Hi, Stephen Clarke of EIOSA alerted me to the existance of:
ELECTRICITY DISTRIBUTION PRICE REVIEW: ASSOCIATED REVIEW OF LICENCE
AND CODES DRAFT DECISION April 2005
at
http://www.escosa.sa.gov.au/resources/documents/050502-EDPRLicenceCodeReview_DraftDecision.pdf
which I was unable to locate on the ESCOSA website via the text-only
interface.
I continue to believe that the proposed distribution code's conditions
for payments being made to customers for interruptions to supply and
street lights not repaired in a timely fashion are unfairly restrictive
compared with the "media sound bite" impressions that customers are
eligible for payments when receiving more than a certain number of
interruptions of
*any* duration in a given year or when a street light
faults that the customer was first to report are not repaired in a
certain time-frame
*regardless* of the cause of the fault or party
owning the light.
Payments due to power interruptions.
Whilst at face value the new Clause 5.3 - Service Standards sounds
reasonable in relation to compensating customers for excessive numbers
of interruptions to supply of electricity, I fear that the definition of
"interruption" used by ESCOSA and
*not* defined in the draft descision
will not include customers such as myself who suffer numerous short
interruptions (reclosures) that nonetheless cause significant
inconvenience due to the need to restore computers, appliances on
delayed startup and the like.
If at all possible, the definition of "interruption" should include all
losses of mains power cycles.
If ESCOSA insists on using a definition of "interruption" that is
greater than greater than a certain time length (e.g. one minute), then
that duration should be specified in wherever the term "interruption" is
used, and require that shorter interruptions continue to be monitored by
ESCOSA.
Payments due to street lights not being repaired within stipulated time
frames.
Whilst ETSA Utilities still trumpets "for which we are responsible" in
connection with the street light repair GSL, faults in the supply of
power to TSA-owned street light poles which
*is* ETSA Utilities'
responsiblity are
*not* currently covered by the street light SGL. As
far as I know, the range of faults for which the GSL is payable is
restricted to "luminaire", although again the term "luminaire" is not
used in the draft decision. (As an example, the street light in front of
229 Fullarton Road Eastwood was not working for several months until an
underground power supply fault was fixed and I received no GSL payment).
Furthermore, ETSA Utilities have told me that they would not implement
ESCOSA's suggestion of arranging for payments for late repairs that they
are contracted to provide to TSA, claiming that ETSA Utilities treat
ETSA Utilities owned streetlights and TSA owned streetlights with equal
priority. Even allowing for this, this does not help situations like the
TSA street light failure in front of the Shell service station on
Fullarton Road Rose Park that I reported FOUR TIMES OR MORE to ETSA
Utilities and was only fixed after I reported the failure directly to
TSA. People reporting street light failures should not have to
repeatedly report the same fault. At the time of this submission, there
are still many TSA owned street lights along Main North Road not working
due to faults in ETSA Utilities' power supply and they do not seem to be
getting repaired in a timely fashion.
If the faults covered by the street light GSL are only for failure to
replace the "luminaire" on ETSA Utilities' owned street lights, this
should be spelled out in the distribution code at the first mention of
the street light GSL.
I would far prefer the street light GSL to cover ETSA Utilities owned
street lights and TSA owned street lights equally. If not, the
distribution code should spell out which street lights ETSA Utilities
are responsible for (e.g. all lights on stobie poles) and which street
lights ETSA Utilities are not responsible for.
I would far prefer the street light GSL to cover all faults that could
cause street lighting to fail (supply, physical post, daytime sensor,
light itself) instead of just "luminaire".
I have been unable to obtain a copy of the agreement between ETSA
Utilities and TSA (CLER tariff arrangement) and would hope that ESCOSA
will take action to publicise it.
I take issue with ETSA Utilities idea of restricting the area that a
person could report street light failures. Too many areas have locals
not taking it upon themselves to report local street light failures.
Regards,
Arthur Marsh
PO Box 372
Blackwood SA 5051
ph 0417 852 110