Energy Consumers Australia appreciates the opportunity to comment on the Australian Energy Market Commission’s (AEMC) Coordination of Generation and Transmission Investment – Access Reform: Directions Paper (the Paper) of June 2019.
The CoGaTI process is one of a number, such as the Integrated System Plan (ISP) and the Energy Security Board’s Post 2025 Market Design process, that are seeking to ensure that the transition of the electricity system occurs in a way that maximises affordability for consumers without compromising reliability.
We note that the ‘Step Change’ scenario that is being included in the 2020 ISP will provide a view of the least cost pathway to a net zero carbon energy sector. As you know net zero carbon by 2050 is an objective already adopted by a number of State Governments. The cost impact of a lack of integrated energy and emissions reductions policies which leads to poorly timed investment cannot be borne by consumers as the sector transitions to increased renewables.
In this submission we note consumer priorities as revealed by our Energy Consumer Sentiment Survey together with the observations of consumer advocates who were briefed by AEMO staff. We generally support the development of locational marginal prices, but believe the AEMC needs to undertake more detailed modelling of the impact of this move and of the operation of Financial Transmission Rights before further development of the approach.
The full submission can be read here.