EUAA Submission: Amending the Administered Price Cap
Emily Wood | September 1, 2022
‘…The EUAA has previously made a submission requesting that the AEMC not expedite the process under s96 of the NEL[1]. We proposed that the rule change should be considered under the normal two stage review process. In the absence of a Commission decision on our earlier submission, we provide this submission on the basis that the process will be expedited.
In our earlier submission, we argued that it was appropriate to review the APC to see if it was still ‘fit for purpose’ but that the expedited process was unable to properly answer the question Alinta posed in their rule change of whether the ‘trade-offs …are sufficiently balanced to meet the long-term interests of consumers’ (p.5).
We are being asked to express a view on a major policy change that could have potentially large impacts on consumers on the basis of very high level modelling in the Consultation Paper and a ‘qualitative judgement’ or intuition. The Consultation Paper agreed that ‘further analysis’ is required (p.14). The AEMC reported to the Forum on 17th August on progress with that modelling, encouraging stakeholders to engage with the Commission. But, in the absence of details being provided by the Commission, that is difficult to comment on. It would be a very disappointing outcome for consumers were the final expedited decision to contain additional modelling to justify the Commission’s decision…’
Please download attached to read full submission.
