We appreciate the opportunity to comment on the National Electricity Amendment (Establishing values of customer reliability) Rule 2018 (the Rule). This letter sets out our comments on the proposal and addresses a number of the questions posed in the Consultation Paper (the Paper).

This rule change request from the COAG Energy Council (the Energy Council) would make the Australian Energy Regulator (AER) responsible for calculating and updating values of customer reliability. These values are used to develop reliability standards and settings for both transmission and distribution networks, and wholesale markets.

The value of customer reliability is a measure that has long played a role within the incentives framework and investment tests for electricity networks, but whose importance has to date been limited by insufficient attention being paid to robust and regular estimation.

At a time when electricity prices being paid by consumers are at historical highs, it is critical that not one more dollar is invested by electricity networks, one day earlier than necessary, to meet the communitys expectations of reliability.

In this context we support the Energy Councils proposed Rule to require the AER to assume responsibility for establishing values of customer reliability (VCR), to establish a formal mechanism for the AER to develop a methodology for the calculation of VCRs, and to update and review VCRs on an ongoing basis.

Energy Consumers Australia supports the rule change request being treated as noncontroversial in accordance with s. 96 of the NEL and being processed on an expedited basis.

The full submission can be read here.