AGL recently responded to the Australian Energy Market Commission’s (AEMC) draft determination on life support registration for customers.
The AEMC draft determination offers a more preferred rule change to that requested by the initial rule proponents. The AEMC state in the draft determination that the reason for not pursuing the proponents recommended rule change was that there is limited evidence around the extent of the issue, and the Commission considers that the cost of the proposed solution would likely outweigh the benefits. We agree with AEMC that the initial rule change represented higher costs than benefits to the market due to the lack of evidence.
Based on this position, we therefore question whether the AEMC preferred rule change appropriately demonstrates a greater benefit than cost given the absence of evidence. Further, the AEMC proposes less than a week for retailers to implement following a final determination. We note a range of activities that retailers would need to undertake to ensure compliance that cannot be completed within this timeframe. We recommend a 1 August 2021 start date to ensure that systems and processes can appropriately be implemented should the rule change proceed.
Our full submission can be accessed here.