We appreciate the opportunity to make a submission to the Draft Rule Determination on the National Energy Retail Amendment (Strengthening Protections for Customers in Hardship) Rule (the Draft Rule).
Energy Consumers Australia supports the draft Rule, which we see as an important component in the suite of policy and regulatory measures ensuring access to affordable energy for vulnerable consumers facing hardship.
Recent research commissioned by Australian Council of Social Service and the Brotherhood of St Laurence underlined the extent of the energy affordability challenge for people on low incomes. A quarter of low income households spend nearly 9% on energy, compared to the highest earning households who spend around 1.5%. Some of the lowest income households – including a quarter of Newstart or Youth Allowance recipients – in Australia now spend more than 10% of their incomes on energy, compared to around 8% a decade ago.
As we noted in our submission to the Consultation Paper, we see a range of benefits for consumers arising from the proposed Rule, including:
• a single point of reference for hardship programs;
• consistency in approach, deriving from the inclusion in all hardship programs of standard
requirements;
• an improved customer understanding of rights and entitlements;
• improved opportunities for AER to monitor performance;
• greater industry clarity over minimum requirements; and
• improved processes for approval and variations to hardship policies.
We support the focus on ensuring consistency of advice to consumers, through a pro forma for retailers setting out their policies, as well as the Australian Energy Regulator standardised statements, outlining in plain English the rights and responsibilities of retailers in the National Energy Retail Law.
That innovation will not only make it easier for consumers to understand their rights, but should also make it easier for consumer representatives (financial counsellors, emergency relief agencies, and volunteers) to assist households experiencing financial hardship.
The full submission can be read here.