This submission responds to the NSW Department of Finance and Services’ Position Paper, Urban Water Regulation Review (the Position Paper). The submission comments on the proposed Retailer of Last Resort (RoLR) and Operator of Last Resort (OoLR) arrangements that are outlined in the Position Paper. The submission argues that RoLR and OoLR arrangements should seek to ensure that consumers do not suffer an interruption to their water supply and that the costs of a water provider failing are not born by low-income and vulnerable consumers. To this end, PIAC recommends that consumers with concession cards from the Australian Government Department of Human Services or Veterans Affairs should be exempt from paying any costs associated with a RoLR or OoLR event.