Energy Policy WA (EPWA) received an application for a generation licence exemption from Moonies Hill Energy Pty Ltd on behalf of FRWF Stage 1 Pty Ltd, to generate electricity at the FRWF Project.
FRWF Stage 1 Pty Ltd is a special purpose vehicle 100% owned by Moonies Hill Energy.
The public consultation period on the application closed on 28 January 2022. A copy of the licence exemption application can be found below. Three submissions were received and are available below.
One submission supported the application. Two opposed it, expressing concerns around the lack of competitive neutrality that would occur between licensed and unlicensed generators of the same size if the licence exemption application were to be granted. These submissions noted that there are considerable costs incurred by licensed entities such as licence application costs, annual licence fees, and the costs associated with regulatory reporting that are avoided by non-licensed entities.
Due to the competitive neutrality concerns identified the exemption application will not be progressed further. One of the criteria for granting an exemption is that the exemption must not be contrary to the public interest. In this case, EPWA considers that public interest would not be served by having different licensing requirements on generating facilities that are substantively the same size and have similar characteristics.
A proposal to amend the capacity threshold for the electricity generation licence exemption from 30MW to 100MW is currently open for consultation. Further information is available in the consultation paper.
Requests for information relating to this work will be treated in accordance with the Freedom of Information Act 1992 (WA) and Energy Policy WA processes.
Generation licence exemption application – FRWF Stage 1 Pty
Generation licence exemption application – FRWF Stage 1 Pty Ltd PDF (1554KB)
Submissions - FRWF Stage 1 Pty generation licence exemption application
Alinta Energy Pty Ltd PDF (137KB)
Australian Energy Council (AEC) PDF (157KB)
Change Energy Pty Ltd PDF (594KB)