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Submission on the AER Draft Consumer Vulnerability Strategy

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Energy Consumers Australia

We are pleased to provide feedback on the Draft Consumer Vulnerability Strategy put forward by the Australian Energy Regulator (AER).

This strategy has the potential to play a critical role in addressing the impact of energy costs on people’s lives. There is already an energy divide, where people living in inefficient housing, who don’t have rooftop solar or storage, can face disproportionately higher energy bills – improving affordability must therefore be front and centre.  

Our submission calls out the structural nature of energy poverty, noting that these problems cannot be solved in the energy system alone and that successful action needs to involve broader issues such as housing, tenure and income

Future changes in the energy system could further widen the divide between those with resources and access to technology and those without. New energy technologies and services require consumers to have different capabilities – to have the capacity to understand which technologies or services will generate benefits to them, the financial means to buy them, and the technical literacy to use them in the right way to secure those benefits.  

We urge a reframing of the regulatory framework to start with the consumer and their experience, taking a holistic view of the ‘market for energy’ rather than adapting existing frameworks. 

Consumers experience vulnerability – it is not a personal characteristic. People can experience it in one situation, but not in others. There is, however, a danger that when labels such as ‘vulnerable’ or ‘hardship’ are used in communications with consumers, they carry a stigma and can cause shame or embarrassment. That can lead to consumers being reluctant to seek the assistance they need. 

Using the framing of resilience provides an opportunity to avoid perceived implications in the use of the term ‘vulnerability’ — lessening a sense that the people and businesses to be assisted are in some way marginal or impaired. We prefer to employ the concept of resilience, which signifies a capability to withstand adversity now and into the future, and better aligns with the Strategy’s focus on ensuring that the energy market meets the need of consumers.

Our submission supports the overall outcomes and actions outlined in the Strategy, including improving service delivery and design through better leveraging of retailer data to identify and offer help to consumers, empowering consumers through providing more information on the service they can expect from a retailer, minimising disconnections and helping build consumers’ trust and confidence in the market. 

We welcome the Strategy’s emphasis on consumer research to inform the AER’s decisions, and to co-designing solutions with consumers, informed by their experience. Such changes are essential to an accessible, inclusive, affordable and fair energy transition. 

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