PIAC responded to the Australian Energy Market Commission’s (AEMC) consultation on the financeability of Integrated System Plan (ISP) projects rule change.
PIAC does not support the proposed rule changes as the proposals significantly change the allocation of risks and costs, consumer engagement around the changes has not been sufficient and a counterfactual has not been well-established.
We consider there are broader challenges to delivering ISP projects and that pursuing derogations from the Rules without considering the need for complementary changes risks creating unintended consequences.
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