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Enhanced Locational Information (ELI) report AEMO

The CEC consider that the information is useful insofar as it assists developers to initially screen for opportunities (including in areas where there are high congestion levels and where storage and non-network solutions could alleviate congestion and/or increase hosting capacity). We consider that additional information could be included in future ELI reports. This includes a more detailed breakdown of categories of information already included in the 2024 ELI Report relating to generation and storage as well as forward looking information, including headroom forecasts. This will enable developers to better identify opportunities for projects which will release additional energy into the grid and increase hosting capacity.

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Submission

22 Jul

Retailer Reliability Obligation rule change

The CEC supports the proposed rule change on the principle of encouraging optimal utilisation of batteries. The number of batteries and energy storage assets generally will continue to grow. This will provide significant additional benefits to the power system, helping to reduce the total cost of the transition for consumers. Storage can provide a wide range of services, such as fast and very fast FCAS, inertia and system strength, as well as system integrity protection schemes, all of which provide material benefits to consumers.

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Submission

22 Jul

ISP rule change

The CEC supports the proponent’s proposed changes to the NER to expand the Australian Energy Market Operator’s (AEMO) authority and requirement that it give more complete and detailed consideration of gas infrastructure in its Integrated System Plan (ISP) analysis; improve AEMO’s ability to analyse the uptake, availability and value of consumer energy resources to allow for better integration of demand-side factors in the grid; and ensure the ISP gives regard to known community concerns or sensitive locations in setting the parameters for projects. Enabling and obligating AEMO to update its ISP methodology and analysis to undertake and incorporate gas market analysis, including the cost of gas infrastructure investments, would support meeting the National Energy Objectives (NEO) in several ways compared to the current ISP approach more fully.”

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Submission

22 Jul

Cyber security rule change

The CEC agrees to formally recognise AEMO in the coordinator role on matters related to cyber security. Market participants benefit from having clear direction when following cyber security procedures, especially since these apply differently to different levels of the energy supply chain. The CEC proposes that the role of cyber security for AEMO is specifically defined in the NER as part of the power system security function. This role would align with other system security responsibilities.

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Submission

22 Jul

Submission on the ‘Future Made in Australia: Unlocking Australia’s low carbon liquid fuel opportunity’ consultation paper

The Australian Government sought views on the options and design of supply and demand measures to support a domestic low carbon liquid fuel (LCLF) industry, as part of the Governments ‘A Future Made in Australia’ initiative.

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Submission

19 Jul

Submission on the proposed Hydrogen Production Tax Incentive (HPTI)

Treasury sought feedback on the proposed design implementation details of the Hydrogen Production Tax Incentive announced as part of the Future Made in Australia package announced in the 2024-25 Federal Budget.

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Submission

19 Jul

CEC Submission on draft determination and rule on Enhancing investment certainty in the R1 process ERC0363

The original intent of the Clean Energy Council's Investor Certainty in the pre-connection registered data (R1) process was to provide clarity for connecting generators around timelines and processes during the R1 stage of the connection process. This informed the development of our clearly articulated and defined proposed ‘Type’ model approach. The draft rule is a good start in addressing this first issue. However, more is needed to impose discipline to ensure that additional modelling is only requested where this is clearly necessary to manage system security. The draft rule places very little restraint on what modelling can be requested and we remain concerned the historic issues that have imposed major costs on connecting parties will remain largely unresolved. The second objective of the CEC’s original rule change was to move forward the discussion regarding who is best placed to manage the kinds of general power system issues that may arise and impact on a connecting generator moving through the R1 process. Our recommendation was that NSPs are best placed to hold this risk, on the basis they have access to all relevant information and can harness scale economies to resolve issues at lowest cost. We recommend the The Australian Energy Market Commission’s (AEMC) give further consideration to this issue. The kinds of network issues that can delay connections in the R1 stage are likely to become more material as the pace of the transition accelerates, imposing greater uncertainties and costs on connecting generators. The CEC considers overall system costs will be minimised where risk is allocated to the parties who can manage it at the lowest overall cost.

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Submission

17 Jul

WA Design Paper – Capacity Investment Scheme

The Clean Energy Council considers there could be a risk of misalignment of the WA Capacity Investment Scheme (CIS) and Reserve Capacity Mechanism (RCM) process, through project delays or reductions / cancellation of capacity credits for a CIS Agreement (CISA) project. To ensure alignment, we recommend consideration of processes such as the expedited assessment of CISA projects as critical projects and / or the early certification of reserve capacity being automatically granted (on a conditional basis) when the CISA contract is awarded. Further detail is needed on how delays in the commercialisation of a project will be dealt with. Consideration should be given to permitting projects to operate in the wholesale electricity market (WEM) until they can participate in the RCM. We recommend that eligibility criteria be reviewed to include projects with NCESS contracts and to ensure VPPs using DER resources are included in the second and third rounds of clean dispatchable tenders. In relation to projects which do not qualify for a CISA, we request the Department of Climate Change, Energy, the Environment and Water (DCCEEW) give consideration as to how those projects will be impacted by the WA CIS and release any modelling on the proposed WA CIS’s impact on capacity market and energy markets in the South West Interconnected System (SWIS).

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Submission

17 Jul