We thank the Victorian Government for the opportunity to comment on the Victorian Transmission Investment Framework Preliminary Design Consultation Paper (VTIF Paper). We commend VicGrid on the substantial work that has been involved in designing VTIF. Previously RE-Alliance made a Submission to the Victorian REZ Development Plan Directions Paper, an engagement process that informed the VTIF, and participated in the Legislative Council Environment and Planning Committee Inquiry into renewable energy in Victoria. Both should be read in conjunction with this submission.
We consider that the VTIF has many potential benefits for Victorian communities and contains several innovative features not currently available as part of the national transmission framework. As such, we consider that this framework may be superior to the existing national framework due to the inclusion of a number of features including:
- a new early strategic planning process which will take on the views of communities early in the process before the regulatory investment test process;
- a strategic land use assessment (SLUA) geospatial mapping exercise to identify the lowest impact corridors for transmission development and new generation;
- a new optimisation analysis technique which would shift the emphasis from the current central scenario based approach to analysing a strategy which would perform best across a range of plausible scenarios; and
- a new Victorian Network Investment Test which may be either least net cost or maximum net benefits but which would ensure that transmission necessary for reliability and security of supply is built even if returns a net cost.
We congratulate VicGrid for providing such a well researched and innovative Consultation Paper.
It must be noted however that there are a considerable number of urgent issues facing the Victorian Government in the transmission space. We note that the Consultation Paper states that the VTIF would apply to all future Victorian transmission development, but not apply retrospectively to projects that have already commenced regulatory processes. This is unfortunate, as there are major issues facing some of these projects, with social licence issues being particularly relevant.
Not included in the paper are other issues of significant importance, including cost allocation arrangements for inter-regional connectors like Marinus Link, more detail on the proposed offshore wind arrangements, responses to various proposed privately funded transmission lines, and the stage 1 upgrade of the Western Renewables Link from Ballarat to Bulgana (an upgrade that would immediately resolve some social licence issues).
RE-Alliance suggests that a package of project based solutions/reforms may be more urgent than the implementation of VTIF. This package may take the form of interim measures for investment before the first Optimal REZ Pathway Plan and any subsequent REZ declarations will be made prior to the release of the 2024 ISP.
RE-Alliance also sees a role and function for VicGrid more broadly in REZ coordination, to capture strategic opportunities, provide leadership and advocacy, and facilitate generation development. VicGrid could have a leadership role in ensuring the energy transition is locally led and benefits local communities.
However, we consider VTIF is best practice for future developments and we commend VicGrid on the package.