However, we note that the movement in provisions can have an effect on the productivity of NSPs. To account for this we have added a table requesting detail on the movement in provisions. We will then use this data to make an assessment on whether an adjustment for provisions is required. In regards to margins we now explicitly note that margins are to be included in opex. This is consistent with the regulatory financial statements where we request that opex be reported inclusive of margins. Where regulatory financial statements request opex both inclusive and exclusive of margins we have clarified that opex is to be reported inclusive of margins. We received submissions that that data on opex for high voltage customers was not available. CitiPower and Powercor submitted that it was not provided with the information on the type of assets that are operated and maintained by directly connect end-users and there is no basis on which it can estimate another parties' opex. This issue of not having the data to estimate the high voltage customers variable as also raised in our bilateral discussions with the DNSPs. We have included instructions in the RIN that provides guidance on how a DNSP can estimate the opex for high voltage customers. This includes clarifying that the estimate only applies to the operations and maintenance costs associated with the transformer owned by the high voltage customer. We acknowledge DNSPs are unlikely to have data on this variable and the data will have to be estimated based on other sources of information such as comparable opex for similar assets or observed maximum demand. We note the issue of dual function assets included in ActewAGL's RAB is discussed in the Assets (RAB) section below. To be consistent with the inclusion of dual function assets in the RAB, it is also appropriate to include any opex associated with dual function assets. Ergon Energy noted that the definition of connection services may differ across jurisdictions. To ensure that the definition of connection services is consistent, we have adopted the definition of connection services in our connection guideline. Ergon Energy also noted that operating and maintaining connection assets would not be classified as a connection service under the RIN's definition. It is not our intention that the operation and maintenance of connection assets be classified as a connection service for the purposes of economic benchmarking. Instead we consider that this should form part of the network services. We have amended the definition of network services to clarify this.
However, we note that the movement in provisions can have an effect on the productivity of NSPs. To account for this we have added a table requesting detail on the movement in provisions. We will then use this data to make an assessment on whether an adjustment for provisions is required. In regards to margins we now explicitly note that margins are to be included in opex. This is consistent with the regulatory financial statements where we request that opex be reported inclusive of margins. Where regulatory financial statements request opex both inclusive and exclusive of margins we have clarified that opex is to be reported inclusive of margins. We received submissions that that data on opex for high voltage customers was not available. CitiPower and Powercor submitted that it was not provided with the information on the type of assets that are operated and maintained by directly connect end-users and there is no basis on which it can estimate another parties' opex. This issue of not having the data to estimate the high voltage customers variable as also raised in our bilateral discussions with the DNSPs. We have included instructions in the RIN that provides guidance on how a DNSP can estimate the opex for high voltage customers. This includes clarifying that the estimate only applies to the operations and maintenance costs associated with the transformer owned by the high voltage customer. We acknowledge DNSPs are unlikely to have data on this variable and the data will have to be estimated based on other sources of information such as comparable opex for similar assets or observed maximum demand. We note the issue of dual function assets included in ActewAGL's RAB is discussed in the Assets (RAB) section below. To be consistent with the inclusion of dual function assets in the RAB, it is also appropriate to include any opex associated with dual function assets. Ergon Energy noted that the definition of connection services may differ across jurisdictions. To ensure that the definition of connection services is consistent, we have adopted the definition of connection services in our connection guideline. Ergon Energy also noted that operating and maintaining connection assets would not be classified as a connection service under the RIN's definition. It is not our intention that the operation and maintenance of connection assets be classified as a connection service for the purposes of economic benchmarking. Instead we consider that this should form part of the network services. We have amended the definition of network services to clarify this.