PIAC responded to the AEMC’s draft determination on the generating system model guidelines rule change which proposes to allow AEMO to collect more detailed information to assist in modelling and operating the power system. PIAC supports AEMO’s rule change proposal and the AEMC’s draft determination. Noting the great amount of uncertainty and change in the market at this point in time, it is increasingly important that AEMO has all the information required to do its job as the system operator and national planner. PIAC also cautions against giving credibility to cost estimates for complying with the new information obligations that are neither substantiated with detail nor independently verified, as appears to be the case for submissions made to the AEMC for this rule change.