In this submission the Public Interest Advocacy Centre (PIAC) commented on the AEMC’s Consultation Paper for the National Electricity Amendment (Using estimate reads for customer transfers) Rule 2016. The rule change proposes amendments to the National Electricity Rules (NER) and National Energy Retail Rules (NERR) to allow customers the option of transferring retailers on the basis of an estimated read, therefore facilitating more timely transfers.
The rule change sets out a number of conditions that must be met before a customer is allowed to transferred on an estimated read: that the customer is remaining at the same premises; that the customer has provided explicit informed consent to receiving a final bill based on an estimated read; that the customer’s meter is a manually read meter; and that the immediate prior meter reading was an actual meter reading. PIAC supports the proposed conditions. They establish firm boundaries around when an estimated read can be used and mitigate the risk of consumer and retailer exposure to unreliable billing.
In PIAC’s view, consumers should not be held back where it is possible to transfer on an estimated read, in particular where customer self-reads provide an accurate meter reading for billing purposes. PIAC therefore supports an AEMO consultation on developing a procedure for estimating metering data, and recommends that customer self-reads should become the default estimation method.
Equally, there need to be appropriate safeguards to ensure that the processes of estimation and account settlement do not result in consumer detriment. In this respect, PIAC considers that the proposed rule change addresses the issue of lengthy delays in in-situ transfers while providing adequate consumer protections regarding consent and accurate billing.
PIAC also recommends against voiding a transfer where a customer has not consented to transferring an estimated read. PIAC instead recommends that the new retailer should bear responsibility of remedying the situation, and the B2B Procedures should be amended to provide clear procedures for both new and old retailers where a dispute arises.
Furthermore, as the proposed rule change delivers clear benefits to electricity consumers, PIAC recommends that the AEMC deliver similar reform to gas consumers.
