Despite its name, function, and intent, our understanding is that during the market disfunction in June 2022, the Administered Price Cap did not actually cap or reduce prices. As a result, this letter, representing our submission on this rule change, makes three primary points.

• We support the proposed rule change to temporarily increase the APC because doing so reduces the likelihood of another suspension of the energy market, which would increase costs on consumers. It is a temporary, low-risk option.
• The current process for reviewing the APC has failed to achieve the right outcome for the market and consumers. The Australian Energy Market Commission (AEMC) should determine a better approach to review and more dynamically update the APC and other market mechanisms intended to protect consumers and the system. In this context we note that the Reliability Panel itself has reflected on the June events, in its advice to the AEMC in the 2022 Review of Reliability Standard and Settings (the Report) which only became publicly available on 1 September 2022 (the deadline for submissions on the proposed rule change).1
• The AEMC and AEMO need more information to appropriately regulate and operate the market and should be supporting the Commonwealth’s consultation on increasing the Australian Energy Regulator’s (AER) market monitoring authority.

Read the complete submission to see the reasoning behind each of the above points and how we see the next steps to be