We welcome the opportunity to comment on the Draft Benefit Change Notice Guidelines (the Guidelines). This letter sets out our general comments on the Guidelines. Our responses to the conclusions reached in the Notice of Draft Instrument (the Notice) are included in the Appendix.

Energy Consumers Australia supported the Rule Change that inserted rule 48B in the National Energy Retail Rules (NERR). This requires retailers to notify a small customer via a benefit change notice when a benefit provided to them through their market retail contract is expiring or changing.

Of course, in addition to that Rule Change and more recent Rule Change proposals there remains a need for a bigger, systematic package of market reforms as we have proposed in our submissions to the Australian Competition and Consumer Commission (ACCC) Retail Electricity Price Inquiry (the ACCC Inquiry).

After a 10-year period where electricity prices have doubled, households and small businesses are doing everything they can to bring their bills down. These small consumers are telling us they want better information and tools and advice to get control over their costs.

These Guidelines form an important part of a package of retail market reforms being driven by the Prime Minister following his intervention in August 2017, and through the ACCC Inquiry. Energy Consumers Australia is deeply engaged in this work to refocus the retail energy market on much better outcomes for consumers: to bring prices down as quickly as possible and to drive genuine innovation in services.

The full submission can be read here.