Our elected representatives need to act now and make decisions that prioritise equality, opportunity and wellbeing for every person in every community.

Submission to the Australian Energy Market Commission: Rule change request to make energy bills clearer

On 17 April 2020, the Australian Energy Market Commission (AEMC) received a rule change request from the Minister for Energy and Emissions Reduction, the Hon Angus Taylor MP, to amend the National Energy Retail Rules (NERR).

The rule change proposal seeks to simplify energy bills, so households and small business owners can better understand and manage their bills, and find a better energy deal. It covers both gas and electricity bills.

Under the NERR, retailers are required to prepare an energy bill complying with 26 content requirements. The proponent considers the rules should be changed to contain an objective and outcome-based principles for energy bills, which would underpin a mandatory Australian Energy Regulator (AER) guideline with specific requirements on content and format.

QCOSS supports the stated aim of the proposed rule change to simplify energy bills. In the case of energy, we know that the market itself can create or exacerbate vulnerabilities and hardship. Energy bills are one part of this.

Read our full submission.

Submission to the Review of Queensland Energy Legislation Part 2

Energy is an essential service. Australia’s energy system exists to serve the community and underpins much of our lives, including heating and cooling our homes, powering medical equipment, cooking food and powering our transport. The overarching purpose of energy legislation should be to support the provision of this essential service in an affordable and fair manner, including to transition fairly to a zero-carbon economy.

QCOSS welcomed the opportunity to make a submission to the Review of Queensland Energy Legislation Part 2: Options paper – A consultation paper containing detailed regulatory impact statements, October 2019.

It is QCOSS’ view that while unnecessary duplication between state and national energy laws needs to be removed, it is our view that some state government oversight of consumer protections, pricing and regulation is necessary to ensure all Queenslanders continue to have access to fair, affordable and sustainable energy. Consequently, there remains a need to keep broader policy objectives and state powers in the Queensland legislation.

It is also QCOSS’ view that distributed energy resources, energy efficiency and demand management are significant opportunities to improve health and affordability for low-income and vulnerable households. These households experience a greater proportional impact on living affordability through energy bills, unhealthy homes and fewer opportunities to participate in a fair transition. Such needs of low-income and vulnerable households are not adequately addressed through national laws and programs, but can be addressed through state-based legislation.

Read our full submission here.

Submission to the Draft Determination on the Default Market Offer Price 2020-2021

The purpose of the Draft Market Offer is to protect consumers from high prices. Regulators often prioritise competition and the AER sets out a policy objective is to “incentivise competition, consumer engagement, innovation and investment”.

QCOSS’ position is that competition should not be an objective in and of itself, but rather the pathway through which affordable and transparent prices are achieved.

Unfair competition, poorly designed incentives, lack of or poor engagement with consumers, poorly targeted innovation and inefficient investment, risks increasing the vulnerability created by the energy market.

As an essential service, consumers should not be expected to continually shop around in order to achieve affordable prices.

Read our full submission here.

Submission to Consumer Protections in an Evolving Market: New Energy Products and Services – 2020 Retail Energy Competition Review

As an essential service, it is important that every person has access to affordable electricity. Unfortunately, our 2019 Living Affordability in Queensland report found that many people do not have enough money to get by, especially in regional areas where the cost of living can be higher.

People on low incomes spend a higher proportion of their income on essentials, such as housing, food, electricity, transport, phone and internet services.

As these financial pressures increase and energy resources become increasingly decentralised, regulation must provide enough consumer protections that support every person; reduce and prevent vulnerability; and ensure no one is left behind. These objectives must be front of mind for the Australian Energy Market Commission (AEMC).

Read our letter to Australian Energy Market Commission.

1 December 2020