We appreciate the opportunity to comment on the Australian Energy Regulator (AER)’s draft Export Tariff Guidelines. Our submission on the AER’s earlier consultation paper outlined our expectations as to what work would be undertaken by electricity networks before proposing export tariffs. Our expectations were predicated on the view that in principle, export tariffs should be rare, observable, and effective:
- Rare: Relatively few consumers will pay export tariffs due to networks setting export limits that reflect the right of consumers to host sufficient solar to meet their needs
- Observable: Export tariffs are seen by consumers as they are incorporated into retail prices by retailers
- Effective: Export tariffs achieve the desired behaviour change when seen by consumers
This view has not changed. We have two recommendations that we would like to see incorporated in the Final Determination.
- The Guidelines should clarify that network engagement with retailers should occur while the tariffs are being considered rather than after they have been created.
- The Guidelines should make it clear that extensive analysis considering multiple factors should be undertaken to justify the inclusion of export tariffs within a Tariff Structures Statement.
These recommendations are described in more detail in our submission here.