Alignment with the Integrated System Plan The draft guidance currently states that ‘RIT-Ts should be undertaken using a consistent approach to that taken in the ISP, unless there is a strong reason not to do so’. [...] Notwithstanding that the Australian Energy Market Operator (AEMO) will now consider emissions reduction as a class of market benefit in the final 2024 ISP, there is currently a lack of publicly available detail on how AEMO will apply the interim VER to the final 2024 ISP. [...] The draft guidance also states that ‘should RIT-D proponents decide to estimate the benefit of emissions reduction in their assessments, they should wherever possible take a consistent approach to that taken in the ISP’. [...] ENA therefore recommends that the final guidance allows for changes in greenhouse gas emissions to be included in RIT-D (and RIT-T) assessments where they relate to emissions changes which are material for that assessment, even where they may not be covered in the methodology adopted in the final 2024 ISP. [...] Review We look forward to engaging with the AER on its upcoming update of the CBA and RIT Guidelines, and recommend that, once that update is complete, the final AER guidance is also reviewed to ensure that there are no inconsistencies given that this guidance is intended to have primacy over the Guideline updates.
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