SP AusNet Supported a symmetric scheme. Did not consider it appropriate for all NSPs (especially those that had responded to incentives). Stated that the changes to the NER should result in more balanced forecasts and that the ex post review for capex strengthened the incentives to remain within the forecast already. Issue Respondent Comments Symmetry of a CESS Jemena Supported a symmetric scheme similar to that previously applied in Victoria. COSBOA Supported an asymmetric CESS with greater penalties than rewards. Supported the reasons for this in the issues paper. Strength of the CESS reward NSW DNSPs Supported a moderate reward, recognising that a high reward could result in inefficient underspending. EUAA/ CEM Supported a reward of around 35 per cent for all NSPs (that is, government-owned and private NSPs). EnerNOC Supported rewards being equal across opex and capex. Failing that, supported rewards being at least as high as for opex. PIAC Supported a reward at the lower end of the 20 to 30 per cent range due to concerns about capex deferral and over-forecasting by NSPs. Suggested that the power could be increased if the AER's information improved allowing it to determine whether a NSP had deferred inefficiently. SP AusNet Stated that perhaps the current incentives are not strong enough but perhaps 20 to 30 per cent would be a good starting point. CitiPower, Powercor and SA Power Networks Stated that the reward should be the same as for opex so as to limit substitution between the two categories of expenditure. Energex If a CESS is introduced, supported it being low powered. Energex also supported the strength being balanced with incentives for opex and service. Strength of the CESS penalty TEC Supported a penalty that is greater than 30 per cent.
case for excluding 'innovation' costs. ActewAGL Supported the guidelines including principles for determining what can be excluded from the CESS. MEU Supported capex being adjusted for actual growth and achieved replacement before the CESS is applied. CitiPower, Powercor and SA Power Networks Supported capex associated with contingent projects, pass throughs and re-openers being excluded from the CESS. Suggested that the AER develop a defined and agreed list of principles or criteria for capex that could be excluded from the CESS. Grid Australia Noted that demand, the form of price control, the length of the regulatory period and the treatment of less certain projects and unexpected costs can all result in windfall gains/losses. Issue Respondent Comments Exclusions from the CESS ENA Supported the guidelines including a defined and agreed set of principles and criteria for identifying potential exclusions from the CESS with NSPs able to apply for these exclusions. DSDBI Supported adjustments for growth assumptions, labour and materials COSBOA Did not support any exclusions being allowed. Inclusion of the power of the CESS in the guidelines PIAC Supported the power of the CESS (or the method for determining the power of the CESS) being included in the guidelines. CitiPower, Powercor and SA Power Networks Supported the power of the CESS being included in the guidelines with flexibility for higher rewards for more efficient NSPs. Grid Australia Supported the incentive rates (or methodology for determining these) being included in the guidelines. ENA Recommended a range and criteria be included in the guidelines with the specific power to be determined in the framework and