Missing impacts on new fossil fuel non-baseload generation

Submitters agreed that the scope of the ban should be limited to avoid impacts on the construction of non-baseload fossil-fuel plants. 

Non-baseload fossil-fuel plants play an important role in ensuring security of supply and smoothing the transition to net zero emissions. 

Some submitters identified the continued need for construction of new fossil-fuel baseload plants. 1 submitter quantified the “need to build up to 320 MW of new fast-start peakers by 2038 to ensure the increasingly renewable electricity system can meet growing demand at peak times.” This is primarily gas-fired peakers. 

Submitters identified difficulty in strictly distinguishing ‘baseload’ and ‘non-baseload’ generation when imposing a ban. Concerns were raised about the impact that uncertainty could have for potential investors. 

A majority of submitters felt that construction of non-baseload plants should not require a Ministerial exemption to minimise barriers to their construction. 

However, 1 submitter believed that requiring investors to apply for an exemption to construct non-baseload fossil fuel plants would ensure clarity and efficacy of the ban.