Submission on Proposed delay to the review of the transmission ring-fencing guideline

We support the proposal to delay the AER’s review of the transmission ring-fencing guideline. The ring-fencing guidelines set out rules which the electricity transmission businesses must follow to ensure they do not exploit their monopoly power to gain an unfair advantage in other areas.

As outlined in the letter from Energy Networks Australia, there are a number of substantial reform processes currently underway which may affect the extent of a Transmission Network Service Provider’s roles and responsibilities. We agree that it would be beneficial to defer reviewing the ring-fencing guideline until after the direction of these broader reforms is better established.

We also consider the deferral would provide the AER, TNSPs and stakeholders with additional time to develop a better understanding of any implementation issues coming from the recent contestable connections framework as well as lessons from the implementation of the distribution ring-fencing guideline.

We do not consider there are pressing concerns with the current guideline which outweigh the benefits outlined above and in the letter from Energy Networks Australia.