Submission to AER’s Retailer Authorisation and Exemption Review: Issues Paper’ Alternative formats available on request to PIAC - Contact PIAC
PIAC made a submission to the Australian Energy Regulators’ (AER) ‘Retailer Authorisation and Exemption Review (the Review): Issues Paper’ (the Paper). The Paper outlined an intent to assess the adequacy of the current energy consumer protection framework through the introduction of new products and energy services.
PIACs submission recommended the Review more robustly consider existing outcomes for consumers and examine the effectiveness of regulation and protections in delivering outcomes for consumers now, before examining future implications. We noted our concerns that the Review was too narrowly focusing on market mechanisms and was underpinned by a range of flawed assumptions. Our submission included:
- Discussion on the definition and implications of the essentiality of energy
- Comments on the relationship between consumer protection, regulation, and innovation
- Caution in relation to assumptions regarding consumer uptake of distributed energy resources
- Highlighting consumer harm in embedded networks
- Responding to the AER’s Objectives in undertaking the Review
- Recommending the AER re-evaluate and update the Consumer Risk Assessment tool
- Detailed responses to specific questions in the Paper
Altogether, these comments urged the AER to significantly alter the scope and framing of the Review to better consider the enduring needs of consumers and focus on improved outcomes for all consumers.