Tips for making a rule change request
The following tips are provided to assist in submitting a rule change request:
Discuss your proposal with us
Even prior to submitting a rule change request, a useful first step is to informally speak with us. We can:
- assist you in framing your request in the most valuable form and provide best practise examples of previous rule change requests
- help provide advice about the level of detail we require to be contained in your request, review a draft of your request and provide feedback on whether the request meets the requirements for initiation of the rule change process.
Identify the issue
Clearly articulating the issue you are aiming to resolve assists us in identifying the scope of your request:
- a clear articulation of how you propose to address the issue also enhances our analysis of the request
- the inclusion of proposed rule drafting is helpful however it is not a requirement for submitting a rule change request.
Consider whether your request is within the AEMC's powers
Consider whether the AEMC's rule-making powers would enable us to make the rule you seek. It is also useful to consider whether the rule you are seeking may also create the need for consequential or other rule changes under other energy laws.
For example, if your change is under the National Electricty Rules (NER), consider whether an additional rule under the National Energy Retail Rules (NERR) would be required to ensure protections for retail customers continue to be appropriate.
Consider the energy objectives
The AEMC may only make a rule change if we are satisfied that it will or is likely to better contribute to the achievement of the energy objectives - focusing on the long term interest of consumers.
If your request is under the NERR it is also important to consider if it is likely to meet the consumer protection test. Your proposal should outline your reasoning as to why the current rules are not effective in meeting the relevant objective, and how your proposal would be more effective. The AEMC’s decision making framework is explained further in a guide to ‘How the national energy objectives shape our decisions’.
Present evidence where possible
It is always useful to provide qualitative and/or quantitative evidence to support statements of fact included in your request, where possible. Speak with the AEMC to ascertain the level of detail which would be most beneficial at this stage - noting that this is the start of a process of assessment, not the end.
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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