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AEMC Presentation AEMC Presentation Southern Generators proposal Southern Generators proposal 5 th September 2006 5 th September 2006 Todays discussion We are concerned that we did not communicate the context Communication


  1. AEMC Presentation AEMC Presentation Southern Generator’s proposal Southern Generator’s proposal 5 th September 2006 5 th September 2006

  2. Today’s discussion � We are concerned that we did not communicate the context � Communication clarification � Reliability in NSW � Reliability in VIC � Discussion on problem � LYMMCO’s (Southern Generator’s) proposal removes 1200MW of Murray generation � Problem has been significantly worsened by Eucumbene storage level � Summer reliability threat has only crystallised at end of August � NEMMCO is not practically able to manage the risk � Questions and general discussion

  3. Reliability in NSW � Snowy statement that there is no reliability issue related only to NSW reliability Submission to Snowy Hydro’s Re-orientation proposal dated 7th July 2006: In the following section, 7 Power system security and reliability We agree with the AEMC’s conclusion that the Southern Generators’ proposal will not materially affect reliability of supply to NSW , and consider this also applies to the reorientation proposal.

  4. Reliability in Victoria is however now of greater concern � The Victorian reliability issue is public knowledge because it has been discussed with NECA, ACCC, NEMMCO and on public forums in 2004 and 2005 (as well as with number of jurisdictions) � Conclusion of previous discussions was that the issue was not material. It would only be a problem if extreme low storage/low inflows are encountered. (Eucumbene was then 20m higher than today) � Please note that this was the assumption made by the southern generators (diversion rate based on wrong Eucumbene level) in their submission of 4/9/06 � Issue of reliability in Victoria was not discussed during AEMC LYMMCO consultation due to level of Eucumbene in summer 2005/06 and outlook at that time � Eucumbene level is now the lowest recorded and given August inflows the summer situation has become critical

  5. Inflows for July (received in early August) and August (received just before submission) August, September and October are major inflow months!!! July average (over last 105 years) 273Gl This July – 67Gl Only lower July on record 1965, 1967 and 1982 August average (over last 105 years) 345Gl This August – 87Gl Only lower August on record 1982 Prediction for next period very low due to little or no snow cover!!! Information was factually available to us only end of August!!!

  6. Eucumbene storage level continue to fall contrary to history and expectation Eucumbene Active Storage (%) - Period Jan 1970 to Aug 2006 100% 90% 80% 70% 60% Active Storage (%) Nov’05 50% 40% 30% 20% Mar-83 0 - 1131.34 m Aug-06 - 1130.34 m 10% 0% 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 7 7 7 7 7 7 7 7 7 8 8 8 8 8 8 8 8 8 8 9 9 9 9 9 9 9 9 9 9 0 0 0 0 0 0 0 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n n a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J J

  7. Continuous disclosure � Snowy Hydro has informed the Commission of material additional information as it arose during the process � Example: we sent information in early August which had significant empirical data about future Victorian price after draft determination of AEMC on this issue � Water information as soon as it was available end of August � Both pieces of information have had significant market impact…

  8. Both information have had material market impact VIC Bid Flat2007 $43.00 AEMC release Snowy’s water $42.00 Submission – market assumes reduction in $41.00 Draft determination – Snowy’s capability announcement of ‘no major $40.00 submissions’ on LYMMCO’s proposal – market assumes $39.00 done deal and responds accordingly $38.00 $37.00 Price $36.00 $35.00 $34.00 $150millions $50m $33.00 loss to customers loss to $32.00 (Mark to Market) customers $31.00 $30.00 6 6 6 6 6 6 6 6 6 6 6 6 6 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 2 2 2 2 2 2 2 2 2 2 2 2 2 / / / / / / / / / / / / / / 6 6 6 6 6 7 7 7 7 8 8 8 8 8 0 0 0 0 0 0 0 0 0 0 0 0 0 0 / / / / / / / / / / / / / / 1 8 5 2 9 6 3 0 7 3 0 7 4 1 1 2 2 1 2 2 1 1 2 3 Date

  9. Reality check (comparison with NSW price) Victorian price moved more than NSW NSW price went up, not down as predicted VIC/NSW Bid Flat2007 $43.00 $42.00 $41.00 NSW $2.50 $40.00 $39.00 $38.00 $37.00 Price $36.00 $5.50 VIC $35.00 $34.00 $33.00 $32.00 $31.00 $30.00 1/06/2006 8/06/2006 15/06/2006 22/06/2006 29/06/2006 6/07/2006 13/07/2006 20/07/2006 27/07/2006 3/08/2006 10/08/2006 17/08/2006 24/08/2006 31/08/2006 Date

  10. Scheme design and capability implications 1. Geehi is head pond for Murray generation (1500MW) 2. Water is transferred from Eucumbene to Geehi 3. Eucumbene level determines transfer rate to Geehi 4. Geehi storage is small storage (16 hours) � Geehi storage quantity is the critical resource for Murray generation � AEMC SG determination impacts Geehi levels and thus Murray generation

  11. Geehi cannot be allowed to spill – due to environmental damage in National Park � Managing Geehi dam operations is difficult because it is a small storage that cannot be allowed to spill � For environmental reasons, it requires avoidance of spill at all cost � Avoidance of spill requires low storage level and/or ability to generate Murray stations at high level during times of high inflow events (‘forced generation’)

  12. Equation is simple Natural inflow Geehi Storage Inflow from Eucumbene At this level equivalent to 350MW Murray power station 1500MW (market limited to 300MW by Lymmco’s proposal) Power output = Storage + Inflow + Eucumbene transfer

  13. Implications of the equation Currently, we aim to keep Geehi storage high(60-80%) to maximise generation capability Storm risk requires that we be free to generate at high levels or else we must keep the storage low LYMMCO’s proposal creates negative price risk for Murray generation (we will be forced to pay to generate) As a consequence we will choose to keep the storage low (30-50%) rather than pay to generate As a consequence Victoria will have less certain reserves (at the time when Murray becomes Victorian generator of last resort - 600MW can be supplied only by Murray, because of network limitations)

  14. Geehi summer inflow risks The 90% confidence ( 10% POE) inflow in a day for the summer period quantity risk for Geehi catchment is 3.9 Gl – refer to next slide 3.9 Gl inflow quantity is approximately 30% of Geehi active storage. Hence the LYMMCO proposal incentivises Snowy Hydro to reduce target storage levels from 60 to 80 % to 30 to 50%.

  15. Geehi summer inflow risks ML M L

  16. Storage reduction will cause unavailability on a number of days, assuming the same pattern as last summer Geehi Level 1105 70% 1100 Gehhi level [m] 1095 Geehi Level 25% 1090 1085 0% 1080 6 6 6 6 6 6 6 6 6 6 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 2 2 2 2 2 2 2 2 2 2 / / / / / / / / / / / 1 1 1 1 1 2 2 2 2 3 3 0 0 0 0 0 0 0 0 0 0 0 / / / / / / / / / / / 1 8 5 2 9 5 2 9 6 5 2 1 2 2 1 1 2 1

  17. Storage reduction will cause unavailability on a number of days, assuming the same pattern as last summer 1105 70% 1100 Gehhi level [m] 1095 Geehi Level SG Geehi Level 1090 25% 1085 0% ~1200MW 1080 1/01/2006 8/01/2006 15/01/2006 22/01/2006 29/01/2006 5/02/2006 12/02/2006 19/02/2006 26/02/2006 5/03/2006 12/03/2006 physically unavailable

  18. Further implications � Due to reduced generation capability there will be times that we cannot bid our generation due to its physical unavailability. This will have reliability implications and will have market price implications (price for Victorian customers) � Due to reduced generation capability Snowy Hydro is incentivised to withhold its lesser quantity of available generation in anticipation of future higher price periods (higher opportunity cost) � These will lessen competition confronting Southern Generators � Empirical evidence exist in previous slides related to future contract market

  19. NEMMCO issue raised because the only perceived solution to reliability under LYMMCO is NEMMCO’s intervention � If LYMMCO’s proposal is endorsed the only way to manage projected Victorian reliability issue is to assume that NEMMCO will intervene by way of DIRECTION � It is inconsistent to introduce a rule that requires direction (intervention) when the aim is to replace existing rule to avoid intervention � Potential NEMMCO’s direction will not ease ongoing market impact � DIRECTION WILL NOT WORK IN PRACTICE. � NEMMCO will not have information before it is available to Snowy Hydro. And thus it will be too late to issue effective direction. � An order in advance will not work in a practical sense, because it will create conflict between direction and subsequent dispatch instruction (would require full NEMMCO’s control of Murray assets over summer)

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