We appreciate the opportunity to respond to the Australian Energy Regulator’s (AER) draft Regulatory Investment Test (RIT) guideline (Guideline) for both transmission (RIT-T) and distribution (RIT-D). Energy Consumers Australia supports the direction of the proposed changes to the Guideline to strengthen the RIT as an important ‘consumer test’ at a time when affordability is the number one priority for consumers.

Energy consumers want comfortable homes, competitive businesses and bills that don’t make them so anxious that they put off opening them. The latest Energy Consumer Sentiment Survey indicates that in terms of value for money, households and small businesses rate electricity services behind internet, mobile phone, insurance, banking and water services. At the same time, satisfaction with levels of reliability are much higher than they are in relation to price.^[1]Energy Consumer Sentiment Survey: June 2018

With prices at unprecedented levels, and a recent history of over-investment in networks, affordability cannot merely be aspiration of the regulatory framework: affordability must be an explicit criterion in decision-making processes. In this submission we explain why the RIT acts as this strong consumer test and comment on aspects of the updated methodology drawing on insights from our involvement in recent transmission projects.

The full submission can be read here.