This submission responds to the Australian Energy Regulator’s (AER) Issues Paper, Return on debt: Choice of third party data provider (the Issues Paper). The Issues Paper examines the issue of possible third party data providers to supply information that the AER could use in determining the return on debt for network service providers. In the submission, PIAC recommends that the AER not rule out the use of data published by the Reserve Bank of Australia, despite the fact that it is published for one day per month, rather than on consecutive days (as desired under the AER’s Rate of Return Guideline).