Consumer Action, the Consumer Utilities Advocacy Centre and the Victorian Council of Social Service welcome the opportunity to comment on the May 2014 Preliminary Advice from the Independent Reviewer. This joint submission builds upon the points we have raised in our 25 March 2014 letter to you, which we would like to have considered as a constituent part of this submission.
Our organisations are very concerned that while the Preliminary Advice has outlined some important regulatory principles and concerns for the pricing of water, the proposed new regulatory and governance model fails in a number of key respects. This includes a failure to deliver upon the very regulatory principles the Preliminary Advice contends are important, including:
- Economic efficiency
- Transparency, role clarity and accountability
- Simplicity and low regulatory burden
- Independent price setting and oversight
- Consumer engagement, and
We broadly support these principles and the finding in the Preliminary Advice that these principles can underscore an effective regulatory framework. An effective regulatory framework is important to Victorian consumers who rely on an independent and transparent price setting process to deliver efficient and fair water prices.
A PDF of our submission is available by clicking: Economic regulation, governance and efficiency in the Victorian water sector.