Energy Consumers Australia appreciates the opportunity to comment on the Australian Energy Market Operator’s (AEMO) Reliability Forecasting Methodology Issues Paper: How to produce the reliability forecast under the Retailer Reliability Obligation of April 2019 (the Paper) and to participate in the workshop on 9 May 2019.

The Retailer Reliability Obligation (RRO) is an important market-based reform, and we welcome the opportunity to participate in the design of the detailed implementation arrangements. We have commissioned Finncorn to provide advice on aspects of this work which is included in the submission. It is important to note that this work does not represent an ECA position, but is used to identify areas for further engagement and thinking.

The RRO is a useful tool for signaling additional investment needs. However, we need to ensure that it is appropriately calibrated. Conservatism in the approach to the T-3 Reliability Gap forecast and treatment of new entrant generation risks increasing costs to consumers for little, or possibly no, benefit.

The full submission can be read here.