The original intent of the Clean Energy Council's Investor Certainty in the pre-connection registered data (R1) process was to provide clarity for connecting generators around timelines and processes during the R1 stage of the connection process. This informed the development of our clearly articulated and defined proposed ‘Type’ model approach.
The draft rule is a good start in addressing this first issue. However, more is needed to impose discipline to ensure that additional modelling is only requested where this is clearly necessary to manage system security. The draft rule places very little restraint on what modelling can be requested and we remain concerned the historic issues that have imposed major costs on connecting parties will remain largely unresolved.
The second objective of the CEC’s original rule change was to move forward the discussion regarding who is best placed to manage the kinds of general power system issues that may arise and impact on a connecting generator moving through the R1 process. Our recommendation was that NSPs are best placed to hold this risk, on the basis they have access to all relevant information and can harness scale economies to resolve issues at lowest cost.
We recommend the The Australian Energy Market Commission’s (AEMC) give further consideration to this issue. The kinds of network issues that can delay connections in the R1 stage are likely to become more material as the pace of the transition accelerates, imposing greater uncertainties and costs on connecting generators. The CEC considers overall system costs will be minimised where risk is allocated to the parties who can manage it at the lowest overall cost.
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