Cedric von Duering, Author at Compliance Quarter

Nov242021 by Cedric von DueringNo Comments

Time to understand “Ring-fencing”

On 3 November 2021, The Australian Energy Regulator (AER) concluded and published a revision of the Ring-fencing Guideline. Parties are expected to be fully compliant with the updated Guideline (version 3) by 3 February 2022. The Ring-fencing Guideline was revised to establish a framework and controls for a competitive market for deploying community-scale batteries and Stand-Alone Power Systems (SAPS). By separating monopoly network services and avoiding cross-subsidisation of large Distributed Network Service Provider (DNSP), the AER seeks to make energy services more competitive and beneficial for customers. What is Ring-fencing? Ring-fencing describes the division of regulated services (eg. installation/maintenance of poles and wires) and contestable services (eg. installation of smart meters) provided by DNSPs. Thus, the Ring-fencing Guideline regulates to what extent the DNSPs can provide regulated services and when…

Nov242021 by Cedric von DueringNo Comments

Standardised Models for Regulated Metering Services

AU Energy Compliance

The Australian Energy Regulator (AER) is developing a standardised metering services model to use in the future across all jurisdictions. The AER intends to standardise the presentation of distributors’ metering expenditure for the AER’s assessment. The outcomes sought are: Better and more transparent presentation for consumers;Unified understanding amongst distributors; andMore time-efficient processing of proposals by the AER. Currently, the AER assesses each distributors proposal for metering models individually, including their CAPEX, OPEX, revenue and pricing models. The absence of a unified collation and presentation structure results in complexities for the AER, retailers and customers. Different models with varying levels of complexity and information content are a significant barrier for retailers and consumers who engage with distributors’ proposals. A unified model is sought to provide for greater engagement of consumers and…

Sep272021 by Cedric von DueringNo Comments

AER Life Support Registration Guide – A Good Reminder

AU Energy Compliance

On 1 August 2021, the new obligations regarding life support came into effect. These obligations were made pursuant to a rule change published by the AEMC in February 2021. The aim of the new rules is to clarify the responsibilities between retailers and distributors to ensure the accuracy of life support registers. The AER has now published an 11 page guide (the Guide), which although has no legal force, provides information on the following areas: the customer registration process;the deregistration of life support customers;the obligation to share information; andthe obligation to keep and maintain a register and record of life support requirements. Registration Process The Guide provides a breakdown of the life support registration process which is split into: (i) customer notification, (ii) medical confirmation, (iii) deregistration, (iv) information sharing…

Sep212021 by Cedric von DueringNo Comments

ESC Review of the Payment Difficulty Framework

AU Energy Compliance

In January 2019, the payment difficulty framework commenced in Victoria to ensure that disconnection for non-payment is a last resort and that vulnerable customers are supported to pay for their energy usage. After two years of operation, the payment difficulty framework remains the most stringent customer protection framework in the country and has been considered a success by the Essential Services Commission (ESC). Now the ESC has commenced a review to evaluate and assess the operation of the framework in meeting its objective. The ESC does not intend for the review to result in significant reforms to code obligations or to revisit the underlying rationale of the framework. Rather, the ESC seeks to provide more actionable guidance on the framework. The aim of the review is to: Identify issues with…

Jan192021 by Cedric von DueringNo Comments

4 Months not prompt enough to fix customers’ meters

AU Energy Compliance

For the failure to promptly fix meters, the AER has issued eight infringement notices which led three AGL retailers to pay a total of 160,000 in penalties. Each infringement notice cost the AGL entities $20,000. The infringement notices were issued as the AER found that there were sufficient grounds to believe that there was a breach of clause 11.87.7(h) of the National Electricity Rules (NER). The provision requires that a ‘financially responsible Market Participant’ receiving a notice of a metering installation malfunction under clause 11.87.7(g)(3) must ‘promptly appoint a Metering Coordinator’. Note, Embedded Network Retailers are currently not considered ‘financially responsible Market Participants’. However, if the planned changes by the AEMC come into effect it is likely that the same rules apply to Embedded Network Retailers. The infringement notices offer…