ELECTRICITY FRC IN WA KEY MESSAGES

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1 ELECTRICITY FRC IN WA KEY MESSAGES REMC has analysed the likely benefits, csts, and issues assciated with implementing electricity full retail cntestability ( FRC ) in WA. This analysis is intended t assist the WA Gvernment and industry cnsider if, hw, and when electricity FRC shuld be implemented in WA. REMC has successfully perated the WA gas retail market since inceptin, fr ver 10 years, and stands ready t develp, implement, and perate a fully cntestable electricity retail market in the State, nce the WA Gvernment decides it wants t g dwn that path. Benefits Electricity retail cntracts have cnsistently been ffered at discunts t regulated tariffs, s cnsumers that chse such a cntract culd achieve significant savings. Discunts in the eastern States in ranged between 1.5% and 11%. It is reasnable t expect discunts f this magnitude frm regulated electricity tariffs in WA. 46%-81% f custmers have mved t market cntracts t date in the varius jurisdictins in the Eastern States. If this level f custmer transfer (churn) ccurs in WA, then implementing electricity FRC culd result in significant savings t WA electricity cnsumers. A 2.5% discunt frm cst-reflective tariffs culd result in direct net benefits f abut $27.8 millin ver a 10-year perid (NPV = $4.7 millin), accunting fr Market and Netwrk Operatr csts. With a 5.0% discunt frm cst-reflective tariffs, these direct net benefits culd be as high as $113.7 millin (NPV = $53.9 millin). Retailers will be able t innvate and ffer savings and/r value-added prducts t cnsumers (e.g. dual fuel ffers, slar prducts, service discunts, etc.). Custmers dissatisfied with their current services wuld be able t seek service fferings frm ther Retailers. Effective electricity retail market cmpetitin will imprve price signals, which will: Csts restrain the pace f price increases mre directly and respnsively than price regulatin; influence the amunt and timing f electricity usage, which may lead t reduced r delayed future netwrk augmentatin csts, and ptentially reduced peak demand; and put pressure n whlesale energy csts because f Retailers will mitigate risks thrugh hedge cntracts and ther financial instruments. Market Operatr csts: Gas FRC implementatin csts are the best indicatr f the csts t implement electricity FRC in WA because the gas markets were individual markets, and delivered systems similar t what wuld be needed fr the WA electricity market. Average csts t implement gas FRC acrss SA, NSW, Vic and WA was $8.5 millin. This suggests Market Operatr csts f $10-$15 millin, adjusting fr inflatin, and assuming n efficiency imprvements in develping and implementing the systems. REMC Page 1

2 Netwrk Operatr csts: Netwrk Operatrs electricity FRC implementatin csts in the eastern States ranged frm $12-$28 millin, and perating csts frm $2-$5 millin. Western Pwer will need t make significant systems changes t implement electricity FRC, particularly t its metering and market cmmunicatins systems. It is reasnable t expect Western Pwer s csts t be within the $12-$28 millin range. Retailers csts: Retailers will enter the market if ding s is likely t generate a net benefit. Retailer csts will vary significantly depending n the basis f their market entry, and will likely be $7-$10 millin, but may be as high as $20 millin if market changes are significant r if Retailers legacy systems needed t be replaced. Gvernment Cnsideratins Market participants have indicated svereign risk (plicy and regulatry risk) is the primary cncern with implementing electricity FRC; particularly with respect t treatment f Synergy and retail tariff setting. Retailers can manage all ther risks, which ffer the pprtunity fr Retailers t differentiate themselves. The WA Gvernment has indicated several electricity market refrm bjectives which culd be delivered by implementing electricity FRC as fllws: 1. Lwer electricity prices: Electricity FRC will put cmpetitive pressure n all market participants, which will frce them t imprve efficiency, and will reduce ttal electricity supply csts. Cmpeting Retailers will be able t ffer market cntracts t cnsumers at prices belw the regulated tariff. 2. Lwer Gvernment expsure t energy market risk (reduce the subsidy t Synergy): Electricity FRC will frce Synergy t increase its efficiency and reduce csts, which by definitin will reduce the amunt f the subsidy t Synergy. 3. Increase private sectr investment: If the private-sectr is t build new generatin plant, then market participants will need a means t mnetise their investments. The private sectr currently nly has access t a small number f custmers as a means t mnetise their investments, and FRC will give them access t the entire market. Implementing electricity FRC wuld require sme relatively minr up-frnt Gvernment investment t develp Market and Netwrk Operatr systems and prcedures; but will lead t significant lng-term reductins in Gvernment expenditure due t: - n need t fund future generatin capacity; and - a mre efficient market leading t reduced need fr netwrk expenditure. Timing fr Implementing Electricity FRC Tw key issues impact the timing fr when electricity FRC can/shuld be implemented, bth relating t WA Gvernment plicy: what limitatins are t be placed n Synergy s ability t exercise market pwer; and hw are electricity retail tariffs t be set, and subsidies prvided t cnsumers in need? REMC Page 2

3 These impact the ptential timing fr implementing electricity FRC in WA as fllws: Tariffs Timing fr Implementing Electricity FRC Gvernment sets tariffs and subsidises cnsumers via tariffs ERA sets tariffs and Gvernment directly subsidises cnsumers Limited steps taken Limitatins n Synergy Market Pwer Effective Steps Taken Other Mechanisms Split/Privatise X Lng-Term Lng-Term X Medium-Term Near-Term Key Issues Synergy and WA energy market plicy: Synergy is the dminant electricity generatr and retailer; s it has a significant influence n generatin capacity develpment, whlesale and retail pricing, and market develpment. Despite the Synergy re-merger and Synergy market dminance, the WA Gvernment has indicated that it wuld like t have a cmpetitive energy market, and wuld like industry t take the risk in develping future generatin plant. - The WA Gvernment has put arrangements in place t limit Synergy s market cntrl; but it is unclear if these arrangements will be effective, and market participants clearly perceive that they culd create a cnflict f interest r distrt the market. It is essential that Gvernment put effective mechanisms in place t ensure that Synergy cannt exercise its market pwer, and that private sectr market participants have fair access t generatin capacity at cmpetitively determined prices. - Splitting and/r privatising Synergy is ne way t accmplish this, and may be the surest methd. - Hwever, many ther methds are available, s splitting and/r privatising Synergy is nt a prerequisite fr implementing electricity FRC in WA. Electricity retail pricing and subsidies: Electricity retail tariffs are currently abut 33.5% belw the cst t prduce and deliver electricity. As a result, the WA Gvernment subsidises Synergy t prtect its slvency, and the prjected subsidy is $493.2 millin fr 2013/14. Cst-reflective electricity retail tariffs are nt a prerequisite fr implementing electricity FRC. - It is cmmnly argued that electricity FRC shuld nt be implemented until electricity retail tariffs are cst-reflective because cmpetitin will nt develp while tariffs are belw cst. - Hwever, the key is instead giving the ERA respnsibility fr setting electricity retail tariffs; and Gvernment cmmitting t mving tariffs t cst-reflective levels while directly subsidising cnsumers in need. - Implementing electricity FRC sner rather than later, and in the cntext f increasing retail tariffs ver time, wuld allw Retailers t determine the right pint f entry t suit their business mdel. This wuld allw practical FRC t begin when the market determines that tariffs are cst-reflective, nt when a regulatr determines that tariffs are cst-reflective based n imperfect infrmatin. REMC Page 3

4 Custmer prtectin: Gvernment will need t review the custmer prtectin arrangements t ensure end-use custmers are adequately prtected if electricity FRC is implemented, and t align the mechanisms in the gas and electricity markets t the greatest extent pssible, including: - requiring Retailers t get a custmer s explicit infrmed cnsent befre accessing their persnal data; - putting standard cntacts in place t specify minimum service levels; - putting effective marketing cdes in place t put bligatins n Retailers with respect t issues such as custmer acquisitin, relatinship exit activities, etc.; - prescribing and regulating hardship prvisins; - putting debt management prtectins in place fr vulnerable cnsumers; including prvisins t manage f debt recvery when a custmer churns; and - putting Retailer f Last Resrt prvisins in place t manage the rights f cnsumers and Retailers in in the event f a Retailer failure. REMC has canvassed a number f ther issues that will need t be carefully cnsidered when electricity FRC is implemented, including: Regulatry issues: - netwrk access; - licensing; and - tariff subsidy plicy. Netwrk issues: - retailer access; - systems and prcesses; and - metering. Retail issues: - Synergy dminance; - cst f entry; - cherry picking; and - retailer viability. Legislative Optins Gvernment impacts: - impact n Synergy. Market issues: - WEM peratin and market changes; and - whlesale/retail market interactin. Legislative issues: - the prhibitin n electricity FRC; - implementatin ptins; - market peratins; - the Gas Market Mratrium; - price cmparatr tls; and - standardised business-t-business and business-t-market cmmunicatin rules. Legislatin t implement electricity FRC culd be drafted in innumerable ways REMC has canvassed fur: Electricity Retail Market Schemes: - Replicate the prvisins fr Gas Retail Market Schemes under Part 2B f the Energy Crdinatin Act 1994 and apply them t electricity. New WA-based legislatin: - Develp an entirely new set f bespke legislatin t prvide fr the electricity FRC requirements in WA, ptentially based n the prvisins f the natinal legislatin. Cde-based apprach - Establish a cde r cdes under sectin 39 f the Electricity Industry Act 2004 t prvide requirements fr electricity FRC. Natinal apprach: - Enact the Natinal Electricity Law and Natinal Electricity Rules in WA. REMC Page 4

5 REMC has evaluated the abve legislative ptins using the fllwing criteria: crss-energy cnsistency; crss-jurisdictinal cnsistency; simplicity; and structural benefits. Which ptin shuld be chsen depends n which criteria is determined t be the mst imprtant. Simplicity is the key criteria if a lw cst and quick implementatin is deemed critical, in which case the Electricity Retail Market Scheme ptin may be best. Market Operatr Optins There are fur main ptins fr the WA electricity retail Market Operatr: REMC: - REMC perates the WA gas retail market, s this wuld be a simple, timely, and cst effective ptin t implement and wuld allw market participants t use existing WA retail market systems and prcesses. This ptin wuld als allw REMC t btain synergy frm perating bth the WA gas and electricity retail markets. Independent Market Operatr ( IMO ): - IMO perates the WA whlesale electricity market ( WEM ), s this ptin wuld allw integratin f the WA electricity whlesale and retail market peratins. New WA-based peratr: - A Market Operatr culd be established fr the WA electricity and gas, whlesale and retail markets i.e. a single WA energy Market Operatr that wuld take up the current IMO and REMC rles, as well as electricity FRC. If implemented apprpriately, this ptin wuld have all f the benefits f bth the REMC and IMO ptins. Australian Energy Market Operatr ( AEMO ): - AEMO perates the electricity and gas, whlesale and retail markets in all jurisdictins except WA and NT; and has the expertise and resurces t implement electricity FRC in WA, and culd als take up ther WA market peratins. This ptin wuld likely require replacing all WA-based market gvernance arrangements with the natinal arrangements, and using the natinal apprach t legislatin. The Market Operatr ptin chsen will impact market implementatin and peratin csts. Retail market participants have indicated a strng preference fr a Market Operatr with: a clear respnsibility t industry, accunting fr cmmercial peratin f the market and meeting Gvernment plicy; and a gvernance structure similar t REMC r AEMO, nt a statutry crpratin like the IMO. Electricity FRC Implementatin An rderly transitin t FRC is paramunt fr the success f the market. Implementatin shuld have a lead time f abut 2 years, during which time, industry shuld lead develpment f the FRC rules, guided by Gvernment plicy. Industry shuld decide n the technlgy used t implement the FRC rules, based n cmmercial drivers. The ptin chsen shuld be implemented as a standard that is supprted thrugh the regulatry framewrks. REMC Page 5

6 Cntestability threshlds: There are three ptins fr intrducing greater cmpetitin int the WA electricity market: - make small business and husehld custmers cntestable in tw r mre tranches relating t cnsumptin quantities; - first make all small business custmers cntestable, then husehlds in ne r mre tranches relating t cnsumptin quantities; r - g straight t FRC. Ging straight t FRC is the best ptin because: - csts t develp the systems required t serve any sub-set f the remaining nncntestable custmers will be significant; and - intrducing cntestability t any sub-set f nn-cntestable custmers is unlikely generate sufficient cmpetitin t benefit custmers r be viable fr new market entry. Market Operatr systems and infrastructure: A number f drivers will impact the necessary investment in systems and prcesses by the Market Operatr, including: - the number f cntestable custmers; - the number f cmpeting retailers; - the end-use custmers sphisticatin and knwledge f their ability t churn; and - the prjected number f churns and acceptable churn prcessing time. Market Operatr systems need t be able t manage metrlgy functins t supprt daily - estimatin f basic meters usage; - prvisin f data int the WEM settlement system; and - prvisin f data t Retailers fr billing and recnciliatin. Retailer Systems: Retailer csts t implement electricity FRC will depend n the market structure chsen, particularly the type f cmmunicatin infrastructure i.e. use f the FRC Hub r the NEMbased Hkey Pkey. - The FRC Hub is the used by the WA gas retail market, s mst (if nt all) f the existing active WA-based retailers wuld be able t leverage ff their existing market cmmunicatins infrastructure. - Western Pwer uses the Hkey Pkey fr the WA electricity retail market, s current electricity Retailers will have sme Hkey Pkey systems capability. Hwever, Western Pwer uses an ld and utdated versin f the facility, s it wuld need a substantial upgraded t cpe with FRC. Retailers cmmencing peratin in a new WA electricity FRC envirnment wuld need at least the fllwing infrastructures and business prcesses t perate: - CIS/custmer billing systems; - cmmunicatins infrastructure; - netwrk billing recnciliatin mdules; - WEM prtfli frecasting, trading and settlement facilities; - custmer transfer initiatin, tracking, and CIS interface; - credit risk management prcesses; - marketing infrastructure; - cnnectin/discnnectin plicy management prcesses; and - regulatry cmpliance prcesses. REMC Page 6

7 Western Pwer systems: Western Pwer will need t make significant enhancements t their existing systems and business prcesses t implement electricity FRC, including t: - interval meter reading management systems t enable mre rapid validatin and delivery f interval meter data; - netwrk billing systems t cater fr the impact f daily custmer transfers; - cmmunicatins infrastructure and interfaces with back-end systems t cater fr an increased number f interactins; - Natinal Meter Identifier ( NMI ) discvery supprt; and - asset system infrmatin maintenance t cater fr significantly increased traffic as a result f custmer transfers. REMC Page 7

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