for the operation and maintenance of stand-alone energy systems.

September 2016

#20 September 2016
Energy Storage Registration Consultation Paper
Submission to the COAG Energy Council
The CEC welcomes the establishment of a battery storage register. However, the design and implementation of the register must be carefully considered to ensure it delivers value for the range of stakeholders and institutions focused on battery storage, while being practical and not overly burdensome.

#20 September 2016
SA Power Networks Tariff Structure Statement
Submission to the Australian Energy Regulator
SA Power Networks continues to propose network tariffs that would discriminate against solar customers. The CEC’s preference is for demand-based tariffs to be introduced on an ‘opt-in’ or ‘opt-out’ basis. 

#16 September 2016
Future Power System Security (FPSS) Program Progress Report
Submission to the Australian Energy Market Operator
The CEC's submission explains that the Frequency Control Ancillary Services (FCAS) regime has been neglected over the years. It has failed to keep up with the evolving technology landscape and is unnecessarily inefficient. 

#14 September 2016
Termination of the anti-dumping investigation
Submission to the Anti-Dumping Commissioner
The Anti-Dumping Commissioner proposes to terminate the investigation of alleged dumping of PV panels from China. The CEC welcomes the decision. The submission describes the steps the CEC has taken to ensure that consumers have access to accurate information regarding the country of manufacture of the PV panels they are considering purchasing. 

#12 September 2016
Tasmanian Energy Security
Submission to the Tasmanian Energy Security Task Force
This submission highlights the role of additional renewable energy as a contributor to the state’s energy security. New wind and solar capacity can reduce reliance on hydro generation allowing water storages to be co-optimised with the state’s energy needs in prolonged dry periods. 

#9 September 2016
ESCoSA review of the retailer feed-in tariff
Submission to the Essential Services Commission of South Australia (ESCoSA) 
ESCoSA is considering whether to deregulate the feed-in tariff paid by electricity retailers to their South Australian customers. The Clean Energy Council has called on ESCoSA to consider adopting the approach currently under development by the Victorian Essential Services Commission.

#5 September 2016
NSW Wind Energy Planning Framework
Submission to the NSW Department of Planning and Environment
The CEC supports the development of the framework and the replacement of the draft Wind Farm Planning Guidelines which have remained in place since December 2011. An updated framework which provides clarity and certainty for communities, landowners, developers, operators and regulators is critical.

#2 September 2016
Energy Conversion Model Stage 2 Consultation, Draft Determination
Submission to the Australian Energy Market Operator (AEMO)
The CEC provided a submission to AEMO’s Energy Conversion Model Guidelines consultation that raised issues with the Frequency Control Ancillary Services (FCAS) market.

August 2016

#31 August 2016
Victorian Renewable Energy Auction Scheme
Submission to the Victorian Government
The CEC strongly supports the proposal for a Victorian Renewable Energy Auction Scheme and recommends some key principles for the auction design.

#26 August 2016
Energy Conversion Model Stage 2 Consultation, Draft Determination submission
Submission to the Australian Energy Market Operator (AEMO) 
The submission highlights some of the major challenges that prevent South Australia’s wind farms from easily participating in the Frequency Control Ancillary Services (FCAS) market.

#11 August 2016
AER draft decision on SA Power Networks Tariff Structure Statement
Submission to the Australian Energy Regulator (AER)
SA Power Networks' (SAPN) proposal for a discriminatory, anti-solar network tariff is dead and buried following the AER's draft decision. The CEC will continue to work with SAPN, encouraging them to continue with network tariff reform while insisting the reform process must not discriminate against solar and storage customers, which we strongly oppose.

#1 August 2016
Discussion paper on the network value of distributed generation
Submission to the Essential Services Commission
Victoria’s Essential Services Commission (ESC) is reviewing feed-in tariffs and is seeking to determine the true value of distributed generation. In our submission to the ESC, the CEC makes recommendations on issues such as the scope of the review’s approach, definitions, components and characteristics of the network value of distributed generation, conceptual frameworks and methodologies for analysis of the network benefits, and sources of data for analysis.

July 2016

#4 July 2016
Competition for tranmission connections
Submission to the Australian Energy Market Commission (AEMC)
This submission calls upon the AEMC to create new market rules that encourage competition in new transmission connections. The submission supports a range of measures to improve the connection process for large-scale renewables.

June 2016

#27 June 2016
ERC0201 Five Minute Settlement Rule Change, Consultation Paper Submission
Submission to the Australian Energy Market Commission (AEMC)
This submission now recommends that the AEMC undertakes a more comprehensive investigation of options to settle the wholesale electricity market on a five-minute-basis. The CEC’s view is that it is worth understanding this issue and, potential risks and opportunities in order to appropriately advise future electricity market design.

#10 June 2016
Queensland Renewable Energy Expert Panel Issues Paper
Submission to the Queensland Renewable Energy Expert Panel
The Palaszczuk Government has already made an excellent start with its commitment to buy electricity from 120 MW of new large-scale solar generation in Queensland. This is an approach strongly supported by CEC. In this submission we also point to renewable energy policy initiatives adopted by other state governments that could be emulated in Queensland.

#6 June 2016
AER Electricity Ring-Fencing Guideline, preliminary positions paper
Submission to the Australian Energy Regulator (AER)
The CEC's submission focusses on risks to competition caused by networks moving into the solar and storage space. Fundamentally, it asked for appropriate rules to ensure a level playing field across the solar and storage market.

#6 June 2016
Distributed Generation Inquiry Stage 1 Draft Report - The Energy Value of Distributed Generation
Submission to the Essential Services Commission (ESC)
The CEC welcomes the recommendations of the draft report and strongly supports the proposed approach with one amendment for consideration.

April 2016

#20 April 2016
ActewAGL's Tariff Structure Statement
Submission to the Australian Energy Regulator (AER)
The CEC has called on the AER to require ActewAGL to provide an assessment of the groups of customers that would be adversely affected by its proposed Tariff Structure Statement. 

#20 April 2016
SA Power Networks' Tariff Structure Statement
Submission to the Australian Energy Regulator (AER)
SA Power Networks’ proposed Tariff Structure Statement risks a public backlash that would undermine support for tariff reforms. The CEC is calling for all distribution networks to give residential and small business customers the choice of whether to take on a demand-based tariff. 

March 2016

#31 March 2016
Community Consultative Committee (CCC) guidelines - state significant projects
Submission to the NSW Department of Planning and Environment
Our submission recognises the benefits of clear guidelines for running CCCs and selecting participants, and praises the NSW Government for treating wind farms consistently with other types of infrastructure. Our submission raises concerns with the reviewing powers of the committee, the requirement for companies to provide training, and asks that the committee acknowledge the development process and timeline when requesting designs and reports. 

February 2016

#26 February 2016
Dumping investigation into photovoltaic panels exported from China
Submission to the Anti-Dumping Commission
The CEC highlights a litany of failures and problems arising from protracted investigation into alleged dumping of PV modules from China. Crucial issues have not been addressed and the recommendations of the Anti-Dumping Review Panel (ADRP) have created even more confusion.

#11 February 2016
Proposed approach to the inquiry into the true value of distributed generation
Submission to the Essential Services Commission (ESC)
Victoria's ESC is conducting an inquiry into the true value of distributed generation. The CEC broadly supports the approach proposed and makes further recommendations.

January 2016

#28 January 2016
Submission on increasing competition for grid connections
Submission to the Australian Energy Market Commission
The CEC supports the principles of the Australian Energy Market Commission’s rule change on the connection of large-scale generation to transmission grids, while making some specific concessions and recommendations.

#19 January 2016
Response to SA Power Network's Tariff Structure Statement
Submission to SA Power Network
Electricity distribution businesses are changing the way they charge for the use of their poles and wires. SA Power Networks’ policy carries with it considerable political, economic and social risks. The CEC argues against this approach. 

#15 January 2016
Response to ActewAGL's Tariff Structure Statement
Submission to ActewAGL
Electricity distribution businesses are changing the way they charge for the use of their poles and wires. ActewAGL has proposed mandatory assignment of some customers to new, demand-based tariffs. The CEC argues against this approach. 

#14 January 2016
Response to Ergon Energy's Tariff Structure Statement
Submission to Ergon Energy
#Response to Energex's Tariff Structure Statement
Submission to Energex
Electricity distribution businesses are changing the way they charge for the use of their poles and wires. Energex and Ergon Energy will allow customers to choose whether they opt-in to new demand-based pricing arrangements. They will trial new customer engagement strategies that encourage the adoption of emerging energy-related technologies. The CEC supports this approach.

#6 January 2016
Issues Paper on Tariff Structure Statement proposals
Submission to the Australian Energy Regulator
Electricity distribution businesses are changing the way they charge for the use of their poles and wires. The Victorian Government will allow customers to choose whether to stay on their current pricing or opt-in to new arrangements. The CEC supports this approach and calls on other states and territories to follow Victoria’s lead.

Archive

You can view past Clean Energy Council submissions on the submissions archive page.