As the AER rightfully acknowledges, the current market has only amplified the significance of the DMO as a tool to protect consumers from unreasonably high prices. For this reason we are pleased to see the AER highlighting potential changes in approach which could see the DMO best fulfil this function, in the current environment.

In our response to the Issues Paper we submit that:

• the AER should prioritise transparency, stability, and certainty for consumers in its calculation of wholesale costs for the next DMO (DMO 5);
• the retail allowance of 10% for residential and 15% for small business set in the last DMO (DMO 4) is unjustifiably high, especially given expected increases to the overall DMO cost-stack;
• there should be no difference in retail allowance for residential and small business; and
• embedded networks served by authorised retailers should be covered by DMO protections with safeguards against double-charging of network costs.

Read our full submission here