AER Submission – Draft Exemption Selling Guide

Submission to Australian Energy Retailer Consultation on Draft Exempt Selling Guideline (August 2011)

COTA is concerned that the growth of on-selling has the potential to disadvantage older people as they move from detached housing into a range of accommodation arrangements. Living in apartment complexes, residential parks and some retirement villages often involves purchasing energy from an on-seller.

While COTA welcomes a national approach under the AER’s Future Retail Functions, it is concerned that this approach must adequately fulfil the obligations of the AER under the National Energy Objective. Specifically, the AER must ensure that the Exempt Selling Guideline meets the ‘…long term interests of consumers of energy with respect to price, quality, safety, reliability and security of supply of energy’.

COTA remains concerned that customers of exempt sellers may still be disadvantaged in comparison to retail customers under the current approach.