Submission on Draft Determination: Improving application of concessions to bills

The Justice and Equity Centre led a joint consumer and community organisation submission in response to the Australian Energy Market Commission’s Draft Determination on the Improving application of concessions to bills proposed rule change. The joint submission was co-signed by nine other organisations. The JEC previously led a detailed joint submission in response to the Issues Paper for this rule change.

The draft rule will require retailers to ask consumers if they are eligible for concessions and rebates at the time of sign-up, and will require retailers to provide consumers with jurisdiction-specific information on concessions and rebates.

Inconsistent application of concessions and rebates to the bills of eligible consumers is a problem that consumer advocates have been raising with decision-makers over many years and across multiple different processes. While we appreciated the recognition of ongoing issues through the rule-change process, a rule-change alone was never going to be capable of solving the problems – many of which stem from systemic issues that consumers cannot resolve on their own.

Our organisations commended the AEMC on the Draft Determination, which demonstrates important leadership in seeking positive outcomes for energy consumers beyond the narrow scope of what is acknowledged to be possible in this rule change. We welcome the AEMC providing a range of positive, actionable recommendations to other energy market bodies and government decision-makers. These recommendations – particularly the primary recommendation that the Commonwealth Government progress automation of concessions – if progressed, will help ensure the more meaningful and enduring reforms required but unable to be delivered in this rule change process. 

In the Draft Determination, the AEMC adopted most of the recommendations that we put forward in our response to the Issues Paper, including:

• Amending the proposed rule change to require retailers to provide jurisdictional concessions and rebate information;
• Providing a recommendation/ advice to the Energy and Climate Change Ministerial Council that upgrading government and retailer systems to facilitate automated application of energy concessions and rebates is an urgently needed reform that should be prioritised;
• Investigating processes through which concession and rebate validation errors can be resolved;
• Implementing a process to assess language and terminology used in provision of information on concessions and rebates