Energy Consumers Australia appreciates the opportunity to comment on the Australian Energy Market Commission’s (AEMC) Enhancement to the Reliability and Emergency Reserve Trader: Options Paper (the Paper).^[1]https://www.aemc.gov.au/rule-changes/enhancement-reliability-and-emergency-reserve-trader

This paper forms part of the AEMC’s process for considering a rule change proposal made by the Australian Energy Market Operator (AEMO). We have participated in the AEMC’s public workshop and have also participated in the Technical Working Group. The views in this submission reflect our contribution in these forums.

We are concerned about the affordability implications of what is proposed and do not support a change to the RERT framework or the reliability settings at this stage. The experience in the last ten years shows the danger of getting the reliability settings wrong, where network reliability standards were increased in some jurisdictions without enough regard to what that would mean for prices and affordability.^[2]https://www.accc.gov.au/publications/restoring-electricity-affordability-australias-competitive-advantage

In this submission we provide a snapshot of what consumers are telling us about affordability and reliability, about their willingness to contribute to the reliable and secure operation of the system through demand response, and comment on security and reliability in a transitioning market.

The full submission can be read here.