Formal submission to

the "Proposed interconnector linking the Victorian and Tasmanian electricity grids.


for the Integrated Impact Assessment Statement."

by M. Gunter, submitted to the Joint Advisory Panel on 28th June 2000.


Let's cut to the chase. People are fed up with being dished up this sort of grinding bureucratic "consultative" process. If I were to restrict my comments to dispassionately pleading for certain re-wordings and new clause inclusions, I would be tacitly and passively complying with this "grind down the opposition" approach to steam rollering yet another dubious large scale technological fix over an unsuspecting public. The proponents, especially the Tasmanian government (which should be neutral), are so far along the track of being publicly committed to the project, and sunk so much time and effort into glossy supporting literature, that Basslink already seems to have developed an enormous momentum, and ordinary citizens are presumably supposed to feel yet again disempowered and hopeless that this "unstoppable" project could on common-sense and even economic grounds be killed off.

This is my formal submission to the "Proposed interconnector linking the Victorian and Tasmanian electricity grids. DRAFT SCOPE GUIDELINES for the Integrated Impact Assessment Statement."

"1.1 The rationale

Basslink represents a major energy initiative that will allow the trade in electricity between Tasmania and the new National Electricity Market (NEM), the wholesale market in electricity that allows energy companies to trade across State borders."

Part 1 1.1 The Rationale: Electricity customers need to know whose initiative the scheme was. Governments seem to be spruiking for private enterprise, as seen by the extensive web resources made available to the Basslink proponents at (note: as of early July 2000, this site has been closed by the Tasmanian government). In terms of the evolution of a former state monopoly industry, the NEMs new participants, by vigorously promoting more large-scale interconnectors, seem to be regarding the new energy market as "business as usual". Yet again, we have an industry addicted to growth for its own sake; encouraging the most blatant and wasteful energy consumption practices by its customers; with the politicians and economists cheering from the sidelines, because all this activity "grows the economy". However, the present over capacity of supply in Victoria and Tasmania can be maintained for decades, at reduced net energy cost to the consumer, by government siding with the customers, the voters, and the environment, and forming an alliance to counter the seductive energy-wasting strategies of the new asset owners. The National Electricity Market is increasingly evolving into a stock-exchange, casino or derivative market which bears little relationship to the real flows of physical energy throughout the system. Nether does the NEM have mature mechanisms to address the most energy-efficient and sustainable ways of evolving the system to cope with the biggest challenge mankind has ever faced: defending 2000 years of civilisation against the threat of accelerating environmental degradation, through global warming.

Environmental outcomes of electricity industry privatisation to date have been severely negative. Coal is "cheap" because the polluters are not paying for the environmental costs of their activities. When the proponents of four new coal plants in Queensland can get such projects off the ground, it is apparent that nobody in positions of power is taking the threat of global warming at all seriously. The Australian Cogeneration Association has been fighting hard for 5 years to try to get the existing baseload generators to pay their fair share of network access, but NECA has somehow been persuaded that generators should not have to pay the real cost of getting their product to the customers. This project will be manna from heaven for the dirty baseload generators, especially if they can persuade governments to interfere with the market by making Basslink a regulated asset.

"Specifically, Basslink will allow Victoria and other States that are part of the NEM, to export electricity to Tasmania. It will also allow the export of renewable energy sources from Tasmania into the NEM. The flow of electricity between Tasmania and the mainland is likely to occur in either direction during parts of any day"

The public needs to have ballpark figures of the likely flows in each direction, perhaps for a number of different "economic" ways in which the asset may be utilised. We also need to know from the outset if the asset is going to be regulated or unregulated. With the level of commercial risk exhibited by Victorian privatisations over the past six years, I would be surprised indeed if the people of Victoria, Tasmania and Australia were not yet again going to be required, through usurious contract clauses, to underwrite the project, just like CityLink and Loy Yang's broken generator. It seems corporations and capital markets have taken their demands for economic certainty to new heights, and can never find the cash for any major project unless it is a dead-certainty to make buckets of profits. If by some miracle, the public was on this occasion to be spared the economic risk, then Basslink would become an unregulated asset, and the potential beneficiaries would by rights have to pay for the market access afforded by the project. The major entities standing to benefit are Victoria's brown coal generators, and possibly the NSW generators, by a "domino effect": Vic generators currently selling cheaply into NSW will be selling southward, which will free up the NSW off-peak market for local black coal generation to come online: I have heard this described as "NSW generators using Basslink to sell energy into Tasmania", and indeed this may be the way the paper contracts deal with the net result of the new equilibrium. However, this is a gross distortion of the physical reality: load flow analysis of the real energy would show the energy going south to Tasmania comes chiefly from Victorian baseload generators close to the Loy Yang Switchyard, irrespective of what the NEMMCO settlements and contracts may notionally say. In deciding whether Basslink is a common-sense thing on grounds of economic efficiency and environmental sustainability, it is much more important to look at the likely physical flows of energy, than to take any cognisance of the paper contracts, trades and derivative markets.

"It is expected that hydro-electricity from Tasmania will be exported at those times of the day when demand for electricity is at its peak – for example, in the morning before most people go to work, or when they come home in the evening."

The same effect could be achieved at net economic benefit and greenhouse benefit, by a Government campaign to replace electric stoves with gas stoves, and other similar measures to reduce peak demand on the mainland. Basslink will also severely restrict market opportunities for new cogeneration projects to gain a toehold in the mainland market.

"This is because Tasmania's hydro-electric system is able to be operated to meet peak electricity demand more efficiently (by regulating flow of water to turbines) than the predominant thermal based generators on the mainland (because boilers supplying steam to turbines cannot quickly be turned up or down). On the other hand, it is expected that mainland power suppliers will use Basslink to supply Tasmania during those times of the day when demand and prices for electricity are lower."

Alternatively, the Tasmanian government could embark on a massive and long-term job creation strategy of providing 5m2 of solar water heating to every domestic residence in the state, as well as every school, office and government building. Retrofit of solar space heating to the existing building stock should also be explored. This not only keeps Tasmania free of high-emission related electricity, but acts as the perfectly integrated way to conserve valuable hydro-generation water during every sunny summer, and especially during every drought, when there would be even more sunshine for water heating (thus conserving hydro water) than during a normal year.

It seems to me that Basslink as described in the proposal almost guarantees to increase Australia's per-capita greenhouse emissions by extending the reach of dirt-cheap baseload lignite. This must inevitably delay the introduction of more environmentally sustainable energy market solutions for Tasmania locally. The wording of the Draft Guidelines clearly implies that the expected net energy flow will be southward: Even if Basslink was a superconductor, this would substantially increase Australia's net GHG emissions, but once electrical losses of dual AC-DC conversion, and transmision losses are taken into account, Tasmanians may be dismayed to learn how dirty their night-time use of electricity is about to become (should the project get the nod). If a 600 MW links is in place, it seems likely that suddenly, it would make "economic" sense to turn off all hydro generation at night, in order to gamble the water on the "stock market" of the next day's (mainland) peak demand. As a worst case scenario, 200,000 Tasmanian households might each have a massive storage hot water service with a 3 kilowatt element. This is a 600 MW load, running for up to 6 hours each night. If Basslink electrical losses are 10 per cent, then 660MW would have to be fed in at the Victorian side. Sixty Megawatts of losses for six hours every night is 360 MWh per night or 131,400 MWh per year. So just for hot water Tasmanians might be about to shoulder responsibility for 1,314,000 MWh of dirty Victorian power that they actually used, and 131,400 MWh that never got to them because it was warming the mud at the bottom of Bass Strait. The total emissions of Tasmania's night time water heating could suddenly jump from about zero to about two million tonnes of CO2 per year. Have Tasmanians been informed of the facts on emissions?

Time constraints preclude a chapter and verse treatment of the Draft Scope Guidelines document. In dealing solely with the "Rationale", I think I have brought forward many arguments which show the proposal to be irrational. If the Proponents want to act irrationally and spend their money on an unregulated interconnector fully exposed to the financial risk, and wish to try to extract from the Victorian generators a fair and reasonable price for delivering their product to unsuspecting Tasmanians, then good luck to them. Governments must stop playing the old game of regarding interconnectors as essential infrastructure when there are clearly many other sustainable and cost-effective ways of satisfying voters' energy demands. Even a piece of string can compete with the electricity market, when it is a clothes line being used as a "green" alternative to an electric clothes dryer.

By way of background, the following appendix is an extract from a publicly accessible posting I have recently put on the ABC's Science Forum web site. Some engineers have responded on the forum by alleging that I have "lost the plot". Time will tell whether it is those who seek to protect the environment, or those who deny that their actions have a significant environmental impact, that are the mad ones. The public consultation process for Basslink must be totally transparent, devoid of "fudging" uncomfortable realities, and the Tasmanian Government should provide an equal amount of funding* for opponents to develop alternative scenarios to Basslink. (*to match funds already spent by all Australian governments assisting the proponents e.g. Web site space at


I believe the time has come for consumers to boycott regressive and environmentally destructive off-peak electricity tariffs for the simple reason that those tariffs aid and abet the construction of more and more coal-fired power: 82 per cent of hot water in Qld is provided by off-peak electricity: where would the need for interconnectors and four new coal power stations be if every Qld home, school and office had a solar water heater? Industry must also play its part: the trade union movement has realised that there are "no jobs on a dead planet", but when is the corporate world going to realise that there are no GDPs, no profits and no investors on a dead planet either? Next they will be telling us that it is "inevitable" that Australia must have nuclear power stations in order to meet our Kyoto targets, which is bullshit (pardon the language).

Please read the CSIROs latest report on global warming at to learn of your children's warm global future. The next major el Niņo event will kill even more 1000-year-old brain corals than the last one did.

The Nazis were not very popular at Nurenberg for gassing 6 million people, but international capital and its investment in the polluting energy sector is demonstrably (according to reputable climate models) turning the entire planet into a slow-burn gas chamber, possibly leading to the gradual (i'd give it about 500 years on current trends) extermination of human civilisation through accelerating degradation of that vital "infrastructure" called the biosphere.

The extermination of 6 billion people would be a crime one thousand times greater than the Holocaust in terms of human lives, but even greater again by dragging all the other innocent species down with us. Furthermore, complete extermination of an otherwise sustainable steady state global population of say one billion people over the next 500 million years of potential habitability of the earth would be the loss of a potential ten million billion unique human lives (assuming only a 50 year average life span.) Where are the Catholic pro-life activists on this issue??

Off-peak power is analogous to the guards at Auschwitz chucking another cyanide capsule into the gas chamber. Marketing of cheap off peak tariffs means more transmission losses of the dirtiest coal or nuclear fission generated electricity: I can see no way to avoid this unfortunate conclusion.

Please do NOT be misled into thinking you are helping the environment by doing the economically "efficient" thing of buying cheap power at night. It is a major scandal that the purveyors of off peak power seem to have convinced the public that the thermal and economic efficiency of their baseload generators, viewed in isolation, is somehow a Good Thing for the national economy. If they are allowed to get away with it, they will either build more baseload coal, or start plugging nuclear fission power into the National Electricity Market.

Michael Gunter

Note 1. The formal written submission to the Joint Advisory Panel ended at the ruled line immediately above. The hypertext version presented above has had typographical errors corrected, and a couple of hypertext links added.

Note 2. Additional material is in the online version of my submission to the Senate Inquiry into Australia's response to global warming, at