8
4.17. This enhanced capacity to respond to impacts of the pandemic reduces the potential
for the COVID-19 pandemic to give rise to outages or other system security issues.
Improvements to system security, safety and reliability flow onto economic benefits by
avoiding outages for consumers and producers, and minimising damage to energy
system infrastructure through system instability.
4.18. The ACCC therefore considers that the Proposed Conduct is likely to result in a public
benefit in the form of providing greater capacity to ensure the ongoing safety, security
and/or reliability of Australian energy systems.
Minimising costly delays to maintenance
4.19. Travel restrictions, border closures, and other impacts on production are likely to
impact on critical maintenance activities in the energy system. Maintenance at facilities
such as thermal generators can involve significant temporary workforces and highly
specialised foreign labour. These workforces may not be available, or may be
significantly restricted in their movements during the COVID-19 pandemic. Core
components are often imported from specialised manufacturers, and these supply
chains may be disrupted due to COVID-19.
4.20. The COVID-19 pandemic is likely to make maintenance activities more difficult to plan
for, and has the potential to cause delays and extended outages at specific
generators. Such delays or outages at specific generators would impose costs to those
generators. These costs will likely be passed through to consumers.
4.21. The Proposed Conduct is likely to reduce the potential for COVID-19 to cause delays
or extended outages at specific generators. Participants should be able to coordinate a
maintenance schedule that minimises the potential for delays to cascade and create
overlapping, expensive outages. Sharing information will better allow Participants to
find relevant labour and components in the unique COVID-19 circumstances.
4.22. While in normal market conditions, the ACCC would generally take the view that
competition between generators is likely to be superior in allocating maintenance
labour and components, the COVID-19 pandemic may cause acute supply issues to
such markets, such as forcing large teams of skilled labour to quarantine, or become
sick, for extended periods of time. Given the potentially high cost of delays to
maintenance, the ACCC considers that there is public benefit in minimising these costs
during the pandemic.
4.23. AEMO and relevant Participants in Queensland and Victoria have been coordinating
maintenance under the interim authorisation. Such activities reflect that there have
been some COVID-19 related disruptions to maintenance plans.
4.24. An example of this public benefit during the interim authorisation (provided by AEMO)
was when, through discussions held under the interim authorisation, one generator
was able to quickly locate an alternative local supplier of a major part that would
ordinarily be imported from Germany but was unavailable for importation due to
COVID-19 pandemic related restrictions in Europe. This avoided an extended outage
which was at risk of overlapping with other scheduled outages in the state, giving rise
to risks of energy outages. The sharing of this information (which does not ordinarily
occur, even through AEMO) caused other generators to consider their supply chains
for their outages earlier than originally planned, to avoid the risk of delays for their
outages.
4.25. The ACCC considers that the Proposed Conduct is likely to result in a public benefit in
the form of minimising costly delays to maintenance.