Dissenting Report - Labor Senators
1.1Labor Senators thank the Chair for his report and for good faith engagement of the Chair through the inquiry process. Labor senators view this dissenting report as necessary for several reasons. While the inquiry has raised issues with respect to the governance and regulation of energy markets that have merit, and some issues which are not supported by robust evidence or not directly relevant to the terms of reference, we feel the Chair’s report and its recommendations largely fail to adequately consider reforms underway, fail to acknowledge past reviews and transparency and consultation processes already in place, and fail to consider the disruptive and duplicative consequences of some recommendations. Labor Senators feel that if all recommendations from the Committee’s report were adopted as policy, they would have the effect of:
Undermining the governance structures of the National Electricity Market (NEM), including the shared responsibilities between states and the Commonwealth with respect to energy market governance,
Undermine the progress of reforms underway,
Undermine the reliability and affordability of energy supply by creating investment uncertainty, and
Diverting valuable resources of government and market bodies from delivering a more affordable and reliable energy system for consumers.
1.2One of the Chair's key contentions is that there is a lack of transparency in energy planning, governance and regulation. Yet this inquiry has demonstrated that such criticism is unfounded. Australia has one of the world’s most open, comprehensive, widely and openly consulted on, and transparently delivered energy system planning mechanisms in the world in the form of the Australian Energy Market Operator’s (AEMO’s) Integrated System Plan (ISP). The ISP is seen internationally as world’s best practise electricity and transmission system planning.[1] Where genuine opportunities for improvement exist, progress is largely already underway, including through reforms to the ISP informed by the recent Commonwealth ISP Review. Indeed, for many of the report’s recommendations that Labor Senators do agree with, work has already begun to enact reforms and improvements that will deliver the stated goals as laid out in the Chair’s report. What will not assist in the achievement of these goals is the imposition of unnecessary, duplicative and meaningless layers of bureaucracy and parallel processes that will do little to improve transparency or outcomes and instead create wasteful, duplicative work at the expense of efficiency and at the risk of creating investor uncertainty.
1.3Labor senators note or agree-in-principle to a number of recommendations but cannot agree with others for these reasons.
1.4This dissenting report seeks to re-centre the conversation on what matters: evidence-based solutions that ensure Australia’s energy transition is practical, equitable, and achievable – delivering the lowest cost electricity for consumers, while delivering a reliable grid and meeting legislated emission reduction goals. Labor Senators affirm the need for strategic investment in transmission and distribution networks, including in new technology and novel solutions to avoid unnecessary capital expenditures, respect for the established regulatory frameworks that govern our energy market, and a commitment to solutions that can be deployed rapidly and economically.
1.5Australians deserve an energy plan that reflects urgency, clarity, and a deep understanding of how our energy sector operates. Instead, the Committee’s report risks stalling progress, creating confusion, and undermining public and investor confidence at a time when certainty and decisive leadership are more critical than ever.
1.6No inquiry on energy planning and regulation in Australia could avoid the underlying imperative to transition the grid to net zero. That this transition represents the most significant shift in the energy grid's makeup since its inception was a key theme of the inquiry.
1.7Unfortunately, Coalition Senators used the inquiry as an opportunity to prosecute an ideological position on nuclear energy, despite a concurrent House inquiry specifically examining nuclear energy generation in Australia (The House Select Committee on Nuclear Energy). Indeed, the amount of time that discussion regarding nuclear energy took up in this inquiry’s hearings is completely disproportionate to the inquiry’s terms of reference or (to the credit of the Chair) even its presence in the final report. It is therefore necessary to briefly highlight concerns raised by many witnesses regarding nuclear energy in Australia’s energy mix.
1.8Several witnesses highlighted the inability of nuclear energy to address the urgent need to transition the grid away from coal within the requisite timeframe, determined by likely coal closure dates as well as the imperative to transition energy to meet emission reduction goals, including in other sectors of the economy. Witnesses cited the lengthy process required to adjust the regulatory environment and the substantial time needed to physically construct nuclear power plants as significant impediments to its adoption in Australia.[2]
1.9Mr Feeney from the Australian Energy Council put it simply when given the hypothetical of nuclear prohibitions being lifted tomorrow: “[I]f it were lifted tomorrow, I don't think it would obviate the need to invest in renewables from a timing perspective.”[3]
1.10Additionally, witnesses discussed the high cost of nuclear energy in comparison to firmed renewables.[4] The economic feasibility of nuclear energy remains a critical concern, with renewable energy consistently proving to be a more cost-effective solution, even when firming and storage costs are taken into account.
1.11Critically, a proponent of nuclear energy, Mr Parker, founder of Nuclear for Climate Australia, advised that reaching net zero by 2050 would likely require the construction of 22 nuclear plants.[5] This figure far exceeds the Coalition's proposed seven plants, starkly illustrating how poorly suited the Coalition’s nuclear energy plan is to addressing Australia’s energy transition needs.
1.12Furthermore, considering the national energy market is at least 40 per cent renewable generation already, Dr McConnell from the University of New South Wales provided testimony underscoring that nuclear energy’s reliance on high capacity factors makes it incompatible with a grid increasingly dominated by flexible and cost-effective renewable energy:
One of the challenges that is facing coal plants today and one of the reasons that they are under increasing economic pressure is renewable energy undermining their preferred profile and utilisation rates as well as prices. You would expect the same dynamics for something like a nuclear power plant in 10-plus years from now. How they interact with renewable energy does present a challenge for their economic viability.[6]
1.13Labor Senators affirm that Australia’s energy grid transition must prioritise reliable, lowest cost renewable energy solutions that can be deployed rapidly and economically to meet the challenges of climate change and energy security.
1.14One of the recurring themes throughout the inquiry was the critical role of both transmission and distribution networks within Australia’s energy grid. Extensive discussions highlighted the distinct functions and challenges of each network and underscored their shared importance in achieving a reliable and renewable energy future.
1.15A key insight from the evidence presented is that the issue at hand is not an "either/or" proposition;[7] rather, investment in both transmission and distribution networks is essential to ensure the grid’s reliability and capacity to integrate renewable energy sources. This dual focus is critical to meeting Australia's energy needs sustainably and equitably.
1.16CEO of Energy Networks Australia spoke to the need for continued transmission investment:
[Coal-fired power stations] are closing because they are ageing and they are becoming less reliable. We are as a society committed to net zero. Removing coal from the electricity system is one of the lowest cost ways to get there. Added to this, we are expecting the electricity grid to increase significantly—to more than double. This necessarily means building new transmission infrastructure to connect energy from where it is produced in the future in the solar and wind rich regions into our cities and our regions.[8]
1.17When questioned on what the consequences of delayed investment in transmission would be, Ms Bashir, CEO of Nexa Advisory was clear: “It’s higher electricity prices.”[9]For this reason alone, Labor Senators view anything that will delay transmission investments, whether it be the creation of regulatory uncertainty, or the promise of a potential federal Liberal government cancelling thus far unspecified transmission projects, as detrimental to consumers and the national interest.
1.18On the distribution side, the Australian Energy Regulator (AER) provided valuable insights with its focus on enhancing the efficiency of distribution networks as a priority before further capital investments are pursued. This approach is necessary to prevent undue financial burdens on consumers, who are at risk of being adversely affected by excessive capital expenditure.
1.19Clare Savage, representing the AER, articulated this approach clearly during her testimony:
The AER is open to addressing barriers to more efficient utilisation of the network and has demonstrated a willingness to look at ring fencing waivers or regulatory sandboxes if it will result in a better outcome for consumers. We need to understand the barriers to the more efficient utilisation of network infrastructure. We need to get crystal clear on the role of distribution system operation. We need to establish what level of network visibility or control over distributor resources is needed to moderate increasing capital expenditure.[10]
1.20Labor Senators are particularly supportive of the AER’s work to address these barriers, which is essential for ensuring that the distribution network operates at maximum efficiency and remains equitable for consumers. Labor Senators also note the endorsement of this work by energy ministers at the recent Energy and Climate Change Ministerial Council (ECMC) meeting in Adelaide on 6 December, noting the Communique statement “Ministers welcomed the initiative of the Australian Energy Regulator on policy led sandboxing to improve access and accelerate deployment and orchestration of CER/DER.”[11]
1.21Criticism of the Integrated System Plan’s focus on transmission over distribution is addressed below.
Recommendation 1
1.22Labor Senators recommend that the Australian Government and States continue to support the Australian Energy Regulator's work to improve the efficiency of the distribution network.
1.23Another key focus of the inquiry was the Integrated System Plan (ISP) and its perceived shortcomings as a tool in energy planning in Australia. Labor Senators recognise that in developing the ISP every two years, the Australian Energy Market Operator (AEMO) works within a highly prescriptive legislative framework adopted on the basis of the Finkel Review in 2017 under the former Coalition Government.
1.24Labor Senators note that while the ISP was the basis of much discussion throughout the inquiry, a comprehensive review of the ISP was in fact completed in January 2024 by the Department of Climate Change, Energy, the Environment and Water. All 15 recommendations of the review were accepted by Energy Ministers at the Energy and Climate Change Ministerial Council (ECMC) in March 2024. Furthermore, Energy Ministers agreed to a set of actions to implement the review’s recommendations.[12]
1.25The Chair’s view that this was not raised in evidence is not an accurate characterisation. Mr Duggan from DCCEEW raised the review in response to criticism of the ISP by the Chair at the second hearing of the inquiry.[13]DCCEEW also referenced the review in their submission.[14] Additionally, the review was mentioned by a number of other witnesses and submitters.[15] It was the Chair’s prerogative (and any other participating Senators) to question witnesses further on the review when they raised it if, as it appears, he required more information.
1.26Labor Senators view the critical outcomes from the review as:
Better integration of the changing role of gas in an energy grid dominated by renewables
Enhancing consideration of consumer energy resources and the distribution network
Improving the clarity of communication regarding the ISP
1.27The primacy of these areas was supported by evidence given by AEMO on their foci following the ISP review.[16] Labor Senators view this review and the Energy Ministers' response to it as an appropriate remedy to issues affecting the efficacy of the ISP and look forward to the implementation of its recommendations in the 2026 ISP.
1.28Indeed, several of the Committee’s recommendations regarding the ISP are already being implemented due to the recommendations arising from the review. These are noted below in the Labor Senators’ response to each recommendation.
1.29Labor Senators also congratulate the review for enabling a framework that will allow for more continuous improvement of the ISP into the future.[17]
Recommendation 2
1.30Labor Senators recommend that the Australian Government continue to support the implementation of recommendations and actions arising from the Commonwealth's ISP Review.
1.31Labor Senators wish to make note of the transition of the Energy Security Board (ESB) to the Energy Advisory Panel (EAP). Clare Savage, Chair of the EAP, described this change as a shift from a focus on implementation of the Finkel Review's recommendations to a coordinating role of market bodies' advice to government.[18]
1.32Labor Senators view this as an improvement to the administrative architecture governing energy markets, avoiding duplication and ensuring efficient and coordinated provision of advice to ministers from multiple perspectives. Clare Savage's testimony supports this:
From our perspective, we find the opportunity to come together and talk about the sorts of key policy issues that ministers might be considering useful. We've all got our various perspectives. I bring a regulatory focus, Ms Collyer brings a rules focus, and Mr Westerman brings a system operation focus, so it gives us an opportunity to consider what ministers currently have on their plates and to look at our advice in that context. It's certainly useful to us and, we would hope, useful to ministers as well.[19]
1.33Labor Senators commend this shift and believe it positions the Energy Advisory Panel as a more collaborative and streamlined body for delivering comprehensive and balanced advice to government.
1.34Labor Senators note that much of the criticism about a lack of transparency, from governments as well as market bodies, is not supported by evidence beyond opinion provided. Labor Senators note the ISP goes through a rigorous and open consultation process, from the very beginning of the ISP development process, through to the delivery of the final bi-annual ISP. For example, during the development of the 2024 ISP, AEMO consulted with more than 2,100 stakeholders and considered 220 submissions from industry, investors, consumer and community representatives, network planners and governments.[20]
1.35Similar levels of consultation and transparency apply to the operation of the AER and Australian Energy Markets Commission (AEMC). Rigorous consultation processes are set out in the National Electricity Rules, as well as National Electricity Law, National Gas Law, and National Energy Retail Law, governing the work of the AER and AEMC. For example, any Australian individual or organisation (except for the AEMC itself) can apply for a National Electricity Rule change with the AEMC.[21] The AEMC initially holds a completely open consultation process on the proposed rule to inform its draft determination. Following the release of a draft determination, the AEMC engages in another round of open consultation before issuing a final rule change determination.[22] Similar open consultation processes exist for AER determinations.[23]
1.36Labor Senators note that witnesses to the inquiry raised the length of time needed to implement rules and other changes and action projects,[24] while also calling for greater transparency and consultation. These two objectives are by necessity in conflict, with greater consultation taking greater time. Labor Senators view the balance struck by current processes is the right one and note the natural conflict between consultation and openness on the one hand, and speed of reform delivery on the other, will inevitably mean market bodies will be criticised for both not engaging in consultation enough and working too slowly.
1.37In response to criticism that the ECMC, the ultimate governing body for the National Electricity Market, lacks transparency, Labor Senators note ECMC is a sub-committee of National Cabinet and as such must comply with Cabinet Confidentiality. Even though ECMC is covered by Cabinet Confidentiality, ECMC releases a detailed communique after every meeting discussing decisions made and issues discussed.
1.38Labor Senators do not support a review conducted by the Productivity Commission into the Australian energy network. Such a review would create investor uncertainty and confusion, would undermine the work of the National Electricity Market wholesale market settings review[25] currently underway, and in so doing would hurt investment outcomes at a time when AEMO and other market bodies and experts warn the timely delivery of generation, storage and transmission investment is crucial to ensure the reliability and affordability of energy supply. In addition, in recent years there have been a number of reviews addressing the areas outlined in the recommendation including, but not limited to:
Transmission Planning and Investment Review[26]
Electricity network economic regulatory framework review 2020[27]
Coordination of generation and transmission investment[28]
Transmission Frameworks Review[29]
Updating the regulatory frameworks for distributor-led stand-alone power systems[30]
Review of the regulatory frameworks for stand-alone power systems[31]
Post 2025 market design[32]
AEMO Renewable Integration Study (RIS)[33]
ACCC Inquiry into the National Electricity Market[34]
1.39Labor Senators view the reviews and the ongoing processes of the bodies as sufficient. An additional review by the Productivity Commission would be duplicative and wasteful. It is not clear what the Chair hopes will be achieved by such a review that would provide a different outcome from those already conducted.
1.40Labor Senators do not support the development of an updated Strategic Energy Plan by ECMC. It is the Labor Senators’ understanding that the ISP in effects serves as a strategic energy plan so to develop another one would, again, be duplicative and wasteful and create significant industry and investment uncertainty and confusion – impacting investment decisions and as a result the affordability and reliability of energy supply. Issues with the ISP as it currently stands are being addressed through the recommendations from the Commonwealth ISP review which has been endorsed by ECMC.
1.41Labor Senators do not support amending the terms of reference of the National Electricity Market (NEM) wholesale market settings review to include issues relating to governance. The review is by definition inquiring into the market settings needed to support a renewable intensive electricity market, and issues of market governance where relevant to the terms of reference will be addressed.
1.42Labor Senators do not support making the AEMO a corporate Commonwealth entity. This recommendation is neither deliverable nor needed. This recommendation is fundamentally inconsistent with the National Energy Market Agreement[35] (AEMA) between states and the Commonwealth which underpins the agreed governance framework of national energy markets including the NEM, and as such would represent a breach of that agreement. Under the AEMA AEMO is accountable to ECMC rather than any one minister or jurisdiction, as is viewed appropriate given AEMO’s cross jurisdictional as well as inter-jurisdictional role. Labor Senators agree that AEMO has significant accountability via the structure of the market bodies and ministerial oversight through ECMC.
1.43Labor Senators note this recommendation, as it is redundant. Ample information regarding the role and functioning of ECMC are already published[36]including the AEMA cited above which serves as the terms of reference for ECMC.
1.44While Labor Senators agree-in-principle that the Australian Energy Market Commission should conduct post-implementation reviews of rule changes, noting that there are sometimes relatively minor changes that don’t necessarily require review, Labor Senators also note that the NEM wholesale market settings review will practically perform this role in its work, to report back to ECMC in 2025. In addition, Labor Senators note that the structure of the rule change process effectively allows for any rule change to be reviewed through the lodgement of a proposed change to the rule. As a result, while Labor senators agree-in-principle to this recommendation, we do not see it as a priority for immediate implementation.
1.45Labor Senators do not support ECMC ministers tabling a statement that each Final ISP meets the NEOs in their parliament. This is an unnecessary and burdensome extra level of administration. The ISP by definition must meet the NEOs so the tabling of this statement in the various parliaments of Australia is tautological and wasteful.
1.46Labor Senators do not support a rule change so that AEMO’s directors must sign off on both the Draft and Final ISP attesting the plans meet the NEOs. The criticism of this recommendation is the same as Recommendation 7; it is an unnecessary step that is already implied in the rules and guidelines that underpin the development of the ISP. In effect, this recommendation is redundant as the AEMO board already signed off on the ISP and draft ISP, including its compliance with relevant laws, rules, and guidelines including compliance with the NEO.
1.47Labor Senators do not support removing AEMO’s power to make a project actionable for the 2026 and 2028 ISPs. This recommendation seeks to undermine and wind back the improvements to transmission planning and delivery made since the Finkel Review without a strong evidence base that such a change is necessary, and would create significant investor uncertainty resulting in costly delays to transmission projects. This recommendation is also contingent on Recommendation 1 for which reasons against have already been outlined. Regardless, such a step would unacceptably slow the planning process immensely.
1.48While Labor Senators agree-in-principle with the recommendation to include additional analysis when conducting modelling to determine actionable projects, in particular on labour market and economic impacts. However, Labor Senators question whether this is best done by AEMO in the context of the ISP given AEMO energy expertise (rather than broader economic analysis expertise) and given resource constraints. Labor Senators therefore recommend government consider the most appropriate approach to consideration of actionable project economic assessments.
1.49Labor Senators do not support this recommendation and note the AEMC continues to monitor developments in the implementation of jurisdictional contestability regimes in NSW, Victoria and overseas to capture useful insights.
1.50The AEMC’s transmission access reform report recommended that jurisdictions and market bodies establish a collaborative forum to support the effective delivery of jurisdictional schemes.While this forum will have a focus on operational issues and congestion, the implementation of contestability can be a key part of jurisdictional schemes and will therefore likely be considered and monitored as part of this forum.
1.51In addition, recent work programs have considered contestability in networks. These include work undertaken by States in establishing jurisdictional frameworks:
Work undertaken in NSW to establish and implement the Electricity Infrastructure Investment Act 2020 (the EII Act).[37] This includes the AER’s consultation processes in developing its revenue determination guideline for NSW contestable projects.
Work undertaken in Victoria to establish and implement the Victorian Transmission Investment Framework (VTIF),[38] notwithstanding that contestable works already formed part of Victoria’s transmission planning.
Work programs to consider the effectiveness of contestability in the context of ring-fencing and the use of non-network solutions, including:
On 18 July 2023, the AER completed a review of its ring-fencing guideline for electricity transmission.[39]
On 9 December 2024, the AER commenced a review of its ring-fencing guideline for electricity distribution.[40]
On 12 December 2017, the AEMC made a rule on the contestability of energy services that sought to facilitate competition in the emerging energy services market.[41]
1.52Labor Senators do not support dictating to AEMO their approach on software and data used in their work. Labor Senators acknowledge these decisions should be made by technical experts to deliver the most sophisticated and robust analysis possible. The inquiry ascertained that AEMO goes to significant lengths to ensure the transparency of it modelling and most agreed that this is of a high standard and is sufficient. Government should not dictate its process given this existing high level of transparency.
1.53Labor Senators agree-in-principle with these improvements to the ISP but note they are already being addressed as part of the implementation of the Commonwealth’s ISP review.
1.54Labor Senators note this recommendation and have no objection in principle to adjusting the Cost Benefit Analysis Guidelines should such a change be deemed warranted following stakeholder consultation and AER analysis, but any such change should be done through the usual process which involves significant consultation by the AER. Labor Senators also note on 21 November 2024, the AER published final amendments to the Cost Benefit Analysis (CBA) guidelines, the Regulatory Investment Test (RIT) application guidelines and instruments for the Regulatory Investment Test for Transmission (RIT-T) and Regulatory Investment Test for Distribution (RIT-D) following the 2024 Review of the cost benefit analysis and regulatory investment test guidelines,[42] which went through a significant consultation process including public forums, stakeholder forums and written submissions.
1.55Labor Senators agree that the implantation of the CER Roadmap be adequately resourced and note the MYEFO commitment for $36.9 million over six years from 2024–25 to support the optimisation and utilisation of existing grid infrastructure through regulatory reforms and grid enhancing technologies.[43]
1.56Labor Senators do not support the establishment of a separate CER consumer advocacy body. Labor Senators view this as something that is and should be part of Energy Consumer Australia’s work and rather than a new duplicative body, the existing body should rather be resourced adequately to deliver this work.
1.57Labor Senators note this recommendation and note the ECA board is currently determined by agreement by ECMC as set by the ECA constitution. In picking the board of ECA, ECMC must have regard to a skills matrix including relevant skills and expertise to ensure ECA performs its consumer focussed role.
1.58Labor Senators agree-in-principle that the AER (and ECMC more broadly) examine whether a positive duty of care should be imposed on energy market service providers, but Labor Senators also note this is already underway, noting the most recent ECMC communique stated:
Ministers tasked Senior Officials with developing options to strengthen consumer protections and modernise the consumer regulatory framework to reflect the fact that consumers are interacting with the energy system in new and different ways through the clean energy transformation, including producing and storing energy through solar panels and batteries. Senior Officials will bring forward options for consumer regulatory framework reform to the next meeting of the ECMC.[44]
1.59Labor Senators do not support conducting an additional review of the NEO given one was conducted recently by ECMC in the context of the decision to include emission reduction as part of the NEO. Labor Senators also note the NEO does not provide weights to its components. Labor Senators are confident consumer outcomes are already understood to be a high priority by stakeholders, market bodies and governments, in accordance with the existing NEO.
1.60Labor Senators agree that the Australian Government will need to make decisions about a CER Technical Regulator, and the development of nationally consistent standards and consumer frameworks. Labor Senators note this work is ongoing as part of the CER Roadmap, and ECMC recently stated in their most recent communique:
Ministers welcomed the progress to date on the National Consumer Energy Resources (CER) Roadmap, given the increasingly important role CER will play in delivering dispatchable capacity. Ministers maintain their focus on delivering for consumers and communities, and actions under the Roadmap will achieve this by lowering bills, improving access to CER and improving overall system operation.[45]
1.61Labor Senators do not support a review of network charges as this recommendation is entirely duplicative with the statutory responsibilities of the AER. A Commonwealth review would be unnecessary and would duplicate that ongoing work of the AER.
Senator Varun Ghosh
Labor Senator for Western Australia
Senator Karen Grogan
Labor Senator for South Australia
Footnotes
[1]Mr Westerman, Committee Hansard, 5 December 2024, pp. 34 & 44.
[2]See: Ms Savage, Committee Hansard, 23 October 2024, p. 3; Ms Bowyer, Committee Hansard, 31 October 2024, p. 51; Mr Reed, Committee Hansard, 31 October 2024, p. 63.
[3]Mr Feeney, Committee Hansard, 30 October 2024, p. 5.
[4]See: Ms Bowyer, Committee Hansard, 31 October 2024, p. 5; Mr Reed, Committee Hansard, 31 October 2024, p. 63.
[5]Mr Parker, Committee Hansard, 31 October 2024, p. 42.
[6]Dr McConnell, Committee Hansard, 29 October 2024, p. 9.
[7]Ms van den Berg, Committee Hansard, 30 October 2024, p. 4.
[8]Ms van den Berg, Committee Hansard, 30 October 2024, p. 5.
[9]Ms Bashir, Committee Hansard, 30 October 2024, p. 11.
[10]Ms Savage, Committee Hansard, 23 October 2024, p. 29.
[11]Energy and Climate Change Ministerial Council, Meeting Communique, 6 December 2024, available at: https://www.energy.gov.au/energy-and-climate-change-ministerial-council/meetings-and-communiques.
[12]Energy and Climate Change Ministerial Council, Response to the Review of the Integrated System Plan, April 2024
[13]Mr Duggan, Committee Hansard, 29 October 2024, p. 42.
[14]DCCEEW, Submission 12, pp. 4-5.
[15]See for example: ISP Consumer Panel, Submission 76, p. 6; Dr McConnell, Committee Hansard, 29 October 2024, p. 3; Ms Collyer, Committee Hansard, 23 October 2024, p. 59.
[16]Ms York, Committee Hansard, 5 December 2024, p. 33.
[17]Mr Westerman, Committee Hansard, 5 December 2024, p. 43.
[18]Ms Savage, Committee Hansard, 5 December 2024, p. 2.
[19]Ms Savage, Committee Hansard, 5 December 2024, p. 3.
[20]AEMO, Submission 14, p. 11.
[21]AEMC, Submission 16, p. 13.
[22]AEMC, Changing the energy rules – a unique process, available at: https://www.aemc.gov.au/our-work/changing-energy-rules.
[23]AER, Submission 15.
[24]See for example: Professor Brear, Committee Hansard, 29 October 2024, pp. 1-2; Dr McConnell, Committee Hansard, 29 October 2024, p. 2; Ms Bashir, Committee Hansard, 30 October 2024, p. 12; Professor Crossley, 31 October 2024, p. 24; Dr Kuiper, Committee Hansard, 31 October 2024, p. 48.
[25]DCCEEW, National Electricity Market wholesale market settings review, available at: https://www.dcceew.gov.au/energy/markets/nem-wms-review.
[26]AEMC, Transmission Planning and Investment Review, available at: https://www.aemc.gov.au/market-reviews-advice/transmission-planning-and-investment-review.
[27]AEMC, Electricity network economic regulatory framework review 2020, available at: https://www.aemc.gov.au/market-reviews-advice/electricity-network-economic-regulatory-framework-review-2020.
[28]AEMC, Coordination of generation and transmission investment, available at: https://www.aemc.gov.au/markets-reviews-advice/reporting-on-drivers-of-change-that-impact-transmi.
[29]AEMC, Transmission Frameworks Review, available at: https://www.aemc.gov.au/markets-reviews-advice/transmission-frameworks-review.
[30]AEMC, Updating the regulatory frameworks for distributor-led stand-alone power systems, available at: https://www.aemc.gov.au/market-reviews-advice/updating-regulatory-frameworks-distributor-led-stand-alone-power-systems.
[31]AEMC, Review of the regulatory frameworks for stand-alone power systems, available at: https://www.aemc.gov.au/market-reviews-advice/review-regulatory-frameworks-stand-alone-power-systems.
[32]DCCEEW, Post-2025 market design, available at: https://www.energy.gov.au/energy-and-climate-change-ministerial-council/working-groups/energy-transformation-enablers-working-group/post-2025-market-design.
[33]AEMO, Renewable Integration Study (RIS), available at: https://www.aemo.com.au/energy-systems/major-publications/renewable-integration-study-ris.
[34]ACCC, Inquiry into the National Electricity Market, available at: https://www.accc.gov.au/system/files/accc-inquiry-national-electricity-market-december-2023-report_0.pdf.
[35]DCCEEW, Australian Energy Market Agreement (as amended December 2013), available at: https://www.energy.gov.au/energy-and-climate-change-ministerial-council/energy-ministers-publications/australian-energy-market-agreement-amended-december-2013.
[36]DCCEEW, Energy and Climate Change Ministerial Council, available at: https://www.energy.gov.au/energy-and-climate-change-ministerial-council.
[37]NSW Government, Electricity Infrastructure Investment Act 2020 No 44, available at: https://legislation.nsw.gov.au/view/html/inforce/current/act-2020-044.
[38]DEECA, Victorian Transmission Investment Framework, available at: https://www.energy.vic.gov.au/renewable-energy/vicgrid/victorian-transmission-investment-framework.
[39]AER, Review of options to address gaps in transmission ring-fencing framework | Australian Energy Regulator (AER), available at: https://www.aer.gov.au/industry/registers/resources/reviews/review-options-address-gaps-transmission-ring-fencing-framework.
[40]AER, AER consults on proposed changes to transmission ring-fencing guideline | Australian Energy Regulator (AER), available at: https://www.aer.gov.au/news/articles/communications/aer-consults-proposed-changes-transmission-ring-fencing-guideline.
[41]AEMC, Contestability of energy services | AEMC, available at: https://www.aemc.gov.au/rule-changes/contestability-of-energy-services#:~:text=rule%20change%20requests.-,On%2012%20December%202017%20the%20AEMC%20published%20a%20final%20rule,energy%20services%20rule%20change%20requests.&text=The%20final%20rule%2C%20which%20is,assets%20located%20'behind%20the%20meter'.
[42]AER, 2024 Review of the cost benefit analysis and regulatory investment test guidelines, available at: https://www.aer.gov.au/industry/registers/resources/reviews/2024-review-cost-benefit-analysis-and-regulatory-investment-test-guidelines.
[43]The Commonwealth of Australia, Mid-Year Economic And Fiscal Outlook, p. 223, available at: https://budget.gov.au/content/myefo/index.htm.
[44]ECMC, Meeting Communique, 6 December 2024, p. 2, available at: https://www.energy.gov.au/energy-and-climate-change-ministerial-council/meetings-and-communiques.
[45]Ibid., p. 1.
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