Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697636758861.pdf (Australia)
Snowy hydro and market concentration November 2019 Snowy hydro currently has a dominant position in the peak generation and the related cap contract market segment of the National Electricity Market (NEM).

When analysing peaking generation capacity, this becomes readily apparent (see Figure 1 below).

• Two thirds of the peaking generation capacity in NSW, and half of the peak gener- ation capacity in Victoria is currently owned by Snowy Hydro.
• This is an exceedingly concentrated market in both NSW and Victoria, according to common metrics.

• Assuming “Snowy 2.0” is completed, the market share will be further increased, and the degree of concentration will become untenable.

Figure 1: Current market share of peaking generation capacity for NSW and Victoria market regions.
1 Figure 2: Market share of peaking generation capacity for NSW and Victoria market, as- suming Snowy hydro peaking capacity in NSW increases by 2000 MW on completion of “Snowy 2.0”.

Herﬁndahl–Hirschman Index (HHI) The Herﬁndahl-Hirschman index (HHI) is a commonly used measure of market concentration and is reported annually by the Australian Energy Regulator (AER) in the ‘State of the Energy’ market report (AER 2018, page 127).
The HHI is a static metric, calculated by summing the squares of the percentage market shares for all ﬁrms participating in a market.

An HHI value of 10,000 is equivalent to a 100% share, and represents complete monopoly.
An HHI value of 2000 is used by the Australian Competition and Consumer Commissions (ACCC) to ﬂag competition concerns (ACCC 2008, page 37), while the U.S Department of Justice considers markets to be unconcentrated at below 1500, moderately concentrated at 1500-2500 and highly concentrated at 2500 (U.S. Department of Justice and Federal Trade Commission 2010, pages 18 and 19).

The UK’s Oﬃce of Gas and Electricity Markets (OFGEM) guidelines are perhaps more relevant for the electricity market in Australia.
The OFGEM regards an HHI exceeding 1000 as concentrated and above 2000 as very concentrated (OFGEM 2015, page 37).

With a HHI value of 1243 in 2015, the considers the UK wholesale electricity market somewhat concentrated (OFGEM 2015, page 64).

2 HHI in the NEM The most recent aer ‘State of the Energy’ market report shows annual HHI trends for each of the four mainland states over several years (AER 2015, Figure 2.38, page 127).
aer’s reported an average HHI over 2000 for each region, which has not varied signiﬁcantly in recent years.

This is high by both OFGEM standards, and standards used by the ACCC.

In this analysis, the peaking section of the market is analysed a separate segment.
Specif- ically, only scheduled generators of the following technologies type are included: • Hydro • Open cycle gas turbines • Combined cycle gas turbines1 • Reciprocating engines (distillate and Gas) • Batteries These technologies are typically used to meet peak demand, and have low capacity factors.

They do not typically compete with technologies that produce bulk energy (for example coal, wind or solar).

In addition, these power plant sell (and are ﬁnanced through) cap contracts.
As such, it is not unreasonable to consider this market segment in isolation.

The following tables contain the list of scheduled generators and participants considered in this analysis from each state.
Victorian peaking generation Participant Power station AETV AGL Ecogen Bairnsdale Power Station Bogong / Mackay Power Station Dartmouth Power Station Eildon Power Station Somerton Power Station West Kiewa Power Station Jeeralang ‘A’ Power Station Jeeralang ‘B’ Power Station EnergyAustralia Ballarat BESS Gannawarra Energy Storage System Hume (Vic) Hydro Power Station Mortlake Power Station Laverton North Power Station Murray Power Station Valley Power Peaking Facility GSP Origin Snowy Total Max capacity 94.0 300.0 185.0 120.0 170.0 68.0 260.0 300.0 30.0 25.0 70.0 584.0 344.0 1575.0 360.0 4485.0 1Traditionally, CCGT’s operated at high capacity factors.
Current generation patterns suggest they operate more as peaking generators.
3 NSW peaking generation Participant Power station AGL Hunter Valley Gas Turbine EnergyAustralia Tallawarra Power Station GSP Origin Hume (NSW) Hydro Power Station Shoalhaven Power Station Uranquinty Power Station Smithﬁeld Smithﬁeld Energy Facility Blowering Power Station Colongra Power Station Guthega Power Station Tumut 3 Power Station Tumut Power Station Snowy Total References Max capacity 50.0 440.0 70.0 240.0 664.0 185.0 80.0 724.0 80.0 1800.0 665.0 4998.0 ACCC.

2008.

Merger guidelines.


Canberra: Australian Competition and Consumer Commi- sion.

AER.

2015.

State of the energy market 2015.

Melbourne, Australia: Australian Energy Reg- ulator.

— .

2018.

State of the Energy Market 2018.

Melbourne, Australia: Australian Competition / Consumer Commission.

isbn: 978 1 920702 11 3.

OFGEM.

2015.

Wholesale Energy Markets in 2015.

London, United Kingdom: Oﬃce of Gas and Electricity Markets.

U.S. Department of Justice and Federal Trade Commission.

2010.
2010.

Horizontal Merger Guide- lines.

United States of America.

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