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Lower South Island Reliability Transmission Investment Proposal Submission from Contact Energy Limited Lower South Island Reliability Transmission Investment Proposal - 30 June 2010 Introduction Contact welcomes the opportunity to provide feedback on Transpower’s investment proposal. The information in this submission is not confidential. For any questions related to this submission, please contact: James Collinson-Smith Manager – Market Services Contact Energy Limited L 1 Harbour City Tower 29 Brandon Street PO Box 10742 Wellington Email: [email protected] Phone: (04) 462 1249 Fax: (04) 499 4003 Page 2 of 4 30 June 2010 Lower South Island Reliability Transmission Investment Proposal - 30 June 2010 Summary Contact Energy Limited (“Contact”) supports Transpower’s aim to ensure appropriate investment is made in the national grid to meet the needs of electricity consumers and generators. Contact fully supports this investment proposal because it will add essential core-grid capacity between Roxburgh and Invercargill, and it will also provide much needed security of supply to Southland consumers supplied from the 110kV system. Any further increases in constraints on the 110kV system are likely to be detrimental to retail in the Otago-Southland area. These grid upgrades are overdue, as capacity and voltage problems arise whenever a 110kV or 220kV circuit is removed. The Roxburgh interconnecting transformer (T10) overloads under certain load flow scenarios (i.e. during low ROX 110kV generation), T10 may overload with an outage of the Halfway Bush interconnecting transformer (or either of the INV_ROX 220kV circuits, or either of the ROX_TMH 220kV circuits). Contact has to manage this operationally through Roxburgh 110kV generation and therefore wants the Roxburgh T10 interconnecting transformer to be upgraded as soon as possible. Contact cannot guarantee continued voltage support to the 110kV system, as without some certainty of the Roxburgh T10 upgrade we may be incentivised to transfer the Roxburgh G6 generating unit to the ROX 220kV bus. Note that we have not refurbished Roxburgh G8 and therefore it should not be assumed that this would be available for voltage support. The lower South Island (“LSI”) region is unique in that it is dominated by the NZAS Smelter load, important dairying load, and has the potential for a number of large generation developments therefore it is important that security is maintained under a range of scenarios. Each of the generation developments could impact significantly on the timing of grid development requirements in the region. In terms of incentives for new generation developments, Contact notes that Transpower’s generation assumptions do not consider the potential changes in the transmission pricing methodology (“TPM”) with respect to HVDC charges. This reduces the incentives to invest on the core grid in the South Island. If the TPM were to change such that HVDC charges to South Island generators were removed then it would raise the merits of potential South Island developments relative to other options. Should Trustpower’s Mahinerangi windfarm be built to its consented 200MW all Roxburgh 110kV, generation may be transferred to the Roxburgh 220kV bus. Page 3 of 4 30 June 2010 Lower South Island Reliability Transmission Investment Proposal - 30 June 2010 Page 4 of 4 30 June 2010