Dear PLBSP Secretariat,

Re: Jemena Electricity Networks (Vic) Ltd. (JEN) Response to 'Consultation Paper - Regulatory Arrangements to Support the Power Line Bushfire Safety Program

Thank you for the opportunity to comment on the Department of Primary Industries' consultation paper concerning the abovementioned Paper and more specifically "the Victorian Government aims to reduce the risk of bushfire starts on Victorian electricity distribution networks by almost two-thirds".

In summary;

1. JEN's preference is that 'Regulatory Change' is used to affect the implementation of the technology programs nominated;

2. JEN's view is that the ESMS is the best vehicle for enforcing implementation of the technologies nominated and that the AER regulatory distribution price review process should be utilised to recover costs for the rollout of these technologies;

3. JEN's view is that a similar process be employed to the implementation of the network safety programs included in the 2011-15 regulatory period where ESV formally endorses to the AER, the DNSP's future EDPR submission;

4. The DNSP's network safety programs rollout progress should be monitored against the plan by including the additional technology programs in the quarterly safety program reporting to ESV.

JEN looks forward to the opportunity of discussing these matters in further detail. Should you have any queries or require any clarification please contact our Network Performance Manager, Mr David Speairs on 85449614.

Yours sincerely

Richard Twisk
General Manager Electricity Networks
Jemena Electricity Networks

Attachment - Questions for stakeholder response

1. Which of the three general options (regulatory change, ESV Directions, or non-regulatory) is preferable for:

a. the rollout of new generation ACRs?

b. the rollout of REFCLs following a successful trial?

c. requirements for new power lines in high bushfire risk areas?

JEN Response

It is JEN's view that 'Regulatory Change' provides the best mechanism for the rollout of new generation ACRs and REFCLs and the requirements for new power lines in the hazardous bushfire risk area.

2. Has the mechanism and cost recovery approach for each technology been characterised correctly in Table 5.1?

JEN Response

With regard to regulatory change, JEN believes that the ESA does not need to be amended for this purpose. Section 104 is a mechanism by which ESV can request that the DNSPs ESMS contains the requirement to rollout new generation ACRs, REFCL's and power line replacement. Section 105 is a mechanism by which ESV can order that an ESMS contains the requirement for DNSPs to rollout these technologies.

The BMP is not a logical vehicle for this purpose. The BMP is used to ensure that JEN has, and follows appropriate fire prevention standards but it does not define the standards. Defining standards is in the scope of the ESMS. The BMP will monitor that the correct operating procedures are applied to the ACRs. Therefore JEN believes that the ESMS is the appropriate vehicle to ensure that any required technology implementation occurs.

JEN does not consider the non-regulatory option to be workable without a follow-up of an ESV Direction.

For each approach, JEN's view is that a similar process be employed to the implementation of the network safety programs included in the 2011-15 regulatory period where ESV formally endorses to the AER, the DNSP's future EDPR submission associated with these technology programs.

3. What impact (if any) will adoption of the non-regulatory approach for any of the technologies have on the ability of the businesses to seek cost recovery from the AER?

JEN Response

JEN does not expect that the adoption of the non-regulatory approach for any of the technologies will impact on the ability of the businesses to seek cost recovery from the AER, although the DNSP's ability to do so will be improved through a regulatory approach and ESV's endorsement of the DNSP's proposal.

4. Is the BMP or the broader ESMS the best instrument to detail DNSP commitments in relation to the rollout of network assets and power line replacement?

JEN Response

The ESMS is the best instrument to detail DNSP's commitments in relation to the rollout of network assets and power line replacement. The ESA contains mechanisms for ESV to enforce inclusions (or exclusions) for DNSP's ESMS.

JEN does not believe that the BMP could be used effectively to detail DNSP commitments in relation to the rollout of network assets and power line replacement. The BMP could be used to ensure DNSPs have and follow appropriate fire prevention standards but not to define the standards; defining standards is in the scope of the ESMS. The BMP will also monitor that correct operating and maintenance procedures are applied to, whichever technology is employed as directed by this Safety Program.

5. Are there any other suitable options available for the regulation of PBST implementation with respect to network assets, or for any of the individual elements? If so, what mechanism could be used and how would cost recovery be provided for?

JEN Response

JEN has not identified any other suitable options available for the regulation of the PBST implementation other than those that have been proposed.

6. What information should be captured from each of the program components to inform the annual review of progress to the Powerline Bushfire Safety Oversight Committee?

JEN Response

Quarterly reporting of ACR, REFCL and power line volumes installed, measured against agreed, seasonalised targets.

It is recommended that the reporting requirement is incorporated into the existing quarterly safety program reporting to ESV.

Page last updated: 09/06/17