AER submissions to the AEMC Review of chapter 6 of the National Electricty Rules - revenue regulation (October 2006)

On 24 March 2006 the AER provided a submission to the Australian Energy Market Commission, Draft National Electricity Amendment (Economic Regulation of Transmission Service) Rule 2006 (now known as the 'Proposed Rule'). The submission is comprised of three parts. Part A comments on a number of the higher level issues raised by the AEMC’s draft rules. More detailed comments and suggested specific amendments to the draft rules are provided in part B of the submission. Reports of consultants engaged by the AER to analyse aspects of the draft rules are provided in part C. This was shortly followed by a supplementary submission discussing issues related to information disclosure.

Following the AEMC's Draft Rule Determination on 26 July 2006, the AER lodged a further submission on the second Draft National Electricity Amendment (Economic Regulation of Transmission Service) Rule 2006 (now known as the 'Draft Rule') on 15 September 2006. This submission comments on the improved Draft Rule, and makes recommendations on remaining issues in the Draft Rule related to the balance of the regulatory framework and the effectiveness of incentives, the decision-making process, transparency problems and transitional arrangements. This was shortly followed by a supplementary submission specifically dealing with issues related to interpretation of the Draft Rule.

On 20 October 2006 the AER provided a supplementary submission to the AEMC on the appropriateness of the 'reasonable estimate' test for the approval of forecast operating and maintenance and capital expenditure. This was in repsonse to a brief consultation process initiated by the AEMC following receipt of legal advice from the Australian Government Solicitor on the meaning of the test.