The Justice and Equity Centre responded to the Australian Energy Regulator’s (AER) draft update to the Shared Asset Guidelines, focusing on regulated stand-alone power systems (SAPS). These systems offer a more efficient alternative to traditional grid connections, especially in remote areas, and can help lower energy costs for all NSW consumers.
Our submission supports the intent to ensure that when energy networks use regulated assets to provide unregulated services, the benefits are fairly shared with consumers. However, we’re concerned that the current guidelines don’t fully reflect the costs involved in operating SAPS or align with broader energy policy goals.
We recommend updating the definition of SAPS revenue to account for settlement-related costs and streamlining reporting requirements to avoid unnecessary administrative burdens. We also call for better alignment between the Shared Asset Guidelines and the Ring-fencing Guideline to support wider SAPS deployment.
These changes would help ensure SAPS are used where they offer the greatest value, reduce network costs, and promote fairer outcomes for NSW households—especially those in regional and remote communities.
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