{"data":{"id":"sbm2e0b816c7bf8385951785","short_id":81,"created":"2024-05-14T04:42:39.611Z","space_id":"spc2d334047ad0d7e7aa8046","project_id":"prj2d3336e5a90d264a70605","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Karan Sharma","name-of-organisa_9974be":"Alinta Energy","upload-your-subm_09396f":"fil2e0b811181673758b8ab5"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil2e0b811181673758b8ab5":{"id":"fil2e0b811181673758b8ab5","bucket":"files-au-climate","remote_path":"cca/p/prj2d3336e5a90d264a70605/submission/spc2d334047ad0d7e7aa8046/Final_Alinta_Energy_CCA_Sectoral_Pathways.15fa4228.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj2d3336e5a90d264a70605/submission/spc2d334047ad0d7e7aa8046/Final_Alinta_Energy_CCA_Sectoral_Pathways.15fa4228.pdf","filename":"Final_Alinta Energy_CCA_Sectoral Pathways.pdf","transcribed":"14 May 2024\n\nClimate Change Authority\n\nSubmitted through website\n\nElectricity and Energy Sector Plan Discussion Paper\n\nAlinta Energy welcomes the opportunity to provide feedback to the Climate Change\nAuthority on the transition and emissions pathway for the Electricity and Energy Sector.\n\nWe are an active investor in energy markets across Australia with an owned and contracted generation portfolio of over 3,300MW and more than one million electricity and gas customers.\n\nAlinta Energy supports Australia’s net zero emissions by 2050 target and the Australian\nGovernment’s development of emissions pathways for all sectors to achieve the target. Electricity generation has done most of the heavy lifting in reducing Australia’s emissions to date, and it is now critical that action is taken across other sectors of the economy.\n\nOur feedback is categorised by technology, the deployment of which we believe is critical to Australia meeting its emissions targets and should be prioritised.\n\nLong duration storage\n\nDispatchable generation capacity is essential for a successful transition to support the increased penetration of intermittent generation in achieving Government-set emission reduction and renewable targets. This is particularly the case through prolonged periods with low or non-availability of renewable resources, which cannot be covered by short-term storage, and would otherwise impose both significant economic losses arising from power outages and higher long-term energy costs on consumers.\n\nLong duration storage (LDS) technologies, such as pumped hydro and biomass, differ from short/medium duration storage technologies in numerous aspects, including (but not limited to) scale, total investment, complexity, infrastructure build, labour requirements, supply chain issues and development period. Technologies that can provide long-duration (more than 8 hours) dispatchable electricity, are significantly more complex, have longer lead times and therefore need long-term policy certainty and support to facilitate their development.\n\nIt is critical to deploy a portfolio approach to enable different technologies to leverage their respective strengths, with the resultant synergies ensuring the most effective and efficient outcomes for consumers. For example, both pumped hydro and biomass-fired generation can provide system strength capabilities including inertia, fault current and reactive power, critical for network security and enabling integration of higher levels of\n\frenewable energy, and which batteries cannot provide. Such an approach would also minimise issues related to technology localisation, supply chain constrains, a tight labour market, and global competition associated with specific technologies.\n\nThe Government should consider providing separate support for LDS and fully dispatchable projects that can provide dispatchable power generation for more than\n8-hours or establish a capacity market that values the availability of renewable dispatchable generation capacity. A flat capacity payment or a bespoke LDS contract for difference (CFD) mechanism would significantly de-risk high risk projects, particularly those that provide long duration dispatchable capacity, and provide the revenue stream confidence required by proponents to acquire capital. The support arrangement needs to be flexible for different technologies with different requirements, to ensure a suite of projects employing a diverse set of technologies are developed.\n\nAlinta Energy recommends the Government provide support for the development of long duration (more than 8 hours) storage projects, that can provide critical network services to safeguard the transition, via a mechanism with flat capacity payments or bespoke CFD arrangements.\n\nBioenergy with Carbon Capture and Storage\n\nThe International Energy Agency, the Intergovernmental Panel on Climate Change\n(IPCC) and other leading global energy agencies have recognised the potential for carbon capture and storage (CCS) technology to play a significant decarbonisation role in the transition to net zero.\n\nAustralia has a natural competitive advantage with respect to CCS development with known high quality, stable geological storage basins, proximity to existing emissions sources, existing infrastructure, world-class technical expertise and regulatory regimes\n(including environment protection, carbon accounting and reporting and financial services).\n\nWhen combined with biomass powered electricity generation, BECCS (bio energy carbon capture and storage) can provide essential engineered carbon removals\n(CDR’s)/negative emissions that are considered essential by the IPCC to limit warning to 1.5oC.\n\nBiomass powered generation is only potentially constrained by the biomass supply chain, whilst BECCS technology offers the highest possible use of geological storage capacity and biomass feedstock, both finite and valuable resources.\n\nDeployment of BECCS would also create opportunities for the use of captured biogenic carbon dioxide. For example, this could enable the manufacture of very low\n(or negative) emissions fuels and chemical derivatives, such as sustainable aviation fuel\n(SAF). Additional utilisation of captured biogenic CO2 could include manufacture of food and beverages, in the production of urea, and as a feedstock for fertiliser production.\n\nTechnical deployment of BECCS, a critical Carbon Dioxide Removal (CDR) technology, will be feasible in Australia in the near future, however policy and financial is needed to enable and accelerate its deployment.\n\fAlinta Energy recommends that the Government provide additional support for BECCS technology to accelerate its deployment and capitalise on Australia’s natural advantages.\n\nGas-fired Generation\n\nGas-fired power generation (GPG) will be a critical enabler for the establishment and successful integration of a predominantly (more than 80 per cent) renewable electricity powered grid. Over the past decade, the flexibility and reliability of GPG peaking plants in supplying dispatchable power have provided necessary support and backup required for grid security and reliability in periods with little or no renewable electricity generation. We concur with Australia’s former Chief Scientist, Alan Finkel who stated1:\n\n      “The future of gas is to provide peaking generation to ensure continuity of electrical\n      supply during sustained periods of low wind and sunshine. Using batteries,\n      overbuilding, and more transmission lines to cover these extremes will either be\n      impractical or very expensive…by using gas for the last 10 per cent we will avoid\n      needing to overbuild solar and wind, and will minimise the need to build long\n      transmission lines to shuttle the solar and wind electricity vast distances.”\n\nAlinta Energy welcomes and supports the Federal Government’s Future Gas Strategy.\nWe strongly agree with the observation on page 38 of the strategy2:\n\n          “GPG will underpin Australia’s electricity supply in the transition to a net zero\n          economy. It is likely that gas will still play a role in electricity generation up to\n          and beyond 2050.”\n\nAlinta Energy recommends the Government support the development of GPG peaking plants to allow for efficient build of intermittent renewable generation and minimise additional transmission requirements.\n\nOffshore Wind Energy\n\nAlinta Energy supports the position of the Victorian Government, as stated in its\nOffshore Wind Energy Implementation Statement 3 (page 10), that “early offshore wind projects will require financial support to ensure projects are bankable and insurable.”\n\n          “...it is recognised that there is value to the state in an energy system which\n          benefits from offshore wind resources. It is anticipated that greater support will\n          be needed for the first tranche of generation infrastructure compared to later\n          tranches, reflecting market maturity, as has been observed in more mature\n          markets overseas.\n\nWe also support the Victorian Government’s recognition of the need for Federal-State cooperation, as evidenced by its commitment to “continue to work with the Australian\nGovernment to ensure the proposed Victorian Government support package is well- integrated with national capacity incentives.”\n\n\n1   AFR, Alan Finkel, Aug 2, 2023, Say no to nuclear, and yes to gas-fired power, accessed on 19 April 2024.\n2Future Gas Strategy, Australian Government Department of Industry, Science and Resources, p. 38.\n\fThank you for your consideration of our submission. If you would like to discuss this further, please contact Karan Sharma at karan.sharma@alintaenergy.com.au.\n\nYours sincerely\n\nGraeme Hamilton\nGeneral Manager, Government & Regulatory Affairs\n\f","size":128863,"redacted":[],"meta":{"name":"Final_Alinta_Energy_CCA_Sectoral_Pathways.15fa4228.pdf","local_path":"files/vTt7n-NNduCwOzXkjDIweaac.pdf"},"config":{}}}}}