Category Archives: Submissions
Submission in response to the NSW Dept of Planning & Environment Discussion Paper on Consumer Protections
Submission in response to the AEMC’s draft report on the review of regulatory arrangements for embedded networks
Submission to the AEMC review of regulatory arrangements for embedded networks
Network Transformation Report Feedback
Submission to Senate Enquiry on Budget Cuts (ARENA)
Submission to Vic General Exemption Order Review
Submission to the AER’s Issues Paper on Ergon’s & Energex’s TSS
Submission to the AER’s Issues Paper on SAPN’s TSS
Submission to the QCA EPI Draft Report
APVI Response to the ARENA Public Consultation of the Proposed Large-Scale Solar PV Competitive Round
Submission to Ergon Energy’s Consultation Paper ‘The Case for Demand-based Tariffs’
Submission to Ergon Energy’s Consultation Paper ‘Aligning Network Charges to LRMC’
Submission to the AER Issues Paper on Innovative Energy Selling Business Models
Submission to SA Power Networks regulatory proposal
Submission to Qld DNSP regulatory proposals
APVI Submission to the AEMC Network Pricing Amendments
Summary of APVI Response
1. The APVI agrees that network pricing should be efficient and technology neutral.
2. The APVI does not agree with the premise that economically efficient pricing must involve recoupment of past expenditure, particularly where this expenditure was not itself economically efficient. Customers should not be forced to pay for investments they did not choose and do not need.
3. The APVI has serious concerns about some of the background modelling underlying the AEMC Determination. These could have significant impacts on the results and recommendations provided.
4. APVI’s own modelling concludes that a demand component added to electricity tariffs provides a fairer price signal to customers than uniform high fixed network components or time of use tariffs.
The full submission can be found here and the media release can be found here.
