PO Box 372
                        Blackwood SA 5051
                        Ph 0417 852 110


Attention Guaranteed Service Level Review

Hi, I read parts of the Draft 2005 to 2010 Electricity Distribution Price Determination, yet have found no details of the proposed Guaranteed Service Level covering public street lighting and compensation for customers suffering excessive numbers or duration of power disruptions.

As someone who has experienced the failure of the current street light reporting and maintenance system and at least 8 power supply disruptions in recent months I would like to make some comments and suggestions.

THE CURRENT "LIGHT-HANDED" SYSTEM OF REGULATION DOESN'T WORK.

My recommendations on public street lighting:

1. Inform the public of their rights to adequate street lighting on:

residential and commercial/industrial streets,

main roads, and

other particular areas (walkways, level crossings, bridges).

This should include a number of user-friendly methods for the public to comment on the adequacy of street lighting in particular areas with easy  means to follow up on what action has been taken on their comments.

2. Have a uniform, no-exceptions, across-the-board code for the maintenance of public street lighting:

a number of user-friendly options to report street light failures (including intermittent failures) that provide easy means to follow up on the progress of maintenance;

if the responsible party for first attending the street light failure and replacing globes is unable to identify the reported street light, the person reporting the failure is sent a map of the vicinity identifying all street lights in the area so that the reporter can clarify which street light was being reported;

if the responsible party for first attending the street light failure and replacing globes does not undertake their duties within 5 working days, including notification of other parties if the globe replacement does not restore operation of the street light, the person reporting the street light failure is eligible for a credit for each 5 working day period from report to either:

street light restoration by globe replacement, or

notification to other responsible parties, and

is informed of the progress of the maintenance of the street light, INCLUDING UNIQUELY IDENTIFYING THE STREET LIGHT CONCERNED AND PARTY OR PARTIES RESPONSIBLE FOR MAINTENANCE;

if other maintenance beyond globe replacement is required, there is a defined period (from the time of the original report) for the restoration of the operation of the street light. If this period is exceeded, the reporter is paid per period and informed of the progress of the restoration of the operation of the street light INCLUDING UNIQUELY IDENTIFYING THE STREET LIGHT CONCERNED AND PARTY OR PARTIES RESPONSIBLE FOR MAINTENANCE; (this should include pathological cases like the Shepherds Hill Road overpass where the original lighting had to be replaced by more conventional street lighting more than a year after I reported failures in the original street lighting);

failure of the party responsible for receiving street light reports to provide traceable references to be investigated by a regulator with the possibility of fines.

3. Have a publicly accountable system of patrolling for street light failures along Transport SA-controlled roads.

ETSA Utilities and Transport SA have been unable to provide me with details of patrols along Transport SA-controlled roads.

If there is supposed to be regular patrols of Transport SA-controlled roads for street light failures, and there is a failure to effectively maintain street lights along any such roads, the responsible party should be fined at a level where there is clear incentive to undertake adequate patrols rahter than risk being fined;

If there is not supposed to be regular patrols of Transport SA-controlled roads for street light failures, steps should be taken to make identification of failed street lights by members of the public easier.

My Recommendations on Service Guarantees for supply of electricity:

1. There should be real-time monitoring of momentary and extended interruptions to electricity supply with the data publicly accessible (eg on the internet and by telephone).

2. There should be a threshold level of less than twice the statewide mean level of disruptions (in either number or duration) beyond which the affected customers are due for credits which give ETSA Utilities incentive to provide preventative measures (eg covering all exposed 240V switchgear on stobie poles in areas subject to disruptions due to possum electrocutions on exposed 240V switchgear).

My Recommendations on the behaviour of ETSA Utilities:

1. Follow up on all requests for contact regarding street light failures and power disruptions, with penalties for failure to follow up.

2. Honour their own undertakings to get back in touch with members of the public with fines by the regulator for failing to do so. (So far, *** ********, *** ********, ***** ******* and ***** **** of ETSA Utilities have failed to get back in touch with me as promised).

Regards,

Arthur Marsh.