We are pleased to see the Essential Services Commission (ESC) reviewing the Energy Retail Code of Practice (ERCOP), to ensure that consumer protections are fit for purpose, better align with other jurisdictions and instruments, as well as respond to the Victorian commitment to move away from fossil fuel gas use in the home and in small businesses.
Our submission provides specific recommendations in response to the Paper’s questions around:
- Protection for consumers experiencing vulnerabilities
- Supporting the choices of energy consumers
- Pricing and contract protections
More broadly, we would like to see the Essential Services Commission (ESC):
- Ensure equitable protections for all households and small businesses, regardless of whether they are in an embedded network. This includes interrogating pricing and service practices for loyal or ‘legacy’ customers, whether they are fair, or if intervention is required.
- Critically evaluate the application of the Energy Retail Code of Practice and hold retailers to account where they are failing to deliver good outcomes for consumers.
- When assessing the costs and benefits of potential changes, develop and adopt a weighting system that reflects the essentiality of energy and weighs the benefits to consumers on a higher scale than the cost to retail businesses. Energy is an essential service, so retailer implementation costs should not guide whether or what support people experiencing or at risk of payment difficulty are offered, or how retailers adequately meet their obligations.