Submissions

We agree there are opportunities to improve billing to deliver simpler, more understandable bills for energy consumers.

Our submission suggests that the Guidelines assess business conduct from a consumer perspective, and take a holistic view of conduct, noting the market is working to put consumers at its centre.

Energy Consumers Australia encourages the Australian Energy Market Commission to reject the rule change and ensure AEMO fees are subject to the same scrutiny as other network costs.

We support the proposed rule change in principle, as a mechanism that underpins the AER’s Statement of Expectations.

Despite its name, function, and intent, our understanding is that during the market disfunction in June 2022, the Administered Price Cap did not actually cap or reduce prices. As a result, this letter, representing our submission on this rule change, makes three primary points.

The flexible trading arrangement (FTA) rule change, proposed by the Australian Energy Market Operator (AEMO), has been positioned as a way consumers can access more value from their CER, by incentivising flexible demand that can support the operation of the system, while not needing to change their behaviour for their everyday electricity use.

We commend the AEMO team on the effort and time taken to produce an IASR that is clearly a step forward from previous versions.

The lack of clarity on how competition benefits interact with DER and the electrification already assumed in scenarios underline the need for a more exhaustive consultative and evidence-finding process

We have several concerns with the direction of the Draft ISP, which we detail in this submission.