Life support protections are among the most important safeguards in the energy market. For households that rely on energy-dependent medical equipment, interruptions to supply can create immediate risks to health, wellbeing and, in some cases, survival. In this context, Energy Consumers Australia strongly supports an approach grounded in the precautionary principle: where there is a risk of exclusion or administrative error, the system should err on the side of protecting people.
The AEMC’s draft determination demonstrates that it has listened carefully to concerns raised by consumer advocates, health organisations and ombudsmen. In particular, ECA welcomes and strongly supports the Commission’s decision to reject mandatory deregistration, reject the creation of a two-tiered “critical” and “assistive” system, retain Tier 1 civil penalties for all life support breaches, and replace mandatory re-registration with a safer annual check-in process. These changes are critical to ensuring that reforms improve register accuracy without increasing burden or risks for households in vulnerable circumstances.
At the same time, there remain opportunities to strengthen the draft rule further, particularly in relation to multichannel communications, welfare checks, safe-contact protocols, additional monitoring and reporting requirements, and the longer-term development of a Priority Services Register.
The final rule should ensure that no household loses access to life support protections because of an administrative gap, missed form, unanswered reminder or system failure.
Lastly, ECA welcomes the strong alignment emerging between the AEMC and the Essential Services Commission Victoria draft decisions. Consumers should not face a patchwork of different life support processes depending on where they live, particularly where customers move between jurisdictions or where medical practitioners are supporting consumers across state borders. A nationally consistent framework will also make it easier for retailers, distributors, regulators and health professionals to develop common systems, forms and practices.
