We appreciate the opportunity to comment on the Australian Energy Market Commission’s (AEMC) consultations on the proposed rule changes about the financeability of the Integrated System Plan (ISP) Projects. This submission addresses both TransGrid and ElectraNet’s rule change requests.

We do not support the proposed rule change. Governments, policy makers, regulators and industry together need to explicitly consider not just the security and reliability of the energy system, but also the affordability, for consumers and industry alike, throughout the planning and decision making processes. Our view is that trust and confidence is built through steady or declining prices and is undermined by price volatility.

In our submission we talk through our concerns with the current model, consumers capacity to pay, risk allocation and investment. Read it here.