Australian Energy Regulator’s Consumer Vulnerability Strategy

COTA Australia, in collaboration with its Energy Advocates, provided comment to the Australian Energy Regulator (AER) on its Consumer Vulnerability Strategy.

We welcomed the proposed Consumer Vulnerability Strategy as a genuine attempt by the AER to improve energy affordability and reduce the barriers that restrict energy customers’ engagement in the market, especially those facing payment hardship.

In our response we highlighted we would appreciate immediate action directed towards resolving issues experienced by embedded network customers and energy customers who do not have an online presence.

Embedded networks affect energy customers who live in an apartment block, retirement village or caravan park where the electricity runs through a main meter (owned by the property’s proprietor) before reaching each household. We consider this form of energy supply is no longer fit for purpose. Embedded networks can seriously disadvantage energy customers including not being able to access competitive prices or important consumer protections. Plus, available evidence shows that insufficient monitoring and enforcement powers has contributed to there being a lack of clarity as to whether embedded network operators are meeting their obligations as essential service suppliers. Our submission also highlights concerns related to digital exclusion and the disproportionate impacts this is having on groups of older people. For instance, in addition to restricting opportunities for independent engagement with energy suppliers, the move to online communication can result in increased dependence on friends, family and neighbours. Potentially this could augment opportunities for elder abuse, as well as entrench vulnerability in the energy market.

In our response, we also suggested the AER rethink its use of the term ‘vulnerability’. From our perspective, rather than throwing light on the numerous systemic barriers, societal or market characteristics that disempower, the term is generally used to differentiate between those who are perceived as self-reliantly managing their own lives and those needing the kindness of others to ‘get by’.