PIAC responded to the AER’s issues paper on the new retailer hardship policy guidelines. PIAC supports the development of enforceable hardship policy guidelines and the intent of these reforms.
PIAC highlights that the National Energy Retail Law (NERL) protects the rights and interests of all consumers, and supports the specific requirements that Culturally and Linguistically Diverse (CALD) communities have in accessing support from retailers.
We strongly encourage the AER to take the broadest possible interpretation of the scope of the rules in drafting the hardship guidelines, and provide for consistency with the key elements of the Victorian Essential Services Commission Payment Difficulty Framework (PDF), to the greatest extent possible.
We highlight that there is evidence retailers’ fail to consistently meet their minimum requirements in the NER and NERL and that a simpler, more objective and more prescriptive approach to identifying and assisting those in need of support is required.
We recommend the scope of hardship guidelines should support the intent of the National Electricity Rules; that hardship policies reflect minimum requirements set out in the NERL; and key principles for developing standardised statements and hardship policy guidelines.