NO NO NO NO!!!! Enough of these activist institutions selling out...

@FootnotesGuy
Aidan Morrison@FootnotesGuy
20 views Oct 12, 2026 ~5 min read
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NO NO NO NO!!!!

Enough of these activist institutions selling out their independent mandates to protect consumer interests in favour of pursuing Bowen's vanity projects.

“The benefits that we can see is the virtuous cycle of more chargers leading to more EVs leading to more chargers leading to more EVs – and more EVs on the road means reducing emissions ... one of our specific objectives.”

Piss off with your "virtuous circle" BS. You're meant to push back on uneconomic proposals that interfere with consumer interests that are best met by market forces!

A 🧵 to expose what a betrayal this is. Absolutely indefensible. 1/
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Here's an open-letter from... Oh wait...

The entire EV and electricity industry....

Opposing the Rule Change to slug energy consumers for network-owned chargers.

Because it doesn't look like it's in consumer interest! And these guys think they can do it better than the poles and wires folks. 2/
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Really great submission from Tesla. Just the cover letter here.

But they point out that if you make something a regulated monopoly service, it basically poisons the trough for private investment.

The market can do this so much better!
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I've seen some really impressive Tesla charging networks in France.... I'm kinda gobsmacked that they can make it work economically.

But if anyone can... they can...

So don't let the networks make this a for-ever subisdy for a second-class service!
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@FootnotesGuy
Aidan Morrison@FootnotesGuy
While away in France, I had occasion to see some of Tesla's fast-charger network.

It's very impressive technically.

But translating the engineering to economics to finances makes me wonder how it scales. 1/
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So how do they justify this nonsense...

They say that emissions reductions are more important than higher costs to consumers in this case.

There are competing limbs of the National Electricity Objective, they have to consider both.

5/
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So quick backtrack, this is the Rule Change Request. From DCCEEW, Chris Bowen's department. This is driven by Chris Bowen, it's not an organic suggestion from industry or stakeholder groups.

It claims an economic benefit... because emissions have an economic value.

According to declarations made by ministers, and an "Interim Value on Emission Reductions" can be applied so that they can calculate nearly a billion dollars in Net Present Value of benefits from 10 million tonnes of carbon emissions averted over time.

They can claim this benefit (of emissions reductions) is a benefit to ALL consumers, regardless of whether they use EVs..

Ok... if you say so. 6/
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The AEMC goes and re-runs this type of calculation...

And they list a whole heap of assumptions in an appendix.

But the don't mention anywhere (strictly nowhere) the most important assumption.

The Value of Emissions Reductions, ie price of carbon assumed. 7/
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Now we know how AEMC does apply emissions reductions... because in July they released a big "Final Guidelines" note on how it would work.

Claiming they have discretion in managing the balance between the competing objectives (for example with price). 8/
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And they spell out that if a quantitative comparison is required, they use an interim Value of Emissions Reductions (VER).

Interesting this thing actually expired 30 June! No replacement.

That's hardly surprising... because there's now an almighty stoush between the federal minister and a certain state (QLD) about whether coal can be used to power new industries, including data centres.

And I strongly suspect that the VER that was agreed would regain adoption from this council of ministers.

But because the AEMC is... well... basically under the thumb of Chris Bowen. So they'll do him a solid and keep applying the same VER as though nothing as changed, even though everything actually has. 9/
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By the way, when this VER was adopted, we at @CISOZ wrote a whole paper on it. Because we knew it would be used like this, to foist costs for uneconomic investments through to consumers, while giving a thin veneer of economic 'cost benefit' language. 10/

cis.org.au/publication/th…
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And here's a reminder of how that VER looks. So you can see how over $100/tonne is applied in the department and AEMC's model over the life of a charger installed in a couple of years. 11/
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Here's the official table from the AER Guidance note.

Hey, any politicians out there want to advocate for a shadow carbon tax that runs up to $420/tonne?

Well that's the shadow carbon tax that your silence and disinterest has allowed to be inserted into our rules and regulations without anyone saying boo.

The paper we wrote to make the impacts of this understandable at the time is a few posts up. You're welcome. Catch up. 12/

aer.gov.au/system/files/2… - Valuing emissions reduction - Final guidance and explanatory statement - May 2024.pdf
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Anyway, the AEMC calculation is basically opaque and irreproducible from their own assumptions because they avoid showing the part where they apply this carbon price year by year.

Again, this is the kind of cynical avoidance of defending the trade-offs and value judgements your decisions depend upon is really cowardly. Massively pisses me off. If that's the value that emissions reductions have in your model, come out and say it! Defend your number!
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But to make a rule change in favour of the method proposed by the Minister, when the entire industry that should be supported by this is vehemently opposed, at the same time as consumer interests are clearly subordinated by an implicit carbon price they won't name...
This is seriously, inexcusable behaviour from a statutory body that is set up specifically to keep meddling ministers out of efficiently functioning markets that are supposed to actually protect consumer interests.

No one is angry enough about this.
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