AGL is disappointed that the AEMC has decided not to adopt the Clean Energy Council’s (CEC’s) proposed self-assessment, type pathways, materiality guidelines, and conditional approval. While the AEMC's draft rule offers positive initiatives like allowing generators to request justification for additional modelling and streamlining the R1 process, AGL believe the CEC's proposal better addresses R1 process issues. The current draft gives too much discretion to AEMO and NSPs, leading to less transparency and more uncertainty. AGL also advocates for an effective dispute resolution framework for R1 connection disputes, requiring adjudication by independent experts with binding decision-making power. Current options lack these components, with non-binding technical reviews and insufficient obligations in commercial arbitration.
Read the full submission here.