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CEC Submission on the National Construction Code 2025 Public Comment Draft

The Clean Energy Council welcomes the opportunity to provide feedback on the National Construction Code 2025 Public Comment Draft to the Australian Building Codes Board. We address clauses within both Volume One and the Housing Provisions, relating to installation of solar in commercial buildings (J9) and assisting future electrification and EV charging in homes (13.7).

CEC Submission on Minimum Standards for Victorian Rental Properties & Rooming Houses

Energy performance is an ongoing concern for Australian households, with rental properties less likely to have energy efficient appliances and access to consumer energy resources. The CEC commends the Victorian Government for the prioritisation of minimum standards in rental properties, placing the state as a national leader in energy performance requirements for renters. We view these changes as essential steps in achieving Victoria’s clean energy transition and ensuring equality for traditionally excluded consumer groups in energy policy.

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.

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.

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.”

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.

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.

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.