Clean Energy Council submission on consultation paper – Transmission Access Reform EPR0098

The Clean Energy Council strongly recommends further work on the Transmission Access Reform (TAR) project be stopped as soon as possible. Recognising the Australian Energy Market Commission (AEMC) has been tasked with recommending a pathway forward to Ministers, we consider it would be appropriate and accurate for the AEMC to recommend to Ministers that the costs and uncertainties associated with continuing with TAR at this point in time outweigh any of the theoretical benefits of the reform.

Our reasoning for making this recommendation is set out in more detail in the submission. In brief, we consider that work on TAR be stopped as we consider that the reforms being considered:

• increase consumer energy bills through increases in wholesale prices
• require more transmission and REZ infrastructure to be built
• are inconsistent with the new emissions reduction objective in the National Electricity initiative (NEO)
• fail to address purported issues around disorderly bidding and inter regional counter price flows
• undermine existing jurisdictional schemes
• are largely unnecessary given the roll out of jurisdictional policies.
• do not adequately consider the extent to which the market is already responding to congestion, through installation of energy storage with new generation:
• are likely to run counter the work of the Connection Reform Initiative and reduce the effectiveness of the connection process