I write in response to your request for feedback on SAPN s electricity tariff reforms. Executive Summary

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1 ABN Level 1, 136 Greenhill Road Unley SA 5061 Telephone (08) Fax October 2015 Ms Jessica Vonthehoff Communications Consultant SA Power Networks GPO Box 77 ADELAIDE SA 5001 Dear Ms Vonthehoff I write in response to your request for feedback on SAPN s electricity tariff reforms. Executive Summary Demand based tariffs are not new with some large electricity user businesses having faced such tariffs for over 15 years, typically manufacturers or irrigators; who have already had to adjust electricity loads as much as possible to reduce costs. The Tariff Structure Statement (TSS) process should be about ensuring all consumers, including small business and residential customers, eventually face similar price signals related to electricity use but only on the basis that the benefits of moving all small consumers to cost-reflective tariffs outweigh the costs. Unfortunately there is insufficient data provided within the consultation paper for Business SA to understand the impacts on small business and whether or not the proposed transition period is adequate. The consumer impact data shows that the majority of small businesses are worse off which does not align with residential air-conditioning use driving peak demand. The South Australian economy is already in a fragile state, even before the exit of auto-manufacturing in 2017, and any moves to impost cost-reflective tariffs on small business which result in an unnecessary cost burden should be avoided. Should you require any further information or have any questions, please contact Andrew McKenna, Senior Policy Adviser, Business SA on (08) or Yours sincerely, Rick Cairney Director of Policy

2 Why this matter is important to South Australian businesses As South Australia s Chamber of Commerce and Industry, Business SA is the peak business membership organisation in the State. Our members are affected by this matter in the following ways: After labour, electricity costs are the largest concern for small business Rising energy costs over the past decade have already impacted significantly on all business, particularly small business. Now that wholesale energy costs in South Australia have almost doubled in recent months, it is even more critical that the TSS process does not unnecessarily impose further costs on small business. Cost reflective tariffs are important to ensure large electricity users who are typically large employers do not have to subsidise the electricity use of smaller consumers. Moving small business to cost reflective tariffs should be done in such a manner so as to ensure the overall system benefits outweigh the transition costs such as installing and operating smart meters. Key Policy Points 1. SAPN advises that: the changes to tariffs being contemplated will not result in SAPN collecting any more or less money in total during the regulatory period what we are talking about is not the size of the pie, but how the pie might be divided more fairly between customers 1 While Business SA acknowledges that the tariff reforms will be revenue neutral for the current regulatory period, SAPN needs to better articulate the long term benefits of moving small consumers to cost-reflective tariffs. For example, in TSS statements already submitted to the AER, Victorian electricity distribution companies have communicated why cost-reflective tariffs will eventually benefit all consumers and what are examples of the types of infrastructure investment which could be avoided through improved load profiles. Interestingly, maps are even provided of the areas which are more likely to require upgrades due to growing peak demand. The TSS process will have winners and losers in the short to medium term but in order to convince small business more broadly that these reforms are necessary, there must be evidence that the transition costs are outweighed by the system benefits. 2. Business SA is concerned that for a material number of business customers, applying new demand tariffs will result in network charges increasing by more than 50% (or total retail bills increasing approximately 25%). 2 1 SAPN, Electricity Tariff Reform in South Australia Consultation Paper, page 2 2 SAPN, Electricity Tariff Reform in South Australia Consultation Paper, page 5 2

3 This appears in contrast with the predictions from Victorian distribution companies who point to no significant adverse impacts on any one particularly segment of customers. While Business SA accepts that SAPN does not have access to universal smart meter data as is available in Victoria, we question the accuracy of SAPN s existing forecasts and if possible, would like to see some modelling based on extrapolating out Victorian data to try and better assess the potential impacts of tariff reform on South Australian small business. 3. In respect to how peak demand periods vary for residential and business customers, Business SA is unclear as to why small businesses are being so heavily impacted by the move towards cost-reflective tariffs when the primary driver of South Australian peak demand is residential demand. In so far as ensuring consistency between States, Business SA notes examples where for Victorian distribution companies, commercial and industrial demand is actually a higher relative driver of peak demand than residential demand. 3 Accordingly, South Australian small business should not be penalised just on the basis of ensuring each State has consistent peak demand tariff periods. 4. In relation to what level of minimum peak demand is required for residential customers, the optimum level should be closest to what reflects SAPN s actual costs, otherwise a cross-subsidy from business customers remains embedded. 5. In terms of whether or not SAPN should send sharp price signals for peak demand, again the price signals need to reflect SAPN s actual costs and provide an incentive for consumers to change behaviour. Price signals also need to flow back to consumers as quickly as possible to ensure optimum time to adjust usage. 6. Business SA does not support special purpose tariffs for any one particular industry sector. Our membership base spans the breadth of commerce and industry and the agenda of cost-reflective tariffs should be to send proper price signals to all consumers in order to eventually eliminate cross subsidies within the existing tariff structures. Notwithstanding, we are sympathetic to the plight of irrigators and other businesses which may find it more difficult to shift loads to avoid peak demand periods. Accordingly, there must be appropriate consideration made for how these consumers are transitioned to full cost-reflective tariffs. This could include consideration of incentives to install technology to reduce reliance on the networks at peak times. 7. Considering businesses employing less than 20 people comprise over 97.6 percent of all businesses in South Australia, SAPN must take particular care to assess the economic impact of tariff reforms on the small business sector. 3 CitiPower, Tariff Structure Statement , page 31 3

4 Recent announcements of large business closures have become far too common in South Australia and the reliance on small business to drive economic growth has only become greater. SAPN must not unnecessarily jeopardise the future growth of small business in South Australia with tariff reforms that unfairly burden the major driver of the State s economy. A strong and growing South Australian economy also supports SAPN s interests and Business SA looks forward to collaborating to ensure the TSS process can both achieve cost-reflectivity in tariffs without impacting an already fragile economy still yet to feel the full force of Holden s closure in If the TSS process is about moving towards cost-reflective tariffs, then the cost burden of residential air-conditioning should be borne by residential consumers, not businesses. 9. The TSS process represents a major reform in energy markets and it will need to be accompanied by a coordinated communications campaign. Considering the rule change imposing cost-reflective tariffs onto small consumers is driven by the Australian Energy Markets Commission (AEMC), the AEMC should coordinate communications which would also ensure consistency across States and distribution networks. It will also be important that South Australian small businesses understand that the policy shift towards cost-reflective tariffs is being driven by COAG policy and not distribution networks alone. 10. SAPN assistance to vulnerable customers should not operate as a direct or indirect subsidy. Subsidies for low income consumers are already managed through Government schemes to ensure consistency in how consumers are classified for assistance. If the State or Federal Government deems it necessary to provide additional assistance for vulnerable customers to transition to cost-reflective tariffs, this is a matter to be considered in a broader social policy context. SAPN s focus on reducing costs for all consumers will provide the most benefit to vulnerable customers. 11. Business SA s reservations around the veracity of the customer impact data provided to date gives us a degree of trepidation in supporting a fast transition to cost-reflective tariffs for small businesses. We acknowledge the installed cost for small customers of a smart meter combined with the cost of managing interval data is estimated to be in the range of $100-$200 per annum during the period to 2020 (approximately 5% of the annual electricity bill for a 10MWh per annum customer) and a positive business case for a smart meter is unlikely for customers below this threshold before SAPN, Electricity Tariff Reform in South Australia Consultation Paper, page 20 4

5 However, we are also mindful that many large businesses which have been on demand based tariffs for some time may have to continue subsidising smaller consumers more broadly if cost-reflective tariffs are not eventually imposed network wide. There will be winners and losers in the TSS process in the short term but ultimately consumers on balance should be better off and the transition should only occur as and when the realistic probability of benefits outweighs the costs of smart meters. 12. In relation to the ongoing metering charges related to smart meters, the benefits to network operators such as SAPN should ensure the metering costs are maintained at an equivalent level to existing accumulation meters after accounting for any amortised cost of capital component. 13. Business SA would support customers having access to at least 12 months of actual demand data before transitioning to a demand based tariff under any transition scenario. Furthermore, at any level of consumption, there should also be an option for businesses to install smart meters and track costs relative to what would exist under demand tariffs until such a time as consumers at their level are required to shift onto a demand based tariff. 14. Business SA supports all new and upgraded meters services requiring the installation of a smart meter but a policy which automatically assigns those customers onto demand based tariffs should enable an opt-out clause for consumers whose level of consumption would not otherwise require them to be compulsorily shifted onto a demand based tariff. 15. In relation to policies specific to solar PV customers, SAPN needs to bear in mind that the solar industry has become increasingly focused on servicing businesses since the closure of small consumer incentive schemes to new entrants and those businesses have made significant investments in the past few years and should not be unnecessarily targeted for tariff changes before other businesses of comparable consumption levels. Additional information: Please see the following link to Business SA s submission to SA Power Networks Regulatory Proposal: SA%20on%20SA%20Power%20Networks%20regulatory%20proposal% pdf 5

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