Part A Pricing, Demand Management and Customer Billing ... · chapter 6 of the National Electricity...

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Smart Meter Consumer Protection and Safety Review Draft Policy Paper Two Response Template Part A Pricing, Demand Management and Customer Billing

Organisation/Name: ENERGEX Limited Contact Details: GPO Box 1461, Brisbane, Qld 4001 SECTION 2: New Pricing arrangements General comments

Please insert general comments on Section 2 here

Question 2.1

Setting network tariff 2.1. Are there any changes required to the rules and regulation including the relevant sections of the distribution pricing rules in chapter 6 of the National Electricity Rules as a result of the potential new pricing arrangements enabled by smart meters?

2.1 ENERGEX notes that this issue is being considered in the Demand Side Participation (DSP) review. ENERGEX believes proposing changes to current Chapter 6 National Electricity Rules (Rules) as a result of the new pricing arrangements enabled by smart meters is both premature and unnecessary. Clause 6.18.5 of the Rules sets out the pricing principles for Distribution Network Service Providers (DNSP). These require the DNSP to take into account the long run marginal cost of service, have regard to the transaction costs associated with the tariff and whether customers are able or likely to respond to price signals. ENERGEX considers these pricing principles are sufficiently flexible to accommodate potential new pricing arrangements enabled by smart meters such as TOU pricing. ENERGEX is currently in the process of introducing a residential TOU tariff. This tariff will be a three part tariff consisting of peak, off-peak and shoulder periods designed in accordance with Chapter 6 of the Rules.

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Question 2.2

Retail tariffs 2.2. How can effective choice of tariffs for consumers be facilitated given likely network pricing behaviour and retail pressures?

2.2 In Queensland, small customers currently have the choice of either regulated retail (notified) tariffs or a market tariff. Regulated retail tariffs in Queensland are currently under review by the Queensland Competition Authority (QCA). From 1 July 2012 the regulated retail tariffs in Queensland will require the network component of the regulated tariffs to be directly passed on to the customer by the retailers (N+R pricing methodology) Market tariffs in Queensland are typically based on the regulated tariffs with percentage discounts applied. However, retailers are also able to offer an alternative market tariff structure which does not align with the network tariff. Competition among retailers and the availability of market tariffs provides customers with more choice of tariffs.

Draft Policy Positions 1, 2 and 3

Critical peak price tariff and critical peak rebates 1. Critical peak price tariffs can be set by both distributors and

retailers, but only offered by retailers. 2. Critical peak rebates can be offered by retailers or

distributors. 3. Critical peak pricing tariffs and critical peak rebates must be

offered as a voluntary product and only established with a consumer’s explicit informed consent.

ENERGEX agrees with these positions. ENERGEX currently applies a number of pricing principles when formulating new tariffs. These include price signals to encourage efficient use of the network, simplicity and cost reflectivity. The cost of implementation and the customer’s ability to understand and respond to price signals should be taken into account when reviewing these options further.

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Questions 2.3, 2.4, and 2.5

Critical peak price 2.3. What supporting arrangements might be put in place to help consumers gain a better understanding of and benefit from CPP tariffs? 2.4a. Should minimum terms and conditions be specified for CPP contracts? 2.4b. If so what specific issues might be covered? 2.5. Should there be protocol on how a distributor can offer a CPR and a retailer CPP or CPR offers to the same consumer?

2.3 Educating customers and transparency are important if customers are to understand and realise the benefits from CPP tariffs. Customers need to be fully informed prior to signing up for CPP tariffs. Customer awareness campaigns will be a critical element of introducing any new tariff options. This should include suggested ways customers can manage their usage to minimise their electricity bills. CPP contracts could include easy to comprehend worked examples that depict the impact of a CPP event on the customer’s bill. 2.4 ENERGEX believes minimum terms and conditions should be specified including notification method and timing, maximum duration, maximum occurrence etc. 2.5 Yes there must be protocols on the distributor and retailer where a customer is subject to CPR from a distributor and CPP or CPR from a Retailer. The protocols must be transparent and easy for the customer to understand.

Question 2.6

Locational network pricing 2.6. What alternatives to tariff-based incentives might be facilitated through smart metering in order to manage locational network issues?

2.6 Direct load control (DLC) and supply capacity control (SCC) could be used as alternatives to tariff- based incentives. Locational issues would be best managed through targeted demand management or reduction products offered by distributors outside the regulated tariffs.

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Question 2.7

Load control tariffs 2.7. How can the issue of consumers who lose access to dedicated circuit off peak rates be addressed?

2.7 Currently in South-East Queensland, ENERGEX’s position is to allow customers access to controlled load tariffs providing the load they wish to connect meets with the technical requirements of the tariff e.g. ramp on /off rates etc. In addition to controlled load tariffs customers in Queensland will also have the option to move to a TOU tariff which offers off-peak rates (comparable to the controlled load tariffs) to customers who can move their consumption into the off-peak period.

Question 2.8

Consumer choice of tariffs 2.8a. Should all retailers be required to offer a range of retail tariff options to customers including flat tariffs? 2.8b. If retailers are required to provide a range of tariff options to customers does this also mean that networks should also offer a range of network tariffs for retailers? 2.8c. Should these arrangements, if adopted, be transitional? If so, what conditions need to be satisfied before the arrangements can be reconsidered?

2.8a Retailers should not be necessarily ‘required’ to offer a range of tariff options. Retailers should be allowed to offer retail tariff options which they consider best meet their market requirements and customer expectations. Ideally competition in the retail market should ensure that a suite of tariff options are available for consumers. 2.8b Network business should provide retailers with cost reflective tariffs based on network cost drivers. These do not necessarily have to match every retail tariff offered by retailers 2.8c If a flat tariff is mandated then the requirement should be transitional. However, it should be noted that from 1 July 2012 residential customers in Queensland will no longer have access to a flat rate regulated retail tariff. The default residential tariff will be an Inclining Block Tariff (IBT) with customers having the option to move onto a voluntary TOU tariff. ENERGEX believes that flat tariff offerings contradict the need for TOU interval metering and are not consistent with demand side participation targets or expectations.

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Question 2.9

Transfers without penalty 2.9a. Should there be a transitional period which allows consumers to move between contracts without penalty? 2.9b. If so, what conditions need to be satisfied before the arrangements can be reconsidered?

2.9a No Comment. In South-East Queensland, ENERGEX allows customers to change tariff once per annum. Following the introduction of the voluntary residential TOU tariff, customers will be able to revert back to an IBT once in the first 12 months without penalty. This is considered to be reasonably flexible given the administrative cost of tariff changes.

Questions 2.10, 2.11

Supporting informed choice for consumers 2.10. What arrangements need to be put in place to reduce complexity for consumers and assist them to understand the different offers in the market? 2.11a. Does there need to be monitoring of new pricing arrangements to ensure that complexity does not impede the realisation of demand response and consumer benefits? 2.11b. Should the AER undertake such monitoring?

2.10 ENERGEX believes transparency is critical when introducing new pricing arrangements. Customer awareness campaigns will be an integral part of introducing new tariff structures. This could be supplemented by independent websites explaining the different tariff options as well as illustrations of the impact of the different tariffs on different household types and easy to understand suggestions on how customers can manage their usage to reduce their electricity bills. 2.11 Regulators should ensure that customers are not being offered opaque tariff structures. Customers must be offered the best opportunity to understand what contractual arrangements they are entering if the demand response is to be realised. Currently, in accordance with the Rules, ENERGEX must consider tariffs which take into account where customers are likely to respond to price signals. The AER assesses the annual Pricing Proposal for compliance with the Rules.

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Question 2.12

General Transitional Arrangements 2.12. Are there any other transitional arrangements that would help consumers adjust to new pricing arrangements?

2.12 Transitional arrangements are only required for mandatory tariff changes. Customer awareness campaigns will be a critical element of introducing any new tariff options. Customers must be able to request historical meter data through their retailer to assist them in making informed choices regarding the appropriate tariff options.

Question 2.13

Permanent flat tariff for vulnerable consumers 2.13a. Should a flat tariff option be available for vulnerable consumers on a permanent basis? 2.13b. Should that option be required for both standing offers and market offers?

Distributors should not be constrained in their ability to develop cost reflective tariffs that are consistent with the pricing principles in the Rules. ENERGEX notes that there appears to be a crossover of social policy and economic efficiency objectives. This may not be consistent with the overall national electricity objective. Given the regulatory arrangements, social policy objectives are better managed through federal and jurisdictional support schemes and arrangements.

Draft Policy Position 4

Hardship provisions 4. The AER should monitor whether hardship consumers are overrepresented on any particular tariff type.

No comment.

Question 2.14

Appropriate tariffs to hardship consumers 2.14. Should retailers be obliged to recommend the most appropriate tariff to consumers in their hardship program?

No comment.

SECTION 3: Third Party Service Providers General comments

Please insert general comments on Section 3 in here

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Question 3.1

Issues for third parties in market 3.1. Are there further issues to those outlined above that need to be considered for third parties who are not agents of the distributors or retailers?

3.1 ENERGEX believes the issues outlined in relation to third parties are fairly comprehensive. These include: Third party compliance with security and privacy

requirements; access to systems and processes that enable linking to

the consumer’s equipment through the smart meter; third party accreditation; authorisation and customer consent; facilitation by current market participants; dispute management; non-compliance and enforcement; potential material risks to retailers and distributors


Third parties service providers 5. EMRWG considers, except for the case of the provision of customer’s data, that there are important issues to be resolved in providing for third parties in the market framework and systematic consideration should be given to these issues in the overall development of market arrangements for the delivery of smart meter services to consumers.

ENERGEX agrees with this position

Questions 3.2 and 3.3

Third party services 3.2 What services - other than those listed above - could be made available by third parties though a customer’s smart meter? 3.3 What controls should apply to third parties in relation to such service offerings?

3.2 Direct load control (DLC), Supply Capacity Control (SCC) 3.3 The same controls and obligations applicable to retailers and distributors must be applied to third parties. Nevertheless the operations of the third party should not interfere with or take precedence over the operations of the Retailer or Distributor. In emergency situations as well as for safety and network security purposes distributors’ operations should take precedence over the activities of other participants. Obligations must be legally enforceable on all participants.

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SECTION 4: Demand Management - Supply Capacity Control General comments



SCC as a mandatory function for network emergencies 6. Distributor-initiated SCC will be allowed for emergencies to manage network demand.

ENERGEX agrees with this position.


SCC as a discretionary distribution product 7. Distributors should be allowed to offer SCC as a discretionary product to manage network demand, subject to the appropriate consumer protections being in place.


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Questions 4.1, 4.2 and 4.3

SCC as a discretionary distribution product 4.1 Are the existing planned interruptions of supply rules sufficient to protect customers if SCC was offered as a product by distributors? 4.2. How ready are the distribution businesses to offer these products to consumers? 4.3a What additional consumer protections, including marketing requirements, should be placed on distributors in offering these products to consumers? 4.3b. What information should be provided to consumers with these products, and who should be responsible for providing it?

4.1 ENERGEX believes the planned interruptions of supply Rules under NECF are sufficient to protect customers. Applying capacity limits in place of total disconnection is a better outcome for customers. As part of the notification process, additional information would be provided to customers to assist them in understanding how capacity limits work. ENERGEX believes that customers should not be provided with an option to override the capacity limits because of the uncertainty it creates. This is detrimental to the management of the network. 4.2 ENERGEX is investigating opportunities to offer SCC to customers however does not anticipate being able to offer these products in the short term. 4.3a Distribution businesses are regulated monopolies, governed by regulatory arrangements. They do not operate in a competitive environment where they are competing to acquire and retain customers. The use of SCC by distributors will be primarily for load management purposes. Consequently, ENERGEX believes that additional regulation on distributors is neither required nor necessary. Customers are protected by general consumer law. 4.3b Information that helps customers understand what SCC is and how it works as well as the duration in which capacity limits would be in place. This information would be provided by the distributors.

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SCC as a discretionary ret ail product 8. For avoidance of doubt, SCC may not be used as an alternative to disconnection action and may not be offered to any customers entering or participating in a hardship program.

No Comment.

Question 4.4

SCC as a discretionary retail product 4.4a In what circumstances might consumers benefit from SCC as a discretionary retail product? 4.4b How ready is the market to offer these products? 4.4c What consumer protections should apply if these retail products were offered? 4.4d How could the risk of ensuring that these products are not offered, or accepted, by consumers as a means of avoiding de-energisation or mitigating financial hardship be managed?

No Comment.

Policy Position 9

Third parties and discretionary SCC 9. EMRWG considers that at least the same controls as apply to retailers and distributors should apply to third parties regarding any offer of SCC to consumers as a discretionary product.


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Question 4.5

SCC and embedded generation 4.5a Under what circumstances could export supply capacity control be used? 4.5b Should energy exported to the grid be subject to a supply capacity limit? 4.5c. If so, how should this limit be set?

4.5a Export supply capacity control could be useful for network management purposes as well as in emergency situations e.g where there are voltage issues. Currently where a customer is granted permission to export energy to the grid, the distributor generally specifies a ‘maximum feed-in’ limit that is based on network technical conditions, such as maximum allowable voltage rise. In almost all cases, the maximum feed-in limit is the output rating of the inverter. SCC could allow customers to have an inverter as large as they wish whilst ensuring that no more than the maximum allowable is exported. However, ENERGEX notes that this might not be technically feasible with the current inverter technology. Inverters are not currently configured with that type of control input. 4.5b Yes, as mentioned above a limit is applied now and is ‘enforced’ by specifying that the generator capacity is not greater than the allowable feed-in. The limit is enforced to ensure security and safety of the network is not compromised. 4.5c Where it is possible to set dynamic limits through the smart meter, these limits should be set at the discretion of distributors. The distributor has to take into account the technical requirements of their particular network in setting the limit.

SECTION 5: Demand Management - Direct Load Control

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General comments


Draft Policy Position 10 and 11

Offers of DLC 10. Distributors, retailers may offer DLC products and services to consumers. 11. In principle, third parties may also offer DLC products and services to consumers.

ENERGEX agrees with these positions.

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Question 5.1

Third party offers of DLC 5.1a What issues arise for third parties who are not agents of the distributors or retailers in providing DLC products to consumers for energy management purposes? 5.1b. Are consumers sufficiently protected by these third parties’ compliance with the general consumer law or should consideration be given to incorporating these functions in the energy Rules?

5.1a Third parties must comply with the same rules as distributors and retailers offering the same discretionary product. ENERGEX notes that depending on the volume of the load being managed, third parties activities could result in adverse impacts on the network such as power quality issues including voltage dips or even outages. Distributors should have ability to override the activities of third parties in emergency situations Currently the distribution business is responsible for guaranteed service level (GSL) payments to customers when service levels are breached. Given that load control can create network abnormalities, the responsible party for GSLs needs to be reconsidered. ENERGEX believes that the rules associated with the provision of load control services should incorporate provisions to ensure the integrity of the distribution network, as well as changes to the GSL arrangements for third parties and retailers. Examples of items that ENERGEX currently assesses in using of load control include: Ramp on rates Ramp off rates Firmness and diversity factors Randomisation Frequency rates for provision of services Availability Planned outages

These could be included in the operating protocols for all parties. 5.1b ENERGEX believes it is not necessary to duplicate general consumer laws in energy laws.

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DLC contractual arrangements 12. To access DLC customers will be required to enter into separate contracts with the distributor and/or retailer, and must give explicit informed consent to those contracts. 13. For a transitional period, DLC contracts would have a maximum length of 24 months and during the transitional period, customers will have the right to exit the contract without penalty. 14. In the longer-term, these contracts may contain a cost that the customer incurs for early termination of the contract. This must be clearly stated and reflective of the true cost to the business of this early cessation of the contract.

ENERGEX agrees with these positions. However, during the transitional period, there should be a limit to the number of times an individual customer can enter and exit a DLC contract without penalty.

Questions 5.2

DLC contractual arrangements 5.2a. Are there any unintended consequences of enabling consumers to enter into DLC contracts with one or more parties? 5.2b. What conditions need to be satisfied before the transitional arrangements (if any) can be reconsidered? 5.2c. What additional consumer protections, including marketing requirements, should be placed on distributors in offering these products to their customers?

5.2a Potentially this could lead to confusion and added complexity for customers when dealing with a number of different service providers especially in a dispute. 5.2b Any transitional arrangements should be for a defined set period. Beyond that period general consumer laws will protect customers. 5.2c As previously stated ENERGEX believes there is no requirement for additional regulation on distributors.


Contractual arrangements on moving premises 15. DLC contracts will terminate when a consumer moves house, unless otherwise agreed with the customer. Terms and conditions must be clearly stated in the contract.

ENERGEX agrees with this position. This should be stipulated and agreed in the contract

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Questions 5.3

DLC and explicit informed consent 5.3a Are there additional steps to those in the NECF and ACL which should be taken by parties offering DLC to ensure that explicit informed consent is obtained? 5.3b. Should guidelines be produced to assist parties to obtain this consent? 5.3c. Who should develop and monitor these guidelines?

5.3a The NECF as well as the ACL are sufficient for the purposes of ensuring that explicit informed consent is obtained from customers. 5.3b&c The existing NECF requirements are suffice.


DLC and customer exclusions 16. Appropriate provisions would be incorporated into the NECF to ensure that DLC services would not be offered to customers registered with medical life support requirements. 17. No customer will be required to involuntary place any appliance on DLC, including as a condition of participation in a hardship program. 18. Retailers must demonstrate that, if customers on a hardship program have agreed to a DLC service, this service is co�ordinated with all other assistance provided to customers.

ENERGEX agrees with these positions

Question 5.4

DLC and exclusions 5.4. Are there any groups who should not be offered DLC services?

5.4 ENERGEX believes that as long as the potential controlled load meets specific technical requirements, certain groups of consumers should not be entirely excluded from DLC. Customer choice should be promoted and emphasis placed on offering these products to fully informed customers especially if they stand to benefit from lower energy bills.

Question 5.5

Notification of load control 5.5. Should customers be informed when load control is activated?

5.5 If customers are fully informed at the time of entering the DLC contract and are not adversely affected when load control is activated, the extra burden/cost on the DLC provider to notify customers when load control is activated is not required.

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Question 5.6

DLC and manual override 5.6. As the manual override of some DLC services may produce adverse consequences for consumers, including reduced financial benefits, is it a service which should be offered in a contract?

5.6 The manual override capability may defeat the purpose of offering DLC especially to the distributors who would be utilising DLC to manage peak demand and defer network augmentations. If the DLC cannot be guaranteed then the distributor cannot rely on this as a method of managing peak demand and deferring investment and the compensation to the customer should reflects this

SECTION 6: Customer Billing General Comments


Draft policy position 19

Accumulated readings on the bill 19. In accordance with the requirements of the National Energy Retail Rules, the bill should contain an accumulated total for the start and end reads derived from the smart meter.

No Comment.


Time based tariffs 20. All TOU retail tariffs should be published as applying on the local time, rather than AEST and this should be clearly specified in the tariff information.

No Comment.


Notification of estimates/substitutes on customers’ bills 21. In advising customers that a bill contains estimated and/or substituted data, retailers are to describe the data as ‘estimated’ in all circumstances.

No Comment.

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Notification to customers of estimations 6.1. What are the costs and benefits of: a) using a threshold approach? b) showing the scope of any estimations on the bill? 6.2a. Should a threshold be applied to the reporting of the scope of estimations on the bill? 6.2b If a threshold is used how should this threshold be determined? 6.2c. How should customers be informed of the threshold if implemented?

No Comment.


Estimations methodology 22. A customer’s past behaviour during the previous CPP event (if available) should be used in estimating their consumption in the event of a meter failure during a CPP event. 23. All customers should have the right to challenge estimated readings on the bill if they believe that the estimate is not a reasonable estimate of their likely energy use.

No Comment.

Question 6.3

Estimations methodology for critical peak pricing 6.3a. Should changes to the metrology procedure be made to more accurately establish an estimation methodology in critical peak pricing? 6.3b. If so, how should these changes be progressed?

No Comment.


Monitoring of estimated and substituted data 24. AER will having an ongoing role in monitoring the use of estimated and substituted data.

No Comment.

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Part B Consumer Engagement

Organisation/Name: Contact Details: SECTION 7: Consumer Engagement

General Comments



Objectives of consumer engagement 7.1a. Are the objectives of the consumer engagement program sufficiently comprehensive? 7.2b. If not, what other objectives should be identified? 7.2 Are there any other issues which should be promoted in a consumer engagement program?

7.1 & 7.2 The objectives as stated are reasonably comprehensive


Co-ordination of consumer engagement by Government 25. The Commonwealth government and/or the state or territory governments should have a co-ordinating role in the consumer engagement program for the widespread installation of smart meters to enhance the understanding of the program by the community.

Effective consumer engagement relies on a coordinated approach across all government agencies.

Question 7.3

Role of government in non mandated rollout 7.3. What should be the co-ordinating role of government in a consumer engagement program in the absence of a mandated roll out?

7.3 In the absence of a mandated roll-out the government could still play a role promoting the immediate and long-term benefits of smart meter to consumers. Government endorsement of the smart metering program should help promote customer confidence and acceptance of smart meters.

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Involvement of stakeholders in consumer engagement programs 26. To develop relevant strategies for the consumer engagement program and to recommend the most appropriate strategies for different customer groups and circumstances, the involvement of industry and consumer representatives is essential.

ENERGEX agrees with this position. It is essential to have clear and consistent messages from all stakeholders.

Question 7.4

Responsibility for different stages of consumer engagement 7.4a. Who should take the lead role for consumer engagement and the provision of consumer education and information at each stage of a mandated roll out? 7.4b. Does this responsibility change with a non-mandated rollout?

7.4a The party mandating the rollout. 7.4b No, the party initiating the rollout should be responsible to the extent that it provides the least cost outcome for customers.

SECTION 8: Customers’ Access to Data through the Home Area NetworkGeneral comments


Policy position 27

Registering Devices on the HAN 27. Customers will be able to register a device on the HAN without having to enter into a contract with any party


Question 8.1

Registering Devices on the HAN 8.1. Should such registration be provided at no direct cost to the customer?

8.1 The party responsible for the registration should be allowed to recover the efficient cost of registering the customer.


Access Implications of Registration 28. Registering an IHD device or other device capable of receiving and displaying metering data and logging on to a web portal provided constitutes a request for access to metering data.


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Question 8.2

Consumers’ access to data 8.2. Should consumers be able to access their own meter data via an IHD, web portal or similar devices free of charge?

8.2 There is a cost involved in providing the meter data; therefore there should be a mechanism through which the metering data provider can recover the efficient cost of providing the data.


Third party access to data 29. In accordance with current practice, consumers may authorise provision of their data to any authorised third party.


Question 8.3

Third party access to data 8.3 Are there any policy or regulatory changes needed to ensure that where consumers give consent to third parties to access their data this can be readily implemented?

8.3 The current regulatory framework does not cater for the operation of third parties. An AEMC review of the Rules is required to appropriately consider issues affecting the operation of third parties in the national electricity market.


Messaging through the IHD 30. Distributors can send messages on imminent power emergencies and planned interruptions, in accordance with the regulatory requirements, to consumers through their IHD without consent. 31. Neither the retailer nor distributor, or any third party, can send marketing or similar information to consumers through the IHD without the customers’ explicit informed consent to receive the information. 32. For retailers this consent can be obtained at the entry to the contract or during the contract period. Distributors and other third parties must have clear mechanism whereby this content is obtained. All parties must be able to provide clear evidence of this informed consent.


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Question 8.4

Messaging through the IHD 8.4a Is it reasonable to assume that the retailer could send information on pending price increases and other changes to contractual terms through the IHD without a customer’s consent? 8.4b. If not, should the retailer obtain the prior explicit informed consent of the customer for using this medium for transmitting such information.

No Comment.

SECTION 9: Privacy General comments

In forming policy on the protection and privacy of consumers’ data, consideration should also be given to the protocols currently under development by industry through the Smart Networks SMSCG subgroup.

SECTION 10: Independent Dispute Resolution for CustomersGeneral comments



Third party entry to Ombudsman schemes 10.1 Should any party offering products such as DLC through the HAN become members of the relevant Energy Ombudsman scheme? 10.2 What are the implications and risks of this approach?

10.1 ENERGEX supports a requirement that third parties wishing to offer products such as DLC products become member of the relevant Energy Ombudsman scheme. 10.2 This approach reduces the risk of consumers not being able to have their issues appropriately addressed.

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Part C Consumer Safety

Organisation/Name: Contact Details: SECTION 11: Metering Installations and Customer Impacts GeneralComment Please insert general comments on Section 11 in here

Draft Policy Positions 33 and 34

Customer Impacts and metering installations 33. Low income households should not be placed in additional or unexpected financial hardship as a result of the need for electrical repairs being identified during the installation of a smart meter at their premises. 34. Jurisdictions should be responsible for determining how to assist low income customers in these circumstances, depending on the nature of their rollout.

33. In a mandated rollout upgrades or repairs required to install a smart meter should not be at the expense of the any home owners unless safety issues are identified. Where faults and safety issues are identified, these should be addressed through the normal business as usual processes and this may be at the expense of the home owner. Other socials mechanisms would be used to assist those customers identified to be in hardship. In a non-mandated rollout the cost of any electrical repairs should be subject to negotiation between the customers and the party initiating the rollout. 34. ENERGEX agrees with this position.

SECTION 12: Radio Frequency Emissions and Smart MetersGeneral comments Please insert general comments on Section 12 in here

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Radio frequency Emissions and Smart Meters 35. Consumers must be informed about the standards which apply to radiofrequency emissions in respect to smart meters, the obligations on distribution businesses to comply with these standards, the outcomes of any relevant trials, and the compliance monitoring role of ACMA.

ENERGEX agrees with this position, however the wording needs to be changed from “the obligations on distribution businesses to comply with these standards” to the obligations on the metering provider to comply with these standards. ENERGEX also suggests that these requirements need to be reflected in equipment standards (Australian Standards)

Question 12.1 Radio frequency Emissions and Smart Meters 12.1. Who should be responsible for communicating information to consumers? What role should the distribution businesses take?

The party initiating the rollout should be responsible for the provision of the information. The role of distribution business will vary depending on whether it is a government mandated rollout or retailer rollout. In a retailer initiated rollout, the distributor is unlikely to have control over the meter due to the meter being of a type that the distributor is not a responsible participant (RP) for.

Section 13: Remote Energisation/Re energisation and Customer SafetyGeneral comments Please insert general comments on Section 13 in here

Draft Policy Position 36, 37 and 38

Remote energisation and re energisation 36. Remote energisation and re�energisation should become the standard practice across all jurisdictions. 37. Remote re�energisation could be carried out using the Arm or Monitor Supply functions of smart meters, depending on the jurisdictional decisions. 38. Jurisdictions should amend legislation, regulations and codes of practice to facilitate the implementation of remote energisation and re-energisation as standard practice for smart meters.


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Draft Policy Positions 39 and 40

Customer information 39. Guidance must be provided to customers to assist them to undertake the relevant safety checks in their premises before remote energisation or re-energisation is undertaken. 40. Retailers and distributors must not remotely energise or re-energise if they are not assured it is safe to do so.

39 ENERGEX agrees with this position. 40 It is not clear how a retailer or a distributor can be completely assured that it is safe to re-energise remotely.

Question 13.1 Customer information 13.1 What are the options for providing guidance to customers on their obligations regarding remote energisation and re�energisation of electricity supply?

13.1 Customers could be provided with fact sheets


Customer choice 41. Customers may be offered the option of a manual energisation or re-energisation, which may be on a cost-recovery basis. 42. Jurisdictions should make provisions to assist disadvantaged groups of consumers for whom remote energisation or re-energisation is not appropriate.

41. ENERGEX agrees with this position; However ENERGEX strongly disagrees with comments in the paper suggesting that in circumstances where it is a distributor-led rollout, it may be that the distributor is required to meet the costs of manual energisation or re-energisation. Regardless of who initiates a rollout, manual energisation or re-energisation should be on a cost –recovery basis. Provision of manual energisation or re-energisation must be on a cost recovery basis to ensure that customers understand the costs of their decision, where services are not provided at cost reflective prices perverse outcomes arise. 42. ENERGEX agrees with this position.

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Questions 13.2 Customer Choice 13.2. What are the implications for these customer’s premises being energised or re-energised using the on command or the switch on and monitor supply command?

13.2 No comment


Customer access to the meter 43. Electricity retailers and/or DNSPs must develop procedures for the remote energisation or re-energisation of premises where customers do not have convenient access to their meter.

43. ENERGEX agrees with this position.

Questions 13.3 Customer access to meter 13.3a When an energisation request is made by a customer should distributors and retailers ensure that the safety risks are mitigated by asking the customer to ensure that the main switch is turned off? 13.3b. What additional requirements are necessary when customers with smart meters make a request for an energisation that a remote energisation is carried out safely?

13. ENERGEX is unsure if it is realistic to request customers to switch off their main switch. Some customers may not be familiar with the switchboard or able to access the switchboard e.g. in apartments.


Worker health and safety 44. Training and communication for electrical tradespeople should be promoted to raise awareness of the possibility of remote re-energisation when electrical work is undertaken. 45. Codes of practice, guidelines and other documentation relevant to the electrical trades should be amended to recognise the possibility of remote re-energisation.

ENERGEX agrees with these positions

Section 14: National Minimum functionality and Embedded Generation

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General comments Please insert general comments on Section 14 in here

Question 14.1 Embedded generation 14.1. Are there any areas in which the minimum functionality may inhibit the use of embedded generation?

14.1 The minimum functionality should not inhibit the use of embedded generation.

Part A Pricing, Demand Management and Customer Billing ... · chapter 6 of the National Electricity...

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