PIAC responded to the AEMC on its Declaration of Lack of Reserve conditions rule change. PIAC agrees that the AEMC must consider the ability of the proposed rule change to better capture the willingness of consumers to pay for reliability of supply and more effectively incorporate price-reliability trade-offs. However, PIAC stresses that the willingness of consumers to pay – not market participants or other stakeholders – is paramount, as costs are ultimately passed through to consumers.
PIAC agrees that the proposal would help AEMO ensure its procedures are able to evolve with emerging issues and, to the extent that the standard consultation procedures may inhibit this, PIAC supports AEMO’s proposal for a shorter consultation period for any updates. However, PIAC considers that consumers and stakeholders other than those listed in the rule change proposal (generators, TNSPs and Jurisdictional System Security Coordinators) must also be included in this consultation.