The Justice and Equity Centre responded to the Australian Energy Market Commission’s (AEMC) draft decision to include distribution network resilience in the National Electricity Rules. While we support efforts to improve how networks prepare for extreme weather, we’re concerned the proposed framework could lead to higher costs for NSW energy consumers without clear benefits.
Our submission warns that the current definition of “resilience” is too vague and risks being confused with reliability—potentially allowing energy companies to charge twice for the same services. We argue that resilience should focus on how communities experience and recover from outages, not just preventing them.
We also call for stronger safeguards: clearer criteria for what counts as a “resilience event,” better transparency in annual planning reports, and a more robust, binding definition of resilience—not just a flexible guideline.
Without these changes, consumers could face unnecessary costs and overinvestment in infrastructure. We urge the AEMC to take a more measured approach that protects households and ensures resilience spending is fair, efficient, and aligned with community needs.
