The Justice and Equity Centre made a submission to the review into transmission planning in NSW initiated by the NSW Department for Climate Change, Energy, the Environment, and Water.
We support the aims of the review, which are to identify dupiclation in the functions of various planning agencies and to consider the coordination arrangements between said agencies.
We argue that the terms of reference are slightly too narrow, and that issues relating to cost recovery should be included given their impacts on planning and the commitment planners make to constituents that the benefits associated with given transmission investments are greater than their costs.
We also argued that consideration should be given to updating key design elements of the NSW transmission planning infrastructure, notably the NSW reliability standard. The NSW standard takes a different form to the national standard. This is due to the nature of the generators providing energy in NSW when the standard was created. As the energy system evolves, however, away from these particular conditions, a harmonisation with the national standard may be appropriate and ensure that NSW consumers do not pay more for reliability than they would choose to.
