Confusion around unbundled tariffing between individual rights and the best interests of the whole community. Disconnection for non-payment to either party We agree that if competition works well under this Effective and unambiguous treatment of in independent rule change, the need for many conditions may dispute resolution change. We will monitor industry outcomes and revise the guideline based on that experience. B2B procedures should be introduced to best replicate which exist in the contestable market where practical. This would address many We agree with other submissions that condition issues noted above. 4.1.12(e) should not apply to network upgrades. We have amended the condition accordingly. Potential disconnect between the procedures proposed by AER, the However, we do not agree it can be deleted. It is a drafting in the EN Rule Change and the market design proposed by fundamental protection for customers with an AEMO. The rule allows ENO access to meter data but it is difficult to existing direct connection. understand how when ENO will not have access to MSATS and MMS systems. It is not clear that the Rules allow for direct access to child data via the ENM. Network conversions Sympathetic to motivation behind supplementary conditions on network conversions but proposals are overly prescriptive. Additional conditions are not relevant if competition is facilitated through the ENM. AER and AEMO should work together to make competition so seamless that such conditions as matching are not required. Clause 4.1.12(e) is problematic and creates a duty of care inside an EN not existent elsewhere across NEM. Clause 4.1.12(e) should be omitted along with new clause 4.9 which appears to have been included to address the deficiencies of clause 4.1.12(e). Energy Fees, charges and transaction Fees, charges and transaction costs Support the proposal for meter charges Our position is that the ENM fee must be absorbed by the exempt embedded network service provider. Some fees need to be passed on to the customer, such as ENM fees, We only allow the ENM fee to be passed on in which could be a flat fee included in each customer’s regular bill. limited circumstances. We do not agree ENM fees
Confusion around unbundled tariffing Disconnection for non-payment to either party Effective and unambiguous treatment of in independent dispute resolution B2B procedures should be introduced to best replicate which exist in the contestable market where practical. This would address many issues noted above. Potential disconnect between the procedures proposed by AER, the drafting in the EN Rule Change and the market design proposed by AEMO. The rule allows ENO access to meter data but it is difficult to understand how when ENO will not have access to MSATS and MMS systems. It is not clear that the Rules allow for direct access to child data via the ENM. Network conversions Sympathetic to motivation behind supplementary conditions on network conversions but proposals are overly prescriptive. Additional conditions are not relevant if competition is facilitated through the ENM. AER and AEMO should work together to make competition so seamless that such conditions as matching are not required. Clause 4.1.12(e) is problematic and creates a duty of care inside an EN not existent elsewhere across NEM. Clause 4.1.12(e) should be omitted along with new clause 4.9 which appears to have been included to address the deficiencies of clause 4.1.12(e). between individual rights and the best interests of the whole community. We agree that if competition works well under this rule change, the need for many conditions may change. We will monitor industry outcomes and revise the guideline based on that experience. We agree with other submissions that condition 4.1.12(e) should not apply to network upgrades. We have amended the condition accordingly. However, we do not agree it can be deleted. It is a fundamental protection for customers with an existing direct connection. Energy Fees, charges and transaction Support the proposal for meter charges Some fees need to be passed on to the customer, such as ENM fees, which could be a flat fee included in each customer’s regular bill. Fees, charges and transaction costs Our position is that the ENM fee must be absorbed by the exempt embedded network service provider. We only allow the ENM fee to be passed on in limited circumstances. We do not agree ENM fees
AER%20Reasons%20for%20Decision%20-%20Amended%20Network%20Exemption%20Guideline%20-%20Version%205%20-%201%20December%202016.docx