Tips for making a submission
Discuss your submission with us
If you would like guidance for making a submission, you can contact the project team. Contact details can be found on the information sheet for each project. This will allow us to focus our analysis of the issues and to suggest the most valuable feedback to be included in your submission. We welcome setting up meetings to discuss your submission.
Make the most of your resources
Rule changes can vary in materiality and complexity therefore it is important to assess if and to what extent the rule change is likely to impact you as a stakeholder. Speak with the project team to ascertain the most beneficial level of engagement, particularly if you are a resource constrained organisation.
Structure your submission
In our consultation papers and draft determinations we set out an assessment framework indicating the basis on which we propose to assess, or have assessed, the rule change request. It is important for stakeholders to indicate whether they agree/disagree with our proposed assessment framework and why, and then address the issues posed throughout the paper (and any other issues you identify) with regard to the framework or your alternative framework.
Focus your submission on our decision making framework
Under the energy objectives achieving the long term interests of consumers is the overarching objective of any rule change and this forms the basis for our decision making framework. Stakeholders should frame their arguments around how these objectives are likely to be achieved or not.
Assess future impacts
It is useful to include an assessment of what the future impact for consumers will be in the event that the rule is (or is not) made. This can be informed not only by evidence to date but also by theory in fields such as microeconomics and behavioural economics.
Present evidence where possible
Stakeholders insights are strengthened by providing evidence through quantitative and qualitative analysis as well as practical examples of how proposals may or may not work in practice. We do not expect stakeholders to engage in costly evidence gathering however it is important to articulate the substance of the issue and its potential impact on you as a stakeholder. Speculation or assertions are less useful for our analysis.
Explain how your submission adds value
High quality, well-structured and well-evidenced submissions assist us in understanding the key issues and informs our decision making process. We encourage a variety of submissions, but it is the quality of arguments, rather than the quantity received, their individual length, or the party which submits them, that influences our decisions. Identical template submissions made by multiple parties are not given any additional weight.
Submit within the timeframe
It is important that submissions are lodged within the statutory timeframe to ensure we can consider them as part of our decision making. While we endeavour to have regard to submissions received after the closing date, we cannot guarantee they will be given equal consideration to on-time submissions.
Stages of the rules change process
View the different stages of a rule change project
- Making a rule change request
- Consultation paper
- Draft determination consultation
- Final determination
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