PIAC lodged a submission to the AER’s draft Distribution Reliability Measures Guideline. PIAC considers that reliability metrics and incentive schemes such as the Service Target Performance Incentive Scheme (STPIS) should allow clear and consistent measurement of network performance against appropriate targets and provide an incentive to the network businesses to efficiently meet these targets. However, balance is needed to ensure that the impact of the schemes do not exceed consumers’ willingness to pay. PIAC opined, regarding the AER’s intended treatment of major event days, that there is a risk that apparently poor network performance on a catastrophic day may skew the network’s overall reliability measure, which could be used to justify excessive network reinforcement.