PIAC responded to the Australian Energy Regulator’s (AER) Updating the Network and Retail Exemption Guidelines Consultation Paper. The Guidelines were developed to allow for existing circumstances where the standard network and retail rules could not be practically applied. Despite not being intended, the Guidelines facilitated or created an alternative to a robust rules framework, which has been exploited for the convenience or profit of networks operators and exempt entities. PIAC considers this update process to be an opportunity to ensure that equity and protection for consumer access to essential energy services is restored.
In this submission, PIAC makes a number of recommendations including:
- The use of billing agents should not result in any compromise to consumer protections.
Network parties must join an energy ombudsman scheme.
All embedded networks with residential consumers should be in the registered exemption class, not in the deemed exemption class.
A system of escalating penalties should be imposed on entities that do not comply with their obligations.
The AER’s monitoring and compliance work should include collecting and maintaining details about how many people are covered by network and retail exemptions; the types of business structures that are used; and key indicators of consumer protection.