**Published name**
Upload a supporting document (optional)
Locked Bag 14051
Melbourne City Mail Centre
Victoria 8001 Australia
T: 1300 360 795
www.ausnetservices.com.au
11 April 2024
Department of Climate Change, Energy, the Environment and Water
Australian Government
National Adaptation Plan – Submission to issues paper
AusNet welcomes the opportunity to provide this submission to the Department Climate Change, Energy, the
Environment and Water (Department) consultation on the National Adaption Plan (Plan).
AusNet is the largest diversified energy network business in Victoria—we own and operate three core regulated networks: electricity distribution, gas distribution and the state-wide electricity transmission network, delivering energy and providing essential services to more than 6 million Victorian households and businesses.
We also have a commercial arm that holds a significant portfolio of contracted energy infrastructure under the trade name “Mondo”.
We strongly support the development of the plan, to be better prepared for and manage increasing risks from climate change. We support the Department’s objective for the plan, as stated in the issues paper:
Australia’s economy, society, and natural and built environments are being managed and invested
in, to reduce climate impacts and harness any opportunities now and into the future – by all levels of
government, business and community.
Climate change is already having a real and substantive impact on our energy infrastructure and the communities we serve. Since 2021, we have seen three 1-in-a-100 year storms that have caused devasting damage across Eastern Victoria, resulting in more than $100m in electricity infrastructure damage and significant financial and emotional strain on thousands of people and communities. These types of previously considered to be rare weather events are becoming the new norm, which requires us to better plan and prepare for a future of frequent weather extremities being part of our business-as-usual operations.
Our submission highlights climate risks and effects to provision of electricity as an essential service, and provides considerations for the plan on improving network and community resilience to climate change.
Our electricity infrastructure is in difficult terrain highly exposed to extreme weather
Climate change is already having a significant impact on many communities across Australia, seen from significant bushfire, storm and flood events that have caused devastation over the past few years alone.
AusNet is particularly exposed to climate effects due to the areas of Victoria we serve, with our distribution network (‘poles and wires’) sprawling across highly vegetated mountainous areas of Victoria’s east, including the Alpine region. These mountainous areas typically experience more storm activity and when extreme weather occurs, the impacts on the electricity infrastructure and the communities are more severe due to significant vegetation-related damage (i.e., fallen trees and branches).
Figure 1 on the next page shows the mountainous terrain across Victoria and the five different distribution networks, demonstrating most of the areas are in AusNet’s distribution network.
Given our exposures to more extreme weather compared to other parts of Victoria and Australia, we are more exposed to intensifying climate change. To assist us to better plan for future climate change impacts, we recently initiated a climate modelling exercise, taking an ‘all hazards’ risk assessment approach. Once ready, this study will inform our investment in improving network resilience to extreme weather events, including how we better serve our communities as climate changes becomes the new BAU. We can share the results of the study with the Department once ready, to further inform the development of the plan.
Table 1 on the next page summarises the different climate-related hazards and the potential impact to different types of network assets, that was conducted by AECOM recently for all Victoria distributors.
AusNet Electricity Services Pty Ltd / ABN 91 064 651 118 1
Figure 1: Mountainous areas in Victoria, across the five different distribution networks
Source: AusNet
Table 1: Climate change types and network and asset risk and vulnerability
Climate type Network and asset risk and vulnerability
• Extreme temperatures can have impacts on both overhead
Temperature transmission and distribution lines, causing sagging of the lines and
necessitating derating, which may lead to network outages.
There is a projected increase in the
number of extreme heat days and • Temperatures above operational standards can result in the need to
more frequent heatwaves across derate substations and cause faults in communications equipment.
Victoria. • Heatwaves can cause extended duration of overload to distribution
transformers, substations and underground cables, leading to damage
and/or early asset failure.
• Extreme wind presents risk to overhead transmission and distribution
Wind lines. There is the potential to cause damage from debris contact, or
from increased structural loads that exceed safe design limits of
For southern Australia and eastern
Australia, the median results from the overhead structures.
ensemble modelling projected a 7% • Extreme wind and debris contact presents a risk to poles, towers and
to 8% increased frequency for severe communications equipment, as it can damage or destroy the asset
convective winds. and has the potential to impact customer supply.
Note - Low confidence
• The increased intensity and frequency of bushfires was considered to
Bushfires present direct risks to all transmission and distribution asset categories
except underground lines and cables.
Under a high emissions
scenario, the number of high-risk • Most of the identified risks related to bushfires were associated with
bushfire days per year in 2070 is damage or destruction of the asset.
projected to increase by between
approximately 10 to 20 fire days
across much of the state.
AusNet Electricity Services Pty Ltd / ABN 91 064 651 118 2
• Increased intensity and frequency of extreme rainfall was considered
Precipitation to present risks to overhead transmission and distribution lines, poles,
towers, substations, and communications equipment.
Much of Victoria is projected
to experience more frequent and • Flooding can cause the destabilisation of the foundations of towers,
intense extreme rainfall events, poles, and substations resulting in damage to the asset.
however the frequency of events • It was also identified that flooding can limit access to assets, limiting
varies by region across the state. the ability to undertake repair works, prolonging network disruptions.
• Flooding can cause communications equipment and substations to be
inundated, potentially damaging low-lying assets.
• Sea level rise primarily presents risks to poles, underground cables and
Sea Level Rise substations.
Sea levels across Victoria’s • Poles may be inundated, resulting in the erosion and destabilisation of
coast are projected to rise the asset’s foundations.
approximately 24 cm by the 2050s • Sea level rise, in combination with winds, may cause increased sea
and could be as much as 54 cm by spray, hastening corrosion of metal assets.
2070. • Coastal inundation may also cause erosion in underground assets.
• Underground cables’ armouring may be exposed to more saline
groundwater, leading to failure.
Source: AECOM
The impact of climate change on our infrastructure and the communities we serve is intensifying rapidly
As mentioned, since 2021 in Victoria we have experienced three destructive storms that have caused significant damage to electricity infrastructure and had a large impact on the communities we serve. The latest of these extreme weather events was the storm on 13 February 2024, which resulted in approximately
45% of our customer base experiencing a power outage in the first 24 hours. Many communities experienced prolonged power outages (more than a week), due to the need to rebuild parts of the electricity network from the ground up.
Figure 2 summarises the impact of the three recent extreme storms in terms of total minutes of supply on the first day. As shown, the three recent storms have had extraordinary impact on our customers in comparison to any time before that, but they are also intensifying rapidly and becoming the new norm.
Figure 2: System minutes off supply during day 1 of each storm
Source: AusNet
AusNet Electricity Services Pty Ltd / ABN 91 064 651 118 3
While figure 2 indicates the impact of storms in terms of duration of outages, the actual impact on communities is far larger, with many communities experiencing loss of multiple essential services due to electricity supply interruptions, including telecommunications and access to water. In regional and rural parts of Victoria, individual customer water and sewage systems are often dependent on electricity to function, leaving communities exposed during prolonged power outages. Equally, telecommunications infrastructure is largely dependent on reliable electricity supply (with some back-up capabilities), which means communities may lose communication and become isolated during prolonged power outages. Combined with significant financial losses from prolonged outages (loss of food and perishables, loss of business), the impact of the storm events on communities is increasingly severe.
There is a need for a holistic, multi sector coordinated approach to improving electricity network and community energy resilience to climate change, to better manage customer impacts as extreme weather becomes the new norm. This will become even more critical as more customers and communities electrify their gas appliances and transport, increasing reliance on continuous supply of electricity. We discuss this in more detail below.
We support a policy framework for improving network and community energy resilience
Following the 2021 extreme storms in Victoria, the Victorian government conducted and independent Expert
Panel Network Resilience Review, in light of increasing extreme weather events. The review was finalised in
20221, with 8 key recommendations to improve the investment framework and operational readiness of electricity networks, communities, and other critical infrastructure to manage prolonged power outages.
We support the Network Resilience Review recommendations and consider them critical to future proofing essential services, including electricity infrastructure, telecommunications, and water, for climate change risk and the ‘new norm’. Victorian electricity networks and the Victorian government are already progressing the implementation of the Network Resilience Review, including planning for investment in network infrastructure to better withstand weather impacts, and making operational changes to reduce the impact of prolonged power outages on communities during weather events.
However, there is an opportunity for a broader national framework that supports improvements in resilience of essential service providers and local communities. We support flexibility in the regulatory framework to use a broader set of customer values and performance metrics to inform resilience investment. AusNet has recently undertaken an extensive customer research study on various customer values, which shows customers put a high value on improving resilience of the network to reduce the likelihood of prolonged outages. Studies like this one should form part of regulatory revenue proposals, to ensure our investments meet changing customer needs and expectations. Details of our Quantified Customer Values project can be found here.
We also consider further reform is needed to better coordinate resilience investment by the different critical infrastructure and essential service providers, to minimise the risk of overdependence on continuous electricity supply. Even with increased resilience investment, prolonged power outages will continue to occur. Other essential service provides should have appropriate investment incentive to manage their exposure during these extreme events. A framework for more visibility of the back-up power arrangements by different arrangements by the essential service providers would assist in faster and more effective power restoration activities.
Finally, we support the focus of the plan on the First Nations peoples. In our network investment planning we take a targeted approach to engaging with the First Nations peoples, to ensure our investments create least impact on lands that host them. We will continue to evolve our engagement with the First Nations peoples as we plan for the increasing risks of climate change and how that impacts our infrastructure plans.
As climate change intensifies, the cost to serve regional areas will grow disproportionately compared to urban areas
The effects of climate change on electricity infrastructure and the communities we serve is typically felt more in regional and rural communities located in areas of high vegetation and difficult to access terrains. As shows above, AusNet mostly covers regional areas that are mountainous with high vegetation density and terrains with limited road access, which means the impact of extreme weather is typical much larger compared to other parts of Victoria (evident through the last three large storms). Consequently, AusNet customers tend to
1 www.energy.vic.gov.au/about-energy/legislation/regulatory-reviews/electricity-distribution-network-resilience-review
AusNet Electricity Services Pty Ltd / ABN 91 064 651 118 4
pay more in network costs, including for preventive measures to reduce the risk of damage from weather events, as well as the cost of rebuild and operational response once the event occurs.
As climate change intensifies, extreme weather events will continue to impact AusNet’s network areas disproportionately, which would see AusNet customers continuing to pay more over time in comparison to urban areas and other parts of Victoria. Over time, this discrepancy may become unsustainable and create unintended equity and fairness gaps in climate change adaption. The potentially unfair outcomes for reginal customers are likely to be amplified as the energy sector transitions through electrification, with regional customers already feeling left behind regarding access to reliable electricity supply and access to electric vehicle charging.
Climate change adaption will require substantive communication to all Australians about the challenges of climate change and the need for, and benefit of, adaptive measures. It is important the state and federal governments take a leadership role in these communication campaigns, to ensure consistency in messaging around many of the challenges highlighted in our submission (and more).
Please do not hesitate to contact Sonja Lekovic on about the submission or our customer research.
Yours sincerely
Charlotte Eddy
General Manager Regulation and Policy (Distribution)
AusNet Services
AusNet Electricity Services Pty Ltd / ABN 91 064 651 118 5
