its obligations in section 110, it may recover reasonable expenses associated with vegetation management if the land-holder does not comply with its responsibilities pursuant to the notice: (6) If the land-holder does not carry out the activity in accordance with a requirement in the notice mentioned in subsection (3)(c)— (a) the utility may carry out the activity; and (b) the reasonable expenses thus incurred by the utility are a debt due to the utility by the land-holder. In the cost pass through final determination, we considered that ActewAGL's reactive approach to vegetation management was the reason it incurred additional costs in purported "urgent circumstances". Had ActewAGL used a more prudent and efficient pre-emptive strategy, it would have had ample time to adopt a considered and managed response to the greater than normal vegetation regrowth before the 2012–13 bushfire season. That is, a more prudent approach would have eliminated the need for the "urgent" work. In addition, statements in ActewAGL's regulatory proposal suggest it seeks to minimise reactive work in some instances because customers are more comfortable with planned outages than unplanned outages. In 2003, ActewAGL and ACTEW Corporation commissioned NERA and AC Nielson to conduct a study on customers' willingness to pay over a twelve month period. ActewAGL submits: The study found that customers were less concerned with planned (than unplanned) outages of a given duration, as long as they were given sufficient notice of that outage (two to seven days prior notice). ActewAGL goes on to state: ActewAGL Distribution has continued to undertake a relatively high proportion of planned (rather than reactive) maintenance on the network in recognition of this finding and the difficulties associated with accessing backyard reticulation to address unplanned outages. In our view, this suggests that if ActewAGL adopted a more proactive approach to vegetation management it should be able to minimise undertaking "urgent" work on private land. In such cases, uncooperative land holders would be responsible for the costs rather than ActewAGL's entire customer base. However, ActewAGL's current reactive practices seem to be resulting in ActewAGL unnecessarily incurring inefficient expenditure.
its obligations in section 110, it may recover reasonable expenses associated with vegetation management if the land-holder does not comply with its responsibilities pursuant to the notice: (6) If the land-holder does not carry out the activity in accordance with a requirement in the notice mentioned in subsection (3)(c)— (a) the utility may carry out the activity; and (b) the reasonable expenses thus incurred by the utility are a debt due to the utility by the land-holder. In the cost pass through final determination, we considered that ActewAGL's reactive approach to vegetation management was the reason it incurred additional costs in purported "urgent circumstances". Had ActewAGL used a more prudent and efficient pre-emptive strategy, it would have had ample time to adopt a considered and managed response to the greater than normal vegetation regrowth before the 2012–13 bushfire season. That is, a more prudent approach would have eliminated the need for the "urgent" work. In addition, statements in ActewAGL's regulatory proposal suggest it seeks to minimise reactive work in some instances because customers are more comfortable with planned outages than unplanned outages. In 2003, ActewAGL and ACTEW Corporation commissioned NERA and AC Nielson to conduct a study on customers' willingness to pay over a twelve month period. ActewAGL submits: The study found that customers were less concerned with planned (than unplanned) outages of a given duration, as long as they were given sufficient notice of that outage (two to seven days prior notice). ActewAGL goes on to state: ActewAGL Distribution has continued to undertake a relatively high proportion of planned (rather than reactive) maintenance on the network in recognition of this finding and the difficulties associated with accessing backyard reticulation to address unplanned outages. In our view, this suggests that if ActewAGL adopted a more proactive approach to vegetation management it should be able to minimise undertaking "urgent" work on private land. In such cases, uncooperative land holders would be responsible for the costs rather than ActewAGL's entire customer base. However, ActewAGL's current reactive practices seem to be resulting in ActewAGL unnecessarily incurring inefficient expenditure.
AER%20draft%20decision%20ActewAGL%20distribution%20determination%20-%20Attachment%2007%20-%20Opex%20-%20November%202014.DOCX