We appreciate the opportunity to comment on the National Energy Retail Amendment (Advance notice of price changes) Draft Rule Determination 2018 (the Draft Rule). This letter sets out our response on the Draft Rule and draws from our original submission.

Energy Consumers Australia supports changes to the rules that ensure consumers are notified about price changes and are empowered to respond, as was the clear intention of the proponents. We welcome the Draft Rule applying to standing offers and market offers of both gas and electricity retail contracts and notifying customers of price decreases and price increases.

We also applaud the fact that the notices are to be delivered to customers through the customer’s preferred form of communication (where indicated to the retailer) and require that retailers inform customers on the notice that they can request historical billing and energy usage data to assist them in assessing the impact of the price change.

We do however see real value in additional market research and alternative designs to be considered and incorporated in the Draft Rule, in particular:

• the contents of the Draft Rule are determined by the AER in guidelines developed through behavioural economics research into how consumers respond to the notices; and
• the notice period is at least 10 days to enable consumers to respond to the price changes.

The full submission can be read here.