Joint Submission to the AEMC Electricity Consumption Benchmarks Consultation Paper

PIAC provided a joint response to the AEMC’s Electricity Consumption Benchmarks Consultation Paper (the Paper) alongside the Australian Council of Social Service, Victorian Council of Social Service and South Australian Council of Social Service. The paper sought feedback on a rule change proposed by the AER to cease collection of electricity consumption benchmark data. 

We strongly disagreed with the proposed rule change as consumption benchmark data continues to be of use to consumers and to consumer advocates. Electricity consumption benchmarks have been a valuable source of information for households in seeking to understand their energy usage compared to similarly sized households. Benchmark data informs the results for up to 20% of consumers when using the EnergyMadeEasy website. Benchmark data is also useful for energy transition and other government planning.

The proposed rule change is predicated on the removal of benchmarks from bills as part of the Better Billing Guidelines to be implemented from September 2023. Consumer stakeholders did not support benchmarks being taken off bills.

We recommended that a review be conducted into the Better Billing Guidelines at least one year from September 2023 and that the review should include specific testing of consumer responses to the removal of benchmarks from bills.

We also recommended that the AEMC reject the proposed rule change. We recommended that the AEMC make a more preferable rule to require the AER to, in consultation, redesign the benchmarking data collection & publication to increase its utility for consumers, regulators and policy-makers.