Submission to AER Values of Customer Reliability methodology final determination

The JEC received a special invitation to comment on the final determination of the Values of Customer Reliability (VCR) methodology.

We made recommendations that:

• the next review is brought forward from the maximum deadline of five years from now to just three; 
• the AER begin the work of convening an expert panel of advisors to guide the work no later than 18 months from now; and
• the next review aims to produce values that are ‘forward-facing’, meaning intended to be accurate over the duration of the period in which they apply, not just the year in which they are produced.

We also reiterated our position that any VCR methodology that does not use a mixture of both deliberative and non-deliberative direct engagement techniques is likely to substantially misestimate the preferences of consumers with respect to willingness to pay for outages.