Reset Precedents
AER electricity network determinations, line by line, cited to the page

For network regulation teams and regulatory economists preparing a reset

What did the AER cut last time, and what evidence won it back?

For each line item, Reset Precedents shows the network's proposal, the AER's draft decision, the revised proposal and the final decision, with the AER's reasons. Every figure links to the page of the AER PDF it came from.

Example from the data

Ausgrid, total ICT capex, 2024–29

$m, $2023–24, 5-year total. Click a figure to open the AER page.

  1. Proposal301.1
  2. Draft decision205 −32%
  3. Revised proposal272.6
  4. Final decision272.6 accepted

Ausgrid won back $65.3m of ICT capex after it reworked its ERP cost-benefit analysis. The AER's final decision prints the revised figure as $65.3m above the draft (Final Att 5, p.13).

The ERP replacement went from $76m proposed to $4.2m at draft, for "modelling bias", "excessive costs", "deliverability risk" and "contingency costs". $58.9m was accepted at final after three changes:

  • NPV benefits limited to the 15-year asset life
  • delivery staged over 7 years instead of 5
  • contingency removed
1 of 3

draft cuts to cyber security (AESCSF) opex step changes took effect. The AER found a lower amount for 3 of 7 step changes at draft. Only Ausgrid's applied, because its total opex was substituted (Draft Att 6, p.4). The two TasNetworks cuts were not applied, because the AER accepted both totals as "not materially different" (dist. p.4, trans. p.4).

304

cited rows from 10 resets. Each row has:

  • the figure as printed, with its stated dollar basis
  • the same figure in $2024–25 real
  • what happened to the money, with reason codes
  • the verbatim quote and the PDF page
Read the two memosSearch the 304 rows

Two sample memos

Precedent memos across 10 resets

Each memo covers the same 10 resets: Ausgrid, Endeavour, Essential, Evoenergy, TasNetworks and Power and Water (PWC) distribution 2024–29, TasNetworks transmission 2024–29, and Energex, Ergon and SA Power Networks (SAPN) distribution 2025–30. Blue citations open the AER PDF at the cited physical page; hover for the full document name. Grey row IDs open the row in the explorer below.

Memo A

Cyber security and AESCSF opex step changes

What the AER cut, what it applied, and the grounds for acceptance.

Step changes were proposed in 6 of the 10. The other 4 proposed none.

  • Dollar figures use each document's stated real basis.
  • "Not applied" means the AER computed a different figure, but accepted the network's total, so its figure did not set the approved amount (decision_status = finding_not_applied).
  • "Computed" marks our own arithmetic.

Headline findings, with the evidence count for each

  1. 7 step changes were proposed in 6 resets: one each for Ausgrid, Evoenergy, PWC, TasNetworks distribution and TasNetworks transmission, and two for SAPN (uplift and operationalising). 0 of 7 were rejected outright.
  2. At draft, the AER found a lower amount for 3 of 7, but only 1 cut took effect (Ausgrid, whose total opex was substituted (Draft Att 6, p.4) [R043]).
  3. The draft reductions had different grounds; not all were about cost.
    • Ausgrid: the AER found the maturity target (full SP-3) "unnecessarily onerous", and also judged the resourcing costs high (Draft Att 6, p.32) [R037].
    • TasNetworks (both networks): specific cost items. Unsupported roles were removed, and 30% contingency was replaced by 20% escalation (Draft Att 6, p.27; Draft Att 6, p.24) [R275, R295].
  4. AESCSF as "guidance, not an obligation" is stated explicitly in 4 of the 6 resets: Ausgrid (Draft Att 6, p.32; Final Att 5, p.16) [R037, R033], TasNetworks distribution and transmission (Draft Att 6, pp.28–29; Draft Att 6, pp.24–25), and SAPN (Draft Att 6, p.34) [R247].
    • It is not said for Evoenergy, whose documents never mention the AESCSF. Evoenergy's step change was accepted on its SOCI Act obligation (Final Att 6, p.47) [R182].
    • It is not said for PWC either. There the AER simply found SP-2 "prudent" for a distributor (Draft Att 6, p.25) [R217].
  5. Grounds for acceptance (6 resets):
  6. Placeholders: 2 of 6. In Evoenergy and PWC, the draft included the proposed amount as a "placeholder" because it could not test confidential information or cost detail (Draft Att 6, p.52; Draft Att 6, p.25) [R183, R217].

Each step change

Network (basis)ProposedDraftRevisedFinalNotes
Ausgrid D ($2023–24)20.6 (Draft Att 6, p.32) [R036]19.0, −7.8% (Draft Att 6, p.32; Draft Att 6, p.34) [R037, R041]; applied18.1 (Final Att 6, p.17) [R038]18.1 (Final Att 6, p.17; Final Att 5, p.16) [R039, R040]Final: once the AER adjusted the model, the preferred option "presents the highest NPV"; SP-3 is still not an obligation (Final Att 5, p.16) [R033]. EMCa was the consultant.
Evoenergy D ($2023–24)14.6 (Final Att 6, p.48) [R180]14.6 placeholder (Draft Att 6, p.52) [R183]15.0 (Final Att 6, p.48) [R181]15.0 accepted (Final Att 6, p.47) [R182, R184]Accepted on an updated business case and modelling, an EMCa review, and the Security Legislation Amendment (Critical Infrastructure Protection) Act 2022.
PWC D ($2023–24)4.4 (Final Att 6, p.18) [R214]4.4 placeholder (Draft Att 6, p.25) [R217]5.0 (Final Att 6, p.19) [R215]AER 4.9, not applied; total opex 387.2 accepted (Final Att 6, p.18; Final Att 6, p.5) [R216, R222]4.9 is the 5.0 re-indexed for inflation. The revised rise from 4.4 to 5.0 corrected a transcription error.
TasNetworks D ($2023–24)3.9 (Draft Att 6, p.27) [R274]AER 2.8, −1.1, not applied (Draft Att 6, p.27) [R275, R276]not printednot printed; total 541.0 accepted (Final Overview, p.37) [R281]
TasNetworks T ($2023–24)15.4 (Draft Att 6, p.23) [R294]AER 11.0, −4.4, not applied (Draft Att 6, p.24) [R295, R296]not printednot printed; total 209.2 accepted (Final Overview, p.39) [R302]
SAPN D: uplift ($2024–25)47.6 (Draft Att 6, p.30) [R246]47.6 included (Draft Att 6, p.34) [R247]not printedAER model 47.4, not applied; total 2,036.2 accepted (Final opex model, cells O77:S77; Final Overview, p.29) [R303, R261]
SAPN D: operationalising ($2024–25)17.4 (Draft Att 6, p.34) [R250]17.4 included (Draft Att 6, p.34) [R251]not printedAER model 17.3, not applied (Final opex model, cells O80:S80) [R304]A capex-to-opex reclassification (RECLASS), not SaaS.

Resets with no cyber step change (4 of 10)

Search for the missing final figures

  • SAPN: the AER final opex model (CC BY, xlsx) holds the AER's figures in sheet Calc|Opex forecast: O77:S77 for the uplift and O80:S80 for operationalising (Final opex model, cells O77:S77; Final opex model, cells O80:S80) [R303, R304]. These are the AER's alternative-estimate figures. SAPN's own revised amounts are in no AER file we found.
  • TasNetworks: the sitemap lists only draft opex models (Sept 2023). We found no final AER opex model and no RIN workbook on /documents/.
    • TasNetworks’ revised proposal (p.26) says it "accept[s] the AER's draft decision on our total opex". This is third-party material, recorded as fact only.
    • So no final cyber figure exists in the AER files we can reach.

Memo B

Non-network ICT capex: cuts at draft, and what won money back

Which draft cuts took effect, and the evidence that recovered funding at the revised proposal.

  • The AER approves only total capex. ICT amounts are its findings, not allowances.
  • "Applied" means the AER's finding went into a substituted total (decision_status = finding_applied).
  • "Not applied" means the AER accepted the network's total anyway (finding_not_applied).
  • "Computed" marks our own arithmetic.

Headline findings, with the evidence count for each

  1. Draft ICT cuts that took effect: 4 of 10 resets. These are Ausgrid, PWC, Energex and Ergon. In each, the AER substituted total capex (Draft Att 5, p.6; Draft Att 5, p.5; Draft Att 5, p.6; Draft Att 5, p.7) [R002, R194, R073, R106].
  2. The AER found a lower ICT-related figure in 2 more resets, but did not apply it, because total capex was "not materially different":

    Neither is counted as a cut.

  3. Money won back in the revised proposal: 2 of the 4 cuts (Ausgrid, PWC).
  4. All 4 applied cuts cited business-case, NPV or options-analysis weaknesses (BCASE). Two other reasons also appear:
    • Contingency was a reason in 1 applied cut (Ausgrid). It also appears in both unapplied findings (TasNetworks transmission, Endeavour).
    • Deliverability was a reason in 1 cut (Ausgrid).
  5. Recurrent ICT was accepted in all 4 resets where the AER assessed it separately: Ausgrid (Draft Att 5, p.13 (printed p.10): recurrent forecast "more than 20% below" 2019–24) [R023], SA Power Networks (Draft Att 5, p.13 (printed p.10): "approach to forecasting recurrent ICT to be reasonable"; repeated on p.48), TasNetworks distribution (Draft Att 5, p.12) [R268] and Evoenergy (Draft Att 5, p.10) [R174]. The Evoenergy evidence is weaker: the AER relies on the total being "largely in line with" current spend and "over 40%" being recurrent, with no separate recurrent finding. The other documents print no separate AER view on recurrent ICT.

The 4 applied cuts

Ausgrid D ($2023–24)
Initial
301.1 total ICT (Draft Att 5, p.16) [R022]; 278.4 category (Draft Att 5, p.12) [R014]
Draft finding (applied)
205 (Draft Att 5, p.16) [R023]; 191.3 (Draft Att 5, p.12) [R015]
Cut
−$96m (−32%) (Draft Att 5, p.16) [R026]; −87.2 (−31%) (Draft Att 5, p.12) [R016, R017]
Revised
272.6 (Final Att 5, p.13) [R024]
Final
272.6 accepted (Final Att 5, p.13) [R025]; category 264.5 (Final Att 5, p.10) [R013]
Draft reasons
ERP: "modelling bias", "excessive costs", "deliverability risk", "contingency costs"; EMCa. ERP cut from 76 to 4.2 (Draft Att 5, p.16) [R006, R008].
Evidence that won money back
The revised figure was $65.3m above the draft (Final Att 5, p.13). ERP 58.9 was accepted (Final Att 5, p.13) [R011] after three fixes: NPV benefits limited to the 15-year asset life, a 7-year staged delivery, and contingency removed. SaaS: the revised proposal moved $131.2m of SaaS to capex; the AER put it back in opex (Final Att 5, p.7; Final Att 6, p.5) [R003, R044].
PWC D ($2023–24)
Initial
70.7 (Draft Att 5, p.8) [R198]
Draft finding (applied)
48.6 in Table 5.4 (Draft Att 5, p.10) [R199]; 48.2 in text (Draft Att 5, p.18) [R207]
Cut
not printed; computed −22.1 (−31%)
Revised
64.0 (Final Att 5, p.16) [R208]
Final
64.0 accepted (Final Att 5, p.16; Final Att 5, p.10) [R209, R200]
Draft reasons
"No cost benefit analysis was undertaken" for the OT Capability Uplift ($21.6m (Draft Att 5, p.19) [R205]).
Evidence that won money back
A new business case and CBA for the OT uplift (15.8 accepted (Final Att 5, p.17) [R204]), plus an itemised cyber cost build-up (Final Att 5, p.18) [R210]. Computed: 15.4 won back. Basis: the final table is labelled $2022–23, but the overview prints the same table as $2023–24. We convert as $2023–24, giving 65.3 at $2024–25 (Final Att 5, p.10) [R200].

Not cut (6 of 10)

The data behind the memos

Explore all 304 rows

Filter, search, then open a row to read the verbatim AER quote, the reason quote and our notes. Row IDs are stable, so you can cite them.

RowNetworkPeriodTopicStageFigure (stated basis)$m, $2024–25 realDecision statusReason codesSource

Decision status: what happened to the money

included_as_proposed
The network's figure is inside the AER's total.
included_total_nmd
Included only because the AER's different estimate was "not materially different" at total level.
placeholder_included
A provisional amount.
finding_applied
The AER's own figure went into a substituted total.
finding_not_applied
The AER's figure differed, but it accepted the network's total, so the figure did not set any amount.
total_accepted
The AER accepted the network's total forecast.
total_substituted
The AER substituted its own total.
n/a
Proposals and comparisons.

The AER approves a total, not categories. Filter on decision status to find the amounts that were approved.

Reason codes

Coverage

10 resets done, 32 in scope

The 10 extracted resets are all 9 distribution resets decided in 2024 and 2025, plus TasNetworks transmission. The list below holds every AER electricity network determination with a final decision in 2019–25. Names link to the AER final decision overview.

10resets fully extracted
32determinations in scope, 2019–25
37AER PDFs, plus 1 AER Excel model, behind the rows

Distribution (23)

Transmission (9)

How much to trust this

What was checked

Two independent AI reviewers checked the data against the source PDFs. One was briefed as a general manager of network regulation, the other as a regulatory economist. Each chose rows at random. These checks were done by AI reviewers against the AER PDFs, not by a human auditor.

175rows audited against the PDFs
1conversion error found (it affected 3 rows), now fixed
302 / 302PDF rows pass our mechanical check

Mechanical check: the value and at least 90% of the quote's words are found on the cited page when it is re-read straight from the PDF. The 2 Excel rows match the AER model cell by cell.

Dollar basis

The stated basis is kept exactly as printed. We convert to $2024–25 real with ABS CPI, All groups, Australia, series A2325846C (6401.0), June-quarter index. An AER "$YYYY–YY" figure is read as June dollars.

Stated basisCPI (June qtr)Factor
$2022–23133.7 → 141.7×1.0598
$2023–24138.8 → 141.7×1.0209
$2024–25141.7×1.0000

When two AER documents label the same figures differently, we keep the printed label, flag the conflict, and convert on the label that a second AER source confirms. This applies to 15 rows (Evoenergy, PWC, Ausgrid).

Known limits

  • 257 rows were first extracted by AI agents. Labels such as stage, reason code and status were re-checked in a separate pass on 30 rows, plus the AI reviewers' sample. No human has audited them yet.
  • 29 rows record inconsistencies inside the AER documents (wrong basis labels, text that differs from a table, "$2024–24" typos). We keep these as printed and say so in the notes.
  • Where the AER accepted total opex, no AER file gives the network's revised cyber step change. For SAPN the final opex model gives only the AER's own figures; for TasNetworks we found no final opex model.
  • ICT category definitions differ by network, so compare like with like.
  • Consultant reports (such as EMCa's) were not read. One AER Excel model (SAPN final opex) was.
  • 22 of the 32 in-scope determinations are listed only.

What a pilot looks like

Complete the 2019–25 record

Scope

  • All 32 AER electricity network determinations with final decisions in 2019–25, extracted to the same row standard.
  • Capex categories and opex step changes, at all four stages: proposal, draft decision, revised proposal, final decision.
  • Memos like the two above, on any topics you choose.

What you get

  • The full row set, each row with the verbatim quote, AER reason, reason codes and PDF page.
  • Figures as printed and in $2024–25 real, with basis conflicts flagged.
  • This explorer for your team, with stable row IDs to cite in submissions.

Price

Pilot, fixed priceA$25k
After the pilotSubscription
Consultancy licenceabout A$20k/yr

To start a pilot or ask a question, reply to the email this link came in.