Nexa Advisory welcomes the opportunity to contribute to the AER’s 2025 update to the Shared Asset Guidelines for regulated Stand-Alone Power System (SAPS).
We have consistently raised concerns around the role and performance of Distribution Network Service Providers (DNSPs) under the existing regulatory framework, which has limited the evolution and competitiveness of consumer-centric technology solutions including SAPS.
As noted by the AER, the “competitive provision of SAPS generation services will provide long-term benefits to customers by facilitating price discovery and product innovation in SAPS generation services”. As such, it is critical that ring-fencing is upheld such that regulated DNSPs are the last resort in delivering these solutions.
Where ring-fencing is enforced and it is determined that DNSPs are best placed to deliver SAPS solutions, we support the application of the Shared Asset Guidelines by the AER to ensure competitive and cost-effective outcomes for electricity consumers. We agree that all regulated SAPS net positive generation revenues are material and should be reflected in the cost reduction of the regulated revenue requirement to avoid DNSPs ‘double-dipping’ and electricity consumers paying twice for these solutions.
Read our submission here: Nexa Advisory – AER SAPS Review submission