Joint submission to the AER Review of the minimum disconnection amount

The Justice and Equity Centre led a joint community response to the Australian Energy Regulator’s Review of the minimum disconnection amount – Draft decision. The submission was co-signed by Consumer Action Law Centre (CALC), the Financial Counsellors’ Association of NSW (FCAN), First Nations Clean Energy Network (FNCEN), Queensland Council of Social Service (QCOSS) and South Australian Council of Social Service (SACOSS). 

The AER proposes to increase the minimum disconnection amount from $300 to $500. We support the proposal to raise the minimum disconnection amount, however, we do not consider lifting the minimum disconnection amount to $500 as likely to support the principle of disconnection as last resort, and are concerned it does not offer adequate protection for households experiencing vulnerability.

In our submission we discuss the harms caused by disconnection, recommend an approach to setting the minimum disconnection amount that is informed by the risk of harm to consumers, and urge that this reform be considered within the context of wider proposed consumer protections reforms. We provide reasoning as to why we do not consider $500 to be consistent with ensuring disconnection is a last resort and provide our recommendations for how a more appropriate amount may be determined. Finally, we provide support for the AER’s proposal that the disconnection minimum amount apply to all household consumers and respond directly to the consultation questions provided.