Points of principle Firstly, we have concerns the appropriateness of any further recovery” “cost (whether via the RAB or exit charges) for meters that may have been in place for many years and where, therefore, costs may have already been fully recovered through depreciation charges. Secondly, we would have concerns if there were to be any incentives on the networks to install new meters that may have an effect both on metering competition and on generating new costs to recover from consumers (whether via depreciation charges or exit fees). Meter types 5 and 6 Sub-panel 1 supports the AER’s classification of Types 5 and 6 metering services as control services” in the Stage 1 F&As for NSW and ACT (excluding metering “alternative installation services in NSW, which are unregulated). The sub-panel believes that the AER can take further action, which will facilitate the establishment of a competitive regime for advanced metering technology. Cost recovery of legacy metering investments To the extent that continued cost recovery by DNSPs of regulator approved legacy metering investments is deemed reasonable, we believe this cost recovery should have minimal distortionary effects on the emerging contestable market for smart meters. We remain concerned a trend towards significant investment by ActewAGL in type 5 meters that could result in ActewAGL charging significant exit charges for the next regulatory period, as a minimum. The imposition of exit fees to provide for cost recovery of these metering assets would be detrimental to the emerging contestable market in smart meters and therefore, against the long term consumer interest. AS an example, the exit fee for CT meters in South Australia has been reported to be a significant barrier to the emerging market in advanced metering technology. In consideration of exit fees, the Standing Council on Energy and Resources (SCER) has proposed in its Competition in Metering and Related Services Rule Change Proposal Consultation Paper that an exit fee should be based on the average depreciated value of the stock of the distribution business's existing accumulation and manually read interval meters. We are opposed to exit fees for accumulation and manually read interval meters and believe that exit fees are a significant barrier to consumers moving to adopt advanced metering technology. Legacy metering assets replaced during the Victorian AMI program were treated as follows: For metering assets installed from 01 January 2006, including accumulation meters and manually read interval meters, assets were reflected on the newly established Metering Asset Base, and the depreciation of these assets was
Points of principle Firstly, we have concerns the appropriateness of any further “cost recovery” (whether via the RAB or exit charges) for meters that may have been in place for many years and where, therefore, costs may have already been fully recovered through depreciation charges. Secondly, we would have concerns if there were to be any incentives on the networks to install new meters that may have an effect both on metering competition and on generating new costs to recover from consumers (whether via depreciation charges or exit fees). Meter types 5 and 6 Sub-panel 1 supports the AER’s classification of Types 5 and 6 metering services as “alternative control services” in the Stage 1 F&As for NSW and ACT (excluding metering installation services in NSW, which are unregulated). The sub-panel believes that the AER can take further action, which will facilitate the establishment of a competitive regime for advanced metering technology. Cost recovery of legacy metering investments To the extent that continued cost recovery by DNSPs of regulator approved legacy metering investments is deemed reasonable, we believe this cost recovery should have minimal distortionary effects on the emerging contestable market for smart meters. We remain concerned a trend towards significant investment by ActewAGL in type 5 meters that could result in ActewAGL charging significant exit charges for the next regulatory period, as a minimum. The imposition of exit fees to provide for cost recovery of these metering assets would be detrimental to the emerging contestable market in smart meters and therefore, against the long term consumer interest. AS an example, the exit fee for CT meters in South Australia has been reported to be a significant barrier to the emerging market in advanced metering technology. In consideration of exit fees, the Standing Council on Energy and Resources (SCER) has proposed in its Competition in Metering and Related Services Rule Change Proposal Consultation Paper that an exit fee should be based on the average depreciated value of the stock of the distribution business's existing accumulation and manually read interval meters. We are opposed to exit fees for accumulation and manually read interval meters and believe that exit fees are a significant barrier to consumers moving to adopt advanced metering technology. Legacy metering assets replaced during the Victorian AMI program were treated as follows: For metering assets installed from 01 January 2006, including accumulation meters and manually read interval meters, assets were reflected on the newly established Metering Asset Base, and the depreciation of these assets was
Consumer%20Challenge%20Panel%20-%20sub%20panel%201%20-%20submission%20on%20ActewAGL%20regulatory%20proposal%20-%20August%202014_0.docx