Submission: NSW DCCEEW Re: Energy Security Safeguard Rule change

20 February 2026

To: NSW Department of Climate Change, Energy, the Environment and Water
Re: Energy Security Safeguard rule change
 

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the Energy Security Safeguard rule change consultation.

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

A significant focus of IEEFA’s work is examining the role of the demand-side in delivering a least-cost decarbonised energy system. We commend the government of New South Wales for undertaking this broad-reaching review of the Energy Security Safeguard, as this represents a significant opportunity to elevate the contribution of the demand-side to NSW’s energy future.

The first part of our submission presents several key opportunities to expand the Peak Demand Reduction Scheme (PDRS) – specifically around residential hot water, pre-heating and cooling, expanding access to solar and batteries, and thermal efficiency upgrades.

The second part provides more detailed comments in response to selected consultation questions.

We have also provided a submission to the concurrent Energy Security Safeguard policy reform consultation, with some overarching comments on the overall policy framework of the scheme.

Please do not hesitate to contact us if you have any queries regarding this submission.
 

Kind regards,

Jay Gordon, Energy Finance Analyst – Australian Electricity