Required Amendment#3 – Remove KPIs. (Not supported) The KPIs must be removed from the MSLA. Western Power Response – not accepted for the reasons outlined below: Western Power does not agree with the view that the requirement in the Metering Code that a timeframe is included is inconsistent with the inclusion of a KPI. A timeframe is included for every service. The requirement of clause 6.6(b)(ii) of the Code is met. Whenever Western Power undertakes a service it must seek to complete that service within the specific timeframe. There is no doubt what the timeframe is. However, the KPI reflects the reality that it is not practicable to expect that every timeframe will be met every time. The KPI does not mean there is no timeframe. To address Western Power’s concerns as noted in the following paragraphs but to clarify the issue around timeframes, Western Power proposed the following clause: Timeframes and KPIs “For the purposes of clause 6.6(b)(ii) of the Code, the timeframe for each Metering Service which Western Power must seek to achieve is set out in Schedule 4 and the inclusion of KPIs in Schedule 4 does not extend or change those timeframes.” As the Authority notes, KPIs are included in the existing Model Service Level Agreement. Western Power’s tariffs and resourcing were set on the basis of these KPIs. The Authority must have previously formed the view KPIs were permitted under the Code. Western Power has structured its operations in reliance on that view and is concerned that there is now a change in the interpretation of the Code though there has been no change in the Code itself. In addition to the reasons outlined in our prior submission, Western Power considers that the removal of KPIs is not in the economic interest of customers. That is, the removal of KPIs may result in customers paying more for metering services over time, than they would if KPIs are included. Western Power delivers millions of individual metering services each year via a delivery model which uses a combination of insourcing and outsourcing. The cost of providing services is therefore influenced by competitive market pricing and prudent commercial principles. Western Power has tested the market extensively through multiple tender events over an extended period. Commercial service providers expect targets to be set for the measurement of performance. Where these targets are 100%, service providers, reasonably, expect to be compensated for the additional risk of contract default, as compared to a lower target, f...
