Connecting the dots

How enhancing investment certainty in the R1 process will help to facilitate timely connections

Connecting the dots
  • July 10, 2024

The recent release of the 2024 Integrated System Plan (ISP) from the Australian Energy Market Operator (AEMO) confirmed what many industry participants already know – the rate at which variable renewable generation is being connected to the National Electricity Market (NEM) is currently too slow. Presently, around 3 to 4 GW of capacity is connected each year, however many more projects remain in the connections queue.1 The ISP’s Optimal Development Path under the Step Change scenario calls for investment that would increase variable renewable energy six-fold by 2050, or about 6GW of capacity per year.2

The challenge of connecting a high volume of new projects in an increasingly constrained network is driven by various factors. Inconsistency and inefficiencies in the existing process, and ineffective collaboration between generators, developers, network service providers and industry bodies, create delays and complexity in the connection process. The Connections Reform Initiative (CRI), collaboratively established by the Clean Energy Council and AEMO, was created to help overcome these challenges and connect new generators to the grid faster. While the CRI is focused on initiating a suite of reforms, its rule change submission focused on improving investor certainty for assets passing through the registration stage of the connection process. This has resulted in the Australian Energy Market Commission (AEMC)’s recent rule change, amending the R1 process.

What will the rule change do?

The Enhancing investment certainty in the R1 process final rule seeks to reform the R1 process, when connection applicants must demonstrate their plant is capable of meeting or exceeding its performance standards, in order to become a registered participant in the NEM. The final rule is effective from 11 July 2024, however any R1 processes currently underway will not be impacted by the final rule. Figure 1 outlines the key features of the rule change, aimed at improving investment certainty by addressing several gaps and hindrances to timely connections.

Figure 1: Summary of rule change

Simmary of rule change

Source: PwC, adapted from AEMC’s rule determination.

The rule change seeks to increase transparency, communication and predictability in the R1 process

Connecting parties considered a lack of formal obligations under the National Electricity Rules (NER) was contributing to poor engagement and process delays. While AEMO noted that a range of factors could contribute to process delays, including rushed design or poor-quality models and data, it acknowledged that prescription in the NER could improve transparency and consistency for connection proponents. As such, the final rule imposes obligations on AEMO to provide timely notifications to connecting parties. This includes:

  • Within 5 business days of receiving a R1 package submission, AEMO must provide connection applicants with written acknowledgement of receipt or provide details of how the application is non-conformant with the R1 assessment guideline
  • Within 60 business days of receiving a R1 package, AEMO must notify connection applicants of the status of the R1 assessment
  • Within 5 business days of the completion of a R1 assessment, AEMO must notify the connection applicant that the assessment is complete and whether AEMO will register (or conditionally register) the applicant’s generator.

Figure 2: Prescribed timeframes for R1 connection process

Summary of rule change

Source: PwC, adapted from AEMC’s rule determination.

In making this change, the AEMC did not intend the timeframe to add additional burden to existing AEMO or NSP practices. Importantly, the 60 business day timeframe specified does not impose a requirement to make a decision within this period but simply to advise the applicant as to the status of the process. The AEMC was of the view that existing practices already comply with these timeframes. Noting this, the formalisation of timeframes for communication is not intended to speed up these interactions but instead to provide predictability and certainty around when communications and/or information requests from AEMO can be expected by connection applicants.

Faster connections may however be facilitated by greater transparency in the review process. The final rule changes specifies that AEMO and NSPs need to provide written reasons when requesting additional data and information from connection applicants. If it still unclear, the connection applicant is also able to request additional information. This will help to take the guess-work out of the process, and make any re-modelling or provision of additional information more streamlined and efficient, as issues can be more easily identified and remedied by the connection applicant.

The rule change takes a pragmatic approach to revising performance standards

Previously, a requirement in the NER for standards to be ‘no less onerous’ meant that connecting plants were prevented from proposing any adjustments to standards that were lower than existing standards. The AEMC considered this was a key source of engineering overwork and connection delays.

The final rule change relaxes this requirement, allowing connection applicants to revise their standards more flexibly and removing the ‘no less onerous’ requirement where a standard is above the minimum access standard. This change provides flexibility to allow pragmatic revisions to apply, where the end result is immaterial to achieving the overall minimum access standard. This avoids any unnecessary restriction in the renegotiation of standards and is intended to streamline the R1 process. For example, this rule change may streamline the process for battery retrofits for existing solar or wind farms (where the battery is proposed to share a common connection point and performance standards with the existing generator).

The ‘no less onerous’ requirement still exists when renegotiating a standard that is below the minimum access standard, however upon joint agreement by AEMO and the NSP, an applicant may propose a less onerous standard. This is envisaged to support alterations to legacy plant, which may benefit the power system but would otherwise reduce standards below the prescribed level. Noting that this type of alteration should not be unnecessarily prevented, the proviso to allow reductions where there is joint agreement between AEMO and NSPs allows engineering judgement to prevail over the NER in certain situations.

The rule change shifts some of the burden to AEMO and NSPs, who have greater access to information

To avoid duplicate assessments by NSPs and AEMO and prevent misalignment between these two parties, the final rule change requires that AEMO and NSPs must consult with each other during the R1 assessment process. A ‘reasonable endeavours’ obligation to share data and information is also imposed on these parties. For example, it is expected that NSPs will share the results of their assessments and network models with AEMO. Similarly, AEMO should share information from its NEM-wide PSCAD model with the NSP and provide advice to NSPs throughout the process.

These obligations are intended to ensure all parties are well-informed throughout the R1 process and to eliminate information asymmetries. Collaboration and cooperation between NSPs, AEMO and connection applicants is critical to ensuring a streamlined connections process, and will be better supported by the introduction of these new roles and responsibilities for the assessing parties.

What still needs to occur to facilitate timely connections?

It is important to acknowledge that the R1 process does not occur in a silo and successful execution of the connections process is multi-faceted. While these changes to the registration process are a step in the right direction, other key issues remain outstanding.

While rule changes to the R1 process take effect from 11 July 2024, further work and consultation is required for AEMO to update its information resources for applicants to be informed of the new R1 process, including the development of registration guidelines, scheduled to be developed by 1 March 2025.

The registration guidelines will be key to building on the rule change and realising its benefits in providing a clear and consistent process to accelerate renewable energy and storage connections. To achieve this, the registration guidelines will need to clearly explain:

  • Minimum information requirements for R1 packages
  • How AEMO conducts its R1 assessment process
  • Circumstances for when NSPs may request additional information from connection applicants; and
  • When and how ‘conditionally’ approved registrations may be used.

Given these registration guidelines will be more significant and complex, extensive stakeholder consultation is required to help shape the development of information resources for the assessment process.

The rule change is part of broader suite of reforms, being pursued through the Connections Reform Initiative. Currently, AEMO and the Clean Energy Council are working with industry to also develop positions and where necessary, implement changes across the connections process. These initiatives include, but are not limited to:

  • Improving the OEM data and modelling processes to ensure proponents are providing high-quality, consistent data
  • Seeking to better streamline the connection process by introducing a ‘batching’ reform to avoid onerous rework and impact assessments at the application stage of the connections process, when other nearby projects become committed.
  • Adjusting bias towards the Automatic Access Standards through a review of clause 5.3.9 of the NER. This review aims to identify improvements to the plant alteration process and provide certainty in the application and interpretation of the clause. 

While the current rule change addresses many of the gaps in the R1 assessment process, the overall outcomes of these initiatives and how the connections process operates in the future will be dependent on how these other changes are effected.

It is clear the existing regulatory frameworks are not fit-for-purpose and reform is required to improve the timeliness and quality of the connections process. However, there are a myriad of reasons for delays associated with the R1 process – some of which may not be able to be addressed by regulatory reform to existing AEMO and NSP processes.

For example, the existing open access framework incentivises proponents to rush applications in order to get connected ahead of other proponents in the area. This can lead to poor-quality models or incomplete information being provided on application. Additionally, resource constraints on project proponents (or their consultants) may mean that significant turnaround times are needed to respond to clarifications and updates, slowing the overall assessment process.

Regulatory measures are unlikely to fully address these issues. In addition, parties should seek to improve cooperation throughout the connections process. Increased collaboration and effective communication between generators, developers, AEMO and NSPs will help to avoid confusion and set clear expectations as to what is required to get a connection applicant registered. Alongside the increased process certainty brought about by the rule change, a collaborative relationship between all parties involved is critical to support improved engagement and minimise process delays.

References:

1  The AEMC notes as at March 2024, there were 593 projects in the connections queue.

2  AEMO, 2024 Integrated System Plan for the National Electricity Market, June 2024, p. 11.

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