We welcome the opportunity to comment on the National Energy Retail Amendment (Preventing discounts on inflated energy rates) Rule 2018 (the Rule). This letter sets out our general comments on the proposal. Our responses to the questions posed in the Consultation Paper (the Paper) are included in the Appendix.

Energy Consumers Australia (ECA) supports the proposal for the Australian Energy Market Commission (the AEMC or the Commission) to expedite the consideration of this rule change. Of course, there remains a need for a bigger, systematic package of market reforms that we have detailed in our submissions to the ACCC Retail Review.

After a ten-year period where the energy prices have doubled, consumers have recently experienced further, very significant price rises. At a time when households and small businesses are doing everything they can to bring their bills down, consumers are telling us they want better information and tools and advice to get control over their costs.

This rule change is part of an important package of retail market reforms being driven by the Prime Minister following his intervention in August 2017, and through the Australian Competition and Consumer Commission (ACCC) Electricity Supply and Pricing Inquiry. Energy Consumers Australia is deeply engaged in this work to reimagine the retail energy market: to bring prices down as quickly as possible, and to drive genuine innovation in services. Australian households and small businesses have a right to expect that their retailers will be transparent about their pricing, will work with them proactively to ensure they’re on the right deal, and will help them manage their energy use. The fact that the current market is in many ways defined by the converse – by complexity and a lack of clarity about offers and prices or ‘noise’ – is what is driving recent interventions by governments. We are convinced that it will take significant, very concrete improvements in the way electricity and gas services are structured and priced to give governments the confidence that the community would support them stepping back from the market.

The full submission can be read here.