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CS Ringing Fence

Situation

  • Jemena owns and operates a diverse portfolio of energy and water transportation assets across the east coast of Australia.
  • The Australian Energy Regulator (AER) Ring-fencing Guideline is designed to promote competition by establishing a level playing field for all providers of contestable electricity services. As a business providing services which the Australian Energy Regulator considers monopoly in nature, the Ring-fencing Guideline prevents Jemena from discriminating in favour of their own business (or affiliated businesses) and cross-subsidising between monopoly services and contestable electricity services.
  • The Ring-fencing guideline prohibits Jemena Electricity Networks (JEN) from providing any services other than electricity distribution services. Accordingly, JEN cannot offer or provide any contestable electricity services such as electricity retail services, unregulated electricity infrastructure or private networks, customer-side generation solutions such as solar and batteries or energy consultancy services.
  • To implement Ring Fencing across the organisation, all the processes, procedures and policies were reviewed to identify any changes required to the teams involved in delivered the work.
  • The system access was reviewed to ensure there is no information sharing between the contestable and non-contestable part of the business.
  • Relevant teams were physically isolated to ensure the risks of information sharing is minimised.

Work Performed By Our Team

  • Reviewed the Enterprise core processes at Level 4 (end to end functional views, one level above detailed workflow) to understand the nature of work and identify and implement changes to teams, roles and responsibilities due to Ring Fencing guidelines.
  • Reviewed of Enterprise support processes to identify potential impacted areas and then make the relevant teams aware of the Ring Fencing Guideline implications.
  • Reviewed the enterprise wide procedures and policies (with help from Legal department) and implemented necessary modifications to incorporate Ring Fencing Guidelines
  • Created Business Rules in all the relevant process models in ARIS as reference for awareness
  • Update all the process handbooks to incorporate Ring Fencing compliance guidelines

Value For Client

  • Appropriate controls established in the process artefacts to ensure compliance with the guidelines
  • Awareness created through workshops and discussions with relevant teams about do’s and don’ts
  • Procedures and policies updates with relevant reference to the guideline for awareness and action
  • Changes embedded as part of ongoing monitoring and adhere to compliance requirements
  • Embedded as part of organisation impact assessment for future changes to process, procedure and policies

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