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 framework should prioritise consumer safety over register “accuracy”.
ECA welcomes the ESC’s decision to:
- reject a two-tier “critical” and “assistive” framework
- retain equal protections for all life support customers
- reject mandatory four-year re-registration requirements
- maintain retailer discretion not to deregister households who have not provided medical confirmation, while requiring record-keeping of reasons for retaining customers without medical confirmation
- introduce annual check-ins
- allow for secondary contacts and preferred communication methods include gas customers within the reforms
ECA supports the direction of the draft decision and encourages the ESC to make several targeted improvements before finalising the reforms, including:
- introducing stronger multichannel communication requirements
- requiring welfare checks and safe-contact protocols
- considering broader medical confirmation pathways
- providing guidance on “life-threatening conditions”
- strengthening reporting requirements for retailers and distributors
- ensuring compatibility with a future Priority Services Register.
The final framework 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 Essential Services Commission and the AEMC 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.
