AGL-logo30 May 2011

Dear Mr Sarcich

Issues Paper - Victorian Licensing Arrangements

AGL Energy Ltd (AGL) welcomes the opportunity to comment on the Department of Primary Industry's (the Department) recently released Issues Paper (the Paper) on Victorian licensing arrangements under the National Energy Customer Framework (NECF).

AGL is primarily concerned with matters relating to retail issues. Accordingly, we have very few comments on the Paper, given that on the commencement of NECF, jurisdictional retail licensing will be replaced by a national retailer authorisation scheme.

With respect to the proposed policy alternatives outlined in section six of the Paper, AGL supports the first option - that is, there is no further authorisation or licensing requirement imposed on the generation, transmission and distribution sectors at the State level, but rather it is left entirely to the national frameworks. This option is preferred primarily because it will reduce regulatory overlap and lead to greater national consistency in terms of regulation.

AGL recognises that the regulation of small and distributed generation needs further consideration. In this case, we support a number of the recommendations made by the Essential Services Commission in its review of small scale licensing, particularly in relation to customer choice and dispute resolution.  AGL will comment further on this issue once the Department has assessed the various options and provided greater detail.

Please contact Anna Stewart, Manager Regulatory Policy and Strategy should you wish to discuss.

Yours sincerely

Alex Cruickshank
Head of Energy Regulation