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to wholesale price risk, which may also inhibit investment in new generation, or increase the cost of any investments. The goal of any intervention must be to improve outcomes for end consumers. While there are potential benefits to requiring vertically integrated players to functionally separate, we must also have regard to potential costs. The ACCC accepts that the market trend towards vertical integration likely reflects competitive advantages of such a business structure, and that vertical integration therefore has the potential to be pro- competitive. Indeed, a number of small and medium sized retailers are vertically integrated, or are pursuing vertical integration. Inquiry into the National Electricity Market – December 2023 https://www.accc.gov.au/system/files/accc-inquiry-national-electricity-market-december-2023-report_0.pdf Supporting Report : Frontier Economics (2023): https://www.accc.gov.au/system/files/accc-inquiry-national-electricity-market-december-2023-report_0.pdf  Second time the ACCC reviewed retail competition taking into account the impact of a changing generation mix on the hedging contract market and the ability of standalone retailers to manage their risks.

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