The Justice and Equity Centre (JEC) made a submission to the AEMC consultation paper on Including distribution network resilience in the National Electricity Rule.
The JEC supports the intent of the rule, which we understand as providing network businesses greater clarity and more consistent direction concerning spending on resilience. However, we are not convinced this intent is best served by creating new categories of network investment. We are concerned the proposed framework may lead to inefficient investment and unnecessary costs for consumers.
Resilience should focus on response and recovery, not preventing all outages, and approaches should be tailored to the specific needs of different communities. We recommend a comprehensive assessment of consumer risk preferences be undertaken to inform a value of network resilience. This would help foster efficient investment and ensure consumers do not pay multiple times for network resilience.
