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Metro Power Company Pty Ltd ABN 76 115 167 569
Enquiries: Timothy Edwards
Telephone: 0438 855 845
26th April 2024
Department of Climate Change, Energy, the Environment and Water
Capacity Investment Scheme – Western Australia Design Paper
SUBJECT: Submission feedback on the proposed Western Australia, design and implementation of the Capacity
Investment Scheme.
To Whom It May Concern,
In our view, the South West Interconnected System (‘SWIS’) infrastructure, bound by the Wholesale Electricity
Market (‘WEM’) is very small compared to the NEM, but as many recent reports and studies confirm, faces a significant hurdle to achieve a low-emissions future, largely due to lack of adequate transmission network infrastructure.
The monopoly network operator, Western Power, has been unable to demonstrate the on-time-delivery of its
Approved Work Programs and is fumbling to start the project delivery of large-scale transmission network upgrades as set out/proposed in the recent SWISDA1.
In recent years, West-Australians have seen the State Treasury provide adequate funds to Western Power, only to be disappointed with lack of project delivery and the re-scheduling of critical upgrades into future years as competition for skilled resources and materials increase.
The proposed 30MW Eligibility Criteria in Section 3.5.1 of the Design Paper will force all proponents to apply for connection at transmission-level. In our view, the first group of project developments and future assets supported by the Capacity Investment Scheme are very likely fail the Project Delivery milestones (i.e. final Network Access
Agreement, Commissioning) due to the bottleneck in Western Power processes and the lack of delivery/progress with their poorly defined transmission investment plans.
Transmission-level connections require extensive engineering, dynamic studies to assess network connection requirements and adherence to the mandatory Generator Performance Standards. The project assets for connection, including transformers, circuit breakers and land-access for tower-builds have significant, multi-year lead times.
We recommend that one solution to increase renewable energy generation and storage in Western Australia’s
SWIS is to reduce the eligibility requirement from ‘transmission-connected projects > 30MW` to allow `distribution- connected’ projects.
Reducing the eligibility requirement to 9.9MW may allow distribution-connected assets to connect much faster, however the Western Power requirements will still require lengthy and expensive dynamic network studies and modelling prior to entering a Network Access Agreement. The certification of Reserve Capacity by AEMO in the
WEM requires prior network access approval with each application. Reducing the eligibility to only 9.9MW may have an unsatisfactory outcome.
1
SWIS Demand Assessment (www.wa.gov.au)
Metro Power Company Level 1, 56 Kings Park Road, West Perth, Western Australia, 6005 Tel: 1300 302 055 Pg. 1 of 2
www.metropower.com.au
QMS F39
APPD 17.10.19
Metro Power Company Pty Ltd ABN 76 115 167 569
Reducing eligibility further to (say) 4MW will have even more benefit to speedy deployment of renewables and storage across the SWIS. This solution will ensure that lengthy dynamic network studies are avoided, material lead-times can reduce significantly, while land access agreements and development approvals become more streamlined.
Yours sincerely,
Timothy Edwards
Managing Director
Metro Power Company.
Metro Power Company Level 1, 56 Kings Park Road, West Perth, Western Australia, 6005 Tel: 1300 302 055 Pg. 2 of 2
www.metropower.com.au
QMS F39
APPD 17.10.19
