PIAC responded to the Australian Energy Market Commission’s (AEMC) consultation on the rule change proposal to introduce metering coordinator planned interruptions.
We do not support the proposed rule change and strongly recommend the AEMC explore alternative measures within the existing regulatory framework to address the issues identified.
We agree meter exchanges and replacements should be undertaken within appropriate timeframes. However, we highlight that it is predictability and consistency of wait time, rather than the amount of wait time, that is the key consideration. This is particularly true where the potential benefits of a reduced wait time are limited and potentially outweighed by the resulting reductions in consumer information, protection and safety.
We consider any measures to improve the efficiency of exchanges must maintain clear lines of responsibility, avenues for dispute resolution, and minimise the need for additional regulatory complexity. We also highlight the likelihood that existing delays and issues with timing are not intrinsic to the current regulatory framework, but a result of poor co-ordination and communication practices by retailers, DNSPs and metering operators.
We outline our concerns with the AEMC’s proposed response, provide input on the assessment framework proposed in the consultation paper, and respond to questions from the consultation paper.