Recommend clause 4.6.4(a) (ENO may not levy charges that not be charged by local area distributor under a standard contract) be amended to clarify if it is: intended to limit the nature of the charges (similar to the limitation to charges which apply in normal circumstances in clause 4.6.1.1 for which the supporting schedule has been provided); and not intended to limit an ENO recovering internal network changes (if permitted under clause 4.6.3 and Charge Group C). Caravan & Fees, charges and Transaction Costs Fees, charges and Transaction Costs Camping Industry Support proposed amendments to section 4.6 including in relation to late on this submission and similar submissions Association of payments and manual reading charges. However, state based from the Energy and Water Ombudsman, NSW, the NSW legislation specific to the caravan park industry restricts what caravan Caravan Parks Association of QLD and the Residential Tenancies Authority, Qld, we accept park operators can charge. that class NR4 should be allowed to defer the Metering types and access arrangements appoint of an ENM. Also, the provisions for The requirements for all new metering installations and to any of an ENM should apply to long-term reconfiguration of an existing metering installation within an EN are residents of these sites. By imposing a requirement generally reasonable but recommend clarifying: for a delay of 40 business days in clause 4.7 we expect transient residents will not be able to trigger clause 4.2 to make explicit ENO does not pay for meter upgrade a requirement to appoint an ENM and, if they were if retailer or on/market customer replaces meter to do so, it would be at their own cost. clause 4.2.2.1 to make applicable to new and replacement External dispute resolution meters We have amended our dispute resolution clause 4.2.2.3 to make explicit that a purchase or lease of an requirements to recognise commercial and/or existing meter is negotiated by both parties residential tribunals may exist and be available to The prohibition on measures which impede competition should be address disputes. We also have created a redrafted to ensure it is not retrospective. discretion for the energy ombudsman to determine
Recommend clause 4.6.4(a) (ENO may not levy charges that not be charged by local area distributor under a standard contract) be amended to clarify if it is: intended to limit the nature of the charges (similar to the limitation to charges which apply in normal circumstances in clause 4.6.1.1 for which the supporting schedule has been provided); and not intended to limit an ENO recovering internal network changes (if permitted under clause 4.6.3 and Charge Group C). Caravan & Camping Industry Association of NSW Fees, charges and Transaction Costs Support proposed amendments to section 4.6 including in relation to late payments and manual reading charges. However, state based legislation specific to the caravan park industry restricts what caravan park operators can charge. Metering types and access arrangements The requirements for all new metering installations and to any reconfiguration of an existing metering installation within an EN are generally reasonable but recommend clarifying: clause 4.2 to make explicit ENO does not pay for meter upgrade if retailer or on/market customer replaces meter clause 4.2.2.1 to make applicable to new and replacement meters clause 4.2.2.3 to make explicit that a purchase or lease of an existing meter is negotiated by both parties The prohibition on measures which impede competition should be redrafted to ensure it is not retrospective. Fees, charges and Transaction Costs on this submission and similar submissions from the Energy and Water Ombudsman, NSW, the Caravan Parks Association of QLD and the Residential Tenancies Authority, Qld, we accept that class NR4 should be allowed to defer the appoint of an ENM. Also, the provisions for of an ENM should apply to long-term residents of these sites. By imposing a requirement for a delay of 40 business days in clause 4.7 we expect transient residents will not be able to trigger a requirement to appoint an ENM and, if they were to do so, it would be at their own cost. External dispute resolution We have amended our dispute resolution requirements to recognise commercial and/or residential tribunals may exist and be available to address disputes. We also have created a discretion for the energy ombudsman to determine
AER%20Reasons%20for%20Decision%20-%20Amended%20Network%20Exemption%20Guideline%20-%20Version%205%20-%201%20December%202016.docx