To the PLBSP Secretariat,
Regulatory Arrangements to Support the Power Line Bushfire Safety Program - DPI Consultation Paper
Please find below the Municipal Association of Victoria (MAV)'s brief comments in response to the DPI consultation paper regarding the regulatory arrangements to support the powerline bushfire safety program.
The content of the consultation paper does not provide the reader with sufficient information to enable informed responses to the questions asked.
The lack of transparency of Bushfire Mitigation Plan (BMP) content and of Electricity Safety Management Scheme (ESMS) content prepared by distribution network service providers (DNSPs) gives little capability to assess which regulatory approach is better.
Any approach must limit the ability of DNSPs to use the regulatory change pass-through mechanism, as described in the National Electricity Rules, to recover their costs. The costs of these new technologies and works need to be considered in consort with other changes to the network which includes any benefits or savings such new technologies may bring.
The MAV does not support a non-regulatory approach to any of the proposed changes. In the interest of transparency and accountability, a regulatory approach is preferred.
The MAV would prefer that cost recovery for the DNSPs be through the normal five-year regulatory proposal to the AER which, according to the consultation paper, provides the most transparent method through which the need for and efficiency of the proposed expenditure can be tested.
The MAV has no comment on question 3.
The MAV's preliminary view is that the BMP is probably the best vehicle for the regulation of these changes as:
- The Electricity Safety (Bushfire Mitigation) Regulations are, as noted in the consultation paper, specifically intended to make the DNSPs spell out their plans for the mitigation of bushfires in relation to their supply networks
- DNSPs are required under the Electricity Safety Act to make their approved BMP available online for inspection
The MAV cannot answer Question 5 without further information.
The MAV believes these improvements to the electricity distribution network are of such importance that full public disclosure is essential. The regulatory change to the BMP should require the DNSPs to detail publicly (in their published BMP)
- their detailed works plans for these improvements annual progress on implementation
- the costs of the these improvements
- the progressive decrease in risk and fire starts as a result of these improvements
- the numbers of times ACRS and REFCLS were operated during a fire danger period
- the savings in opportunity costs as a result of these investments
These items (and others) could be part of the information provided to the Powerline Bushfire Safety Oversight Committee.
In determining the most suitable regulatory option to ensure the DNSPs meet their commitments, it is critical that the State prioritises community safety and the need to minimise cost impacts on individual community members (irrespective of how the cost is passed on – i.e. through electricity consumption charges or taxes). Reporting on works and expenditure must be transparent and accessible.
Given the Victorian Bushfires Royal Commission finding that five of the Black Saturday bushfires were caused by electricity asset failures, it is critically important that the State works to ensure the DNSPs are making substantial efforts to improve the safety of their assets. It remains unclear, and would be interesting to know, how much of the DNSPs' "investment" in improving the safety of their electricity network assets is actually being borne by the DNSPs, as commercial entities, as opposed to being passed on to consumers via increased electricity tariffs.
Chief Executive Officer
Page last updated: 09/06/17