Market engagement

Vector AMS' smart metering experience and expertise has enabled Vector AMS to provide significant thought leadership in the Australasian utility markets.


Vector AMS is actively participating in the development of the Australian energy reform where it specifically relates to competitive metering. We are engaging with Ministers and their staff at State and Federal level, participating in industry working groups, providing submissions to industry consultations on rules, standards and protocols, and assisting Retailers, Distributors and Industry Groups with understanding the implications of current and future changes in the utility metering environment.

Copies of our regulatory submissions and other public consultation documents can be found below.

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Vector AMS' recent submissions to Regulatory consultation:

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National Measurement Institute (NMI)

NMI's Proposed Approval Standards for Electricity Meters Used for Trade, Legal Metrology Branch, National Measurement Institute 21 August 2015
Vector AMS support the ongoing alignment of metering standards in Australia with international standards. We believe that in the context of Australia's transition to advanced metering, it is appropriate for regulators to critically assess any deviation from international standards when considering their application in the Australian setting. Our preferred approach is for Australia to adopt international standards without changes that may unnecessarily create barriers to entry that distort prices and incentives in the Australian market

Australian Energy Market Commission (AEMC)

Submission on the Proposed Advanced Meter Communications Rule Change, 8 November 2018
Vector AMS has no objection to the rule change request submitted by the Australian Energy Council which seeks to allow the deactivation of the remote communications ability of a customer's advanced meter that is already installed if that is the customer's choice. While it is our belief that advanced meters are safe devices from a health perspective based on scientific evidence, we do respect some consumers' health-related concerns about advanced meters and recognise that the proposed rule change promotes consumer choice in the electricity market. We would like to believe that the need to deactivate the remote communications ability of advanced meters will diminish over time 1) with the increasing uptake of advanced meters, and 2) as the consumer benefits of advanced meters are realised more widely in the National Electricity Market.

Submission on the Metering Installation Timeframes Draft Rule Determination and Draft Rules, 25 October 2018
Vector AMS suggests, among other suggestions, that the AEMC's Final Determination and Final Rules on metering installation timeframes: 1) consistently apply DNSPs' obligations across connection and non-connection services, 2) allow the retailer and customer to agree on a "short date range" within which the meter will be installed, 3) identify situations that should be exempt from the proposed timeframes, 4) adopt a 1-day objection period in the nomination of the Metering Coordinator (MC), rather than a "zero day" objection period, to allow the MC to refuse the role in circumstances where it is unable to deliver or does not offer particular services, and 5) allow a short date range for a retailer planned interruption notice in particular circumstances.

Submission on the Proposed Rule Changes on Metering Installation Timeframes, 12 July 2018
In Vector AMS' view, mandating metering installation timeframes is not warranted only six months into the introduction of competitive metering arrangements in the National Electricity Market. Our advanced metering deployment is progressing well, and there is continuous improvement rather than deterioration. Imposing greater prescription at this early stage of market reform to resolve what we consider to be transitional issues will stifle the discovery of better approaches in the installation of advanced meters. It will put a brake on the momentum of smart metering deployment and the development of energy markets.

Submission on the AEMC's Five Minute Settlement Draft Rule Determination, 17 October 2017
Vector AMS recommends that the AEMC clarify in its Final Determination on Five Minute Settlement that: 1) from 1 December 2018, all new and replacement type 4 metering installations will need to be capable of recording five minute data, and 2) these meters will only be required to record and submit five minute data after the commencement of the rule change in 2021. We confirm that the meters we are deploying in the NEM are already capable of recording and storing five minute data.

Submission on the AEMC's Draft Rule Determination on Updating the Electricity B2B Framework, 19 May 2016
VAMS generally supports the AEMC's "more preferable draft rule" on updating the B2B framework, which accommodates new metering service providers and provides flexibility for B2B participants to use alternative means of communication. We believe that any proposed changes to B2B governance and procedures should not be a pre-requisite for the commencement of competitive metering arrangements.

Submission on the AEMC's Consultation Paper on Updating the Electricity B2B Framework, 28 January 2016
In Vector AMS' view, any proposed changes to the B2B framework should not be a pre-requisite for the commencement of the Competition in Metering Rule Change on 1 December 2017. We support the AEMC's decision allowing parties to use alternative communication methods.

 

Submission on the AEMC's Draft Rule Determination on Meter Replacement Processes, 28 January 2016
Vector AMS supports the AEMC's more preferable draft rule which rejected the proposed "prospective Metering Coordinator, Metering Provider and Metering Data Provider roles" and allows parties, in certain circumstances, to enter into commercial agreements to change the meter prior to the completion of the retail transfer process. Vector AMS does not support any alternative option in the future that would allow a change in the meter to trigger the retail transfer process.

AEMC's Draft Rule Determination on Multiple Trading Relationships, 14 January 2016
Vector AMS agrees with the AEMC's Draft Rule Determination not to make an MTR rule change, which reflects the general position of many, if not almost all, submitters.  We consider this decision to be highly sensible at this stage of market development in the NEM.

AEMC Directions Paper – Meter replacement processes, 8 October 2015
Vector AMS believe the proposes meter replacement processes better reflects the Government's objective of promoting competition in the metering market than the proposals in its May 2015 consultation paper, triggered by ERM Power's rule change request on meter replacement processes.

AEMC's Strategic Priorities for Energy Market Development, 9 October 2015
Vector AMS welcome AEMC's recognition of the potential impacts of emerging technology and the need to ensure the regulatory framework enables and supports investment and innovation in the context of a dynamic market. In addition to encouraging efficient investment and flexibility, we believe the further development of energy markets should be emphasised under the "market priority", particularly in the context of the expansion of competition in metering and related services in the National Electricity Market. 

Additional Consultation on Specific Issues – Competition in Metering Rule Change, 1 October 2015
Vector AMS broadly support AEMC's Draft Competition in Metering Rule Change, which proposes amendments that collectively set the framework for expanding competition in metering and related services to small-to-medium businesses and residential consumers in the National Electricity Market ("NEM"). We particularly support the light-handed regulatory framework being proposed, which leaves many transactions to commercial agreements, reflecting confidence in the capability of market mechanisms to deliver benefits to industry and consumers. 

Proposed Multiple Trading Relationships Rule Change, 10 September 2015
In our view, the MTR Rule Change would only add to the complexities of the reform process without overriding benefits for industry and consumers. As such, we recommend that AEMC defer its consideration of this proposal and revisit it, as necessary, when it reviews the metering market three years following the implementation of competitive metering arrangements.

AEMC's Draft Implementation Advice on the Shared Market Protocol, 23 July 2015
Vector AMS broadly agree with the AEMC's Draft Advice on the shared market protocol. We believe the proposed arrangements would support ongoing reforms expanding competition in metering and related services, and the deployment of advanced meters in the National Electricity Market ("NEM").

Draft Rule Change on Meter Replacement Processes, 2 July 2015
Vector AMS believe the proposed rule change on meter replacement processes is unnecessary. This proposal would only add to the complexity of the ongoing reforms in the electricity metering market without overriding benefits to consumers. 

Submission on the Draft Rule Determination - Expanding Competition in Metering and Related Services, 21 May 2015
Vector AMS generally supports the AEMC's Draft Rule. We appreciate the AEMC exercising restraint by leaving most of the proposed arrangements to commercial negotiations and to the rapidly evolving metering market. This supports the Government's market-led approach to achieving its efficiency and competition objectives for the electricity sector.

Implementation Advice on Shared Market Protocol 12 February 2015
Vector AMS supports the decision to implement a "shared market protocol" rather than a more prescriptive "common market protocol". While we support minimum service levels that benefit consumers, we do not support prescriptive technical and functional specifications. We believe that a more prescriptive approach would limit market competition, dampen investment incentives, stifle technological and service innovation, compromise technology neutrality, shift upfront risks from investors to consumers, and increase implementation and compliance costs.

National Electricity Amendment (Customer access to information about their energy consumption) Rule 2014; and National Energy Retail Amendment (Customer access to information about their energy consumption) Rule 2014, 5 June 2014
Consumers should be able to access information on their electricity consumption from their distributor or retailer. This would promote a more efficient and dynamic electricity market. Service providers should be allowed to recover the costs of providing information where these are high.

National Electricity Amendment (Expanding Competition in Metering and Related Services) Rule 2014; and National Energy Retail Amendment (Expanding Competition in Metering and Related Services) Rule 2014, 29 May 2014
Vector AMS supports the Rule Change Request however we do not consider that the AEMC's proposal to impose exit fees for the replacement of legacy meters with smart meters to be an appropriate mechanism. Exit fees create a cost barrier to entry, which could frustrate competition and disadvantage first-mover entrants.  We suggest alternatives to exit fees. While we support the setting of minimum service standards, which benefit consumers, we do not support proposals mandating technical standards. We prefer the development of principles and guidelines. As market competition emerges, the need for greater regulation should go away.

Supplementary Paper – Regulatory Framework: Framework for open access and common communication standards, 7 March 2014
Vector AMS supports the AEMC's draft recommendation to allow the development of the market for smart metering services without regulatory intervention.  Vector AMS further supports a competition review of end-user services enabled by smart meters at an appropriate time in the future. 

Draft Report: Framework for Open Access and Communication Standards, 30 January 2014
The AEMC's proposal to mandate technical standards for smart metering is not necessary and is not to the long-term benefit of consumers. The proposal is likely to 1) limit market competition, 2) dampen investment incentives, 3) stifle technological and service innovation, 4) compromise technology neutrality, 5) shift upfront risks from investors to consumers, 6) and increase implementation and compliance costs without overriding benefits to consumers.

COAG

Submission on the Proposed NEM Data Strategy, 20 April 2018
Vector AMS supports greater access to data, particularly for the development of new and innovative services that benefit consumers. We encourage the Energy Security Board and other regulators to refrain from adopting highly prescriptive arrangements for data access and sharing in the NEM, where competition in metering services has been introduced. Where competitive services are emerging, the need for prescriptive arrangements should fall away.

Submission on Facilitating Access to Consumer Electricity Data, 26 March 2018
Vector AMS suggests that the consideration of any future data access scheme be incorporated into the Energy Security Board's broader and more strategic work on the proposed Data Strategy for the NEM. This will ensure that regulatory overlaps and gaps, and unnecessary costs, are avoided.

Regulatory implications of new products and services in the Electricity market 20 March 2015

We are not convinced that "regulatory reforms" are warranted to accommodate new products and services being offered to electricity consumers. We believe this will limit innovation and competition that benefit consumers.

AER

Submission on the AER's Issues Paper on TasNetworks' Electricity Distribution Regulatory Proposal for 2017-2019
VAMS supports TasNetworks' decision not to include metering exit fees and transfer fees in its regulatory proposal for 2017-2019. We oppose the imposition of these fees because they create a barrier to market entry, limiting competition and hampering the deployment of advanced meters to the mass market.

AER's Preliminary Decision on Victorian Electricity Distribution for 2016-2020, 21 December 2015
Vector AMS agrees with the AER's preliminary decision to classify metering services in Victoria as alternative control services for the next regulatory control period.  It is appropriate in the context of the transition to competitive metering arrangements, reflecting the lighter-handed form of regulation these services will be subject to.  The unbundling of metering services from network charges enables market participants to make more informed commercial decisions - an important feature of an emerging competitive market.

AER Issues Paper Victorian Distribution 2016-2020, 13 July 2015
Classifying metering services under Alternative Control promotes pricing transparency that enables market participants to make more informed investment decisions, an important feature of a competitive market. It also improves the ability of those services to become contestable, and as a lighter-handed form of regulation (relative to Standard Control), it is an appropriate classification in the context of an emerging competitive market.

AER's Preliminary Decisions on Electricity Distribution in Queensland and South Australia for 2015-16 to 2019-20, 3 July 2015

Vector AMS believe the preliminary decisions will promote market competition and innovation in metering and related services, and facilitate the timely deployment of smart meters in Queensland and South Australia, the benefits to consumers of which are widely recognised. 

Submission on the AER's Preliminary Positions on TasNetworks' Replacement F&A, 15 May 2015
Vector AMS welcome the AER's decision to replace the Framework & Approach ("F&A") for electricity distribution in Tasmania for the next regulatory control period. In our view, this is appropriate and necessary in light of ongoing reforms in the electricity sector, including the proposed rule change expanding competition in metering services in the National Electricity Market ("NEM").

Vector Submission Residual Capital Cost Recovery 27 March 2015
We support mechanisms that remove exit fees for the replacement of type 5 and 6 ("legacy") meters with smart meters for the next regulatory control period. Exit fees create a barrier to market entry that is likely to frustrate the policy objective of expanding competition in metering services in the NEM. While we oppose exit fees, we recognise that distributors should be allowed to recover the cost of their efficient regulated investment, i.e. residual capital costs of their legacy metering assets.

Submission on the AER's Draft Decisions on NSW and ACT Electricity Distributor's Regulatory Proposals for 2015-16 to 2018-19, 13 February 2015
We believe a market-led approach, driven by retailers, provides the right incentives for competition, innovation and investment that benefit electricity consumers. 

Submission on the AER's Draft Decisions on NSW and ACT Electricity Distributor's Regulatory Proposals for 2015-16 to 2018-19

Submission on AER's Issues Papers on Queensland and SA Electricity Distributors' Regulatory Proposals for 2015-16 to 2019-20, 30 January 2015
Vector AMS supports in principle the Australian Governments market-led approach in the metering market and the electricity sector. Vector AMS does not support the proposal charge exit fees because it will create a barrier to market entry stifling competition but accept there is a need to recover the efficient residual capital costs of the meters and propose this should be through DUoS.

Issues Paper, ActewAGL electricity distribution regulatory proposal, 2014-15 to 2018-19, 22 August 2014
Vector AMS is concerned that a transition to a competitive metering market in ACT is not widely discussed in the Issues Paper.  A key issue for Vector AMS is the AER's proposal to impose exit fees. We suggest alternatives that do not require exit fees, including a combination of an appropriate unbundled charge and the remaining value of the asset recovered through the distributor's regulatory asset base.

Issues Paper, NSW electricity distribution regulatory proposals, 2014-15 to 2018-19, 8 August 2014
Vector AMS is concerned that a transition to a competitive metering market in NSW is not widely discussed in the Issues Paper.  A key issue for Vector AMS is the AER's proposal to impose exit fees. We suggest alternatives that do not require exit fees, including a combination of an appropriate unbundled charge and the remaining value of the asset recovered through the distributor's regulatory asset base.

Preliminary positions on replacement framework and approach for electricity distributors in Victoria, 21 July 2014
Vector AMS is pleased with the AER's decision to replace the current Framework & Approach for Victorian distributors to reflect ongoing and impending changes to regulatory arrangements in the NEM. We support the policy objective of expanding competition in metering services in the NEM. We do not consider, however, that the AER's proposal to impose exit fees is an appropriate mechanism to promote competition in the metering market in Victoria. Exit fees create a barrier to entry, frustrating competition.

Notice inviting submissions on whether it is necessary to amend or replace the current Framework and Approach papers for electricity distributors in Victoria for the 2016-2020 regulator control period, 17 April 2014
Vector AMS argues that it would be desirable and necessary to update, if not replace, the F&As for Victorian distributors for the next regulatory control period. The Government's intention to introduce competition in the metering market would have significant implications for market arrangements in the coming years for Victoria, which implemented a mandated rollout of smart meters. These changes need to be reflected in Victorian distributors' F&As, as necessary.

Stage 2 Framework and Approach and Transitional Regulatory Proposal for Ausgrid, Endeavour Energy and Essential Energy, Stage 2 Framework and Approach and Transitional Regulatory Proposal for ActewAGL 5 March 2014
In order to ensure that the migration to smart meters is not unduly distorted by distributors' need to recover the cost of past investments, Vector AMS suggests that the AER consider 1) exit fees, or 2) accelerated depreciation.  Exit fees should be minimised, if not, avoided altogether. Vector AMS recommends that the AER review the impact of exit fees and the development of the smart metering markets in NSW and ACT. Vector AMS also recommends that the AER consider approaches for the accelerated depreciation of regulated distributors' legacy metering assets in these states as an alternative to exit fees.

Framework and Approach for SA Power Networks, Regulatory control period commencing 1 July 2015  and Framework and Approach for Energex and Ergon Energy, Regulatory control period commencing 1 July 2015, 19 February 2014
Vector AMS agrees with the AER's preliminary proposal to unbundle legacy metering charges from lines charges in South Australia and Queensland. This would provide more accurate signals to retailers intending to enter the market or provide improved services to their customers.  Vector AMS proposed that the AER consider approaches for the accelerated depreciation of regulated distributors' legacy metering assets in these states.

The Treasury

The Treasury Competition Policy Review Draft Report 17 November 2014
Competition policy should make markets work in the long-term interests of consumers, encourage innovation and the entry of new players, promote efficient investment in and use of infrastructure, and establish competition laws and regulations that are clear, predictable and reliable.

Department of Industry

Energy White Paper - Green Paper 2014, 3 November 2014
Vector AMS supports the Green Paper's theme of ‘driving regulatory and market reform to…increase competition and consumer choice". Greater competition in Australia's metering market would incentivise investments in smart meters that are critical to achieving efficiency and productivity improvements in the energy sector.

Queensland

Submission on the Review of Queensland Energy Legislation – Issues Paper, 19 June 2018
Vector AMS believes that the deployment of smart meters in Queensland can be facilitated through the introduction of measures that: 1) ensure electricity distributors in Queensland support new connections, and alterations and additions, in a manner that treats all Metering Providers equally, 2) remove legislative barriers to retailers using safe remote disconnection and reconnection services via smart meters, and 3) allow a customer to waive the requirement for a planned interruption notification from that customer's retailer in the installation of a new or replacement meter.

Issues Paper on Electricity Pricing in Queensland, Queensland Productivity Commission, 16 November 2015
The AEMC's development of a rule change expanding competition in metering and related services to small-to-medium businesses and residential consumers in the NEM represents a fundamental shift in the supply of metering services. The benefits of advanced meters are widely recognised in Australia and internationally and will deliver benefits for Queensland consumers. The expansion of competition in Queensland's metering market is expected to facilitate the deployment of advanced meters in the state. 

Queensland Department of Energy and Water Supply (DEWS), 30-Year Electricity Strategy, 6 December 2013
Vector AMS agrees with DEWS supporting the rollout of smart meters where a range of service providers can compete to offer customers smart metering services and product choices. Vector AMS suggests that DEWS focus on ensuring barriers to market entry by competing meter service providers are removed or avoided.

Tasmania

The Replacement of Tasmania's Distribution F&A for the Next Regulatory Control Period 18 March 2015
Vector AMS consistently supports the Government's market-led approach to achieving its efficiency and competition objectives for the electricity sector and ongoing reforms including the introduction of competition in metering services in the National Electricity Market ("NEM"). This would have significant implications for Tasmania, where type 5 and type 6 ("legacy") metering services are currently being provided only by TasNetworks.

South Australia

Department of Manufacturing, Innovation, Trade, Resources and Energy (DMITRE), South Australian Policy for New and Replacement Electricity Meters, 27 March 2014
Vector AMS does not support DMITRE's proposed policy requiring the installation of ‘smart ready' meters by default where a new or replacement meters is required.  This policy would ‘lock out' other market participants and potential investors, whose preferred technology may not be compatible with the smart ready meter. It would limit competition and would not provide the right incentives for metering providers to introduce innovative and more efficient products to the market.

Western Australia

Submission on the Draft Decision on Western Power's Proposed Revisions to its Access Arrangement – AA4, 14 June 2018
In Vector AMS' view, the Economic Regulation Authority must not approve Western Power's proposed advanced metering project unless and until Western Power has complied with the Regulatory Test in Chapter 9 of the Electricity Networks Access Code 2004 (WA). The Regulatory Test requires a detailed consideration of alternative options, which we consider should include an assessment of third party ownership of meters and third party metering services provision to Western Power.

Submission on the Issues Paper on Proposed Revisions to the Western Power Network Access Arrangement - AA4, 11 December 2017
Vector AMS believes that WA consumers will benefit most from advanced metering services that are delivered competitively. We encourage ERA to make policy recommendations on metering that closely align with the NEM competitive metering framework. This will ensure that policy options promoting market competition and innovation that benefit consumers can be developed and implemented.

Submission on the Proposed Selection Criteria for Membership of the Rule Change Panel, 18 March 2016

We generally support the proposed individual and collective requirements for the new Rule Change Panel. In addition, we suggest that the individual requirements be broadened to include understanding of the commercial and technological environments of the WA electricity market. We further suggest that the collective requirements include an in-depth understanding of the drivers and dynamics of market competition, and their impact on investment and innovation incentives.
 
We believe that the rule change body membership should be open to industry representatives or those with extensive industry knowledge and experience. 
 

Submission on the Proposed Design for the New Rule Change Assessment Panel, 14 August 2015
Vector AMS support the proposed design for the new Rule Change Assessment Panel, which focuses on addressing conflicts of interest, and promoting transparency. We agree that these are essential for the effective governance of the Wholesale Electricity Market rule change process that would facilitate reform in the Western Australian market.

Western Australian Government - Department of Finance, Electricity Market Review, 12 September 2014
Vector AMS welcomes the Review, which aims to: 1) reduce costs of production and supply of electricity in Western Australia (WA), 2) reduce the state government's exposure to energy market risks, and 3) attract private sector participants to the electricity market to facilitate long-term stability and investment. We support the Review signalling the introduction of competition in metering services in WA.

NSW

Submission on IPART's Draft Report on Retailers' Metering Practices in NSW, 2 November 2018
Vector AMS supports IPART's recommendation to enable Metering Coordinators (MCs) and Metering Providers (MPs) to perform the following metering-related tasks to minimise delays in the installation of advanced meters in NSW: 1) operating any service fuse carriers required to de-energise a site for the installation of an advanced meter, 2) conducting live isolation work in very limited circumstances for the purpose of installing an advanced meter, subject to meeting the required health and safety conditions, 3) installing ripple control relay devices that are built into the advanced meter, and 4) providing planned interruption notices on the spot but only where the MP is also allowed to do the interruption. Vector AMS also supports IPART's draft decision not to make any recommendation on MCs' training requirements not only for cost-benefit reasons but also to ensure that the Accredited Service Providers and technicians we engage achieve a level of proficiency to ensure quality and safety are maintained under Vector AMS' MP accreditation.

Submission on the IPART Review of Electricity Retailers' Metering Practices in NSW, 29 June 2018
In Vector AMS' view, imposing greater prescription on NSW retailers' metering practices, possibly including prescribed installation timeframes for smart meters, only six months into the introduction of competitive metering arrangements in the National Electricity Market is not warranted. Our deployment of smart meters in NSW is progressing well. More prescriptive arrangements would add to the complexity and costs of the transition to smart metering, and frustrate the ongoing process of discovering opportunities to improve the overall installation process, which benefit consumers.

NSW Smart Meter Taskforce, NSW Trade & Investment, February 2013

Victoria

In VAMS' view, the full adoption of the new NEM regulatory framework for competitive metering at the same time as other NEM jurisdictions would deliver the best outcomes for small business and residential consumers in Victoria. It provides the strongest incentives for innovation, and the right forward-looking incentives for market participants to make the timely transition to competitive metering arrangements in the state.