EUAA Submission: National Electricity Amendment (Including Distribution Network Resilience In The NEM) Rule
Emily Wood | March 27, 2025
‘… Thank you for the opportunity to make a further submission on the Victorian Energy Minister’s proposed resilience rule change. In our previous submission on the Consultation Paper, we argued that the long-term interests of consumers are best served by:
- Not including expenditure factors in the rules as proposed by the proponent, but
- Requiring a comprehensive binding AER Guideline, though substantially different in approach from the binding guideline proposed by the proponent
Our preferred approach would draw on the existing expenditure factors and other guidelines e.g. cost benefit analysis, to provide clear guidance to networks and their consumers on how to engage on, and build the business case for, resilience expenditure. Our concern was that the proposed rule change would lead to significant and unjustified costs for consumers without offsetting benefits with the potential for a repeat of the ‘gold plating’ resulting from tighter reliability standards.
It is important to remember that consumers will make trade-offs on resilience just as they do with reliability. While we have an initial estimate of the VNR, a significant amount of work still needs to be done to ensure this is a robust estimate of consumer preferences, including a robust estimate of willingness to pay. We look forward to further engagement on this…’
Please download attachment to read full submission.
