Question 4: Claiming concessions Clean Energy Council Associated Residential Parks Queensland Crowe Queensland Council of Social Services Brisbane Gateway Resort Caravan and Camping Industry Association (CCIA) NSW EnergyAustralia Origin Energy Shopping Centre Council of Australia AGL energy Networks Association Consumer Action Law Centre Simply Energy Stakeholders agreed that customers who were entitled to receive government energy concessions should receive them. Many supported the AER’s proposal to require exempt sellers to concessions or rebates on behalf of exempt customers. Some did not, in particular park owners, who argued that mandatory collection of rebates would be unfair for small businesses. ARPQ noted that most residential park owners already claimed the rebate. There were differing views on who should bear the administrative costs of claiming rebates, and on how rebates should be applied. CCIANSW stated that the seller should be able to recover the administrative cost of claiming the rebate on behalf of customers, while CUAC stated they should not. AGL also argued that the exempt seller should be able to apply the rebate directly to the customer’s account. Park owners, and a number of stakeholders, were in favour of introducing arrangements whereby customers could claim concessions directly. Several stakeholders expressed concern customers’ awareness of rebate schemes and their eligibility, and suggested that steps be taken to better educate customers. We note that in some but not all jurisdictions exempt customers are able to claim energy concessions and rebates themselves. To ensure exempt customers receive their entitlements in jurisdictions that do not, we propose amending the Guideline to mandate the claiming of government rebates on behalf of exempt customers. The requirement will apply where an exempt customer is entitled to an energy rebate or concession but it can only be claimed by the account holder. The AER acknowledges customers may not be of their entitlements, however as concession schemes are administered by state and territory governments, customer education may be more appropriately managed at a state and territory level.
Summary of submissions and responses from additional amendments Submissions from additional amendments Stakeholder Stakeholder response AER response Further information requirements for retrofit conversions CUAC ATA WINenergy Energy and Water Ombudsman of South Australia AGL Jemena Electricity Networks Origin Energy Energy Networks Australia Energy & Water Ombudsman NSW Shopping Centre Council of Australia The majority of stakeholders supported the proposal that applicants address further information requirements for retrofitted A few considered the proposal did not go far enough, namely that sellers should, in addition, be required to advise customers: about reduced consumer protections including access to ombudsman schemes and hardship arrangements (CUAC, ATA, EWOSA); impact on a customer’s existing retail contract and access to government schemes or rebates (AGL); fees in respect to regulated meters, contract implications if the meter changes, power outages caused by meter upgrades, cost sharing arrangement in respect to the network (ENA). The Shopping Centre Council was concerned about tenants receiving multiple communications and recommended a more streamlined process. It asked for more guidance on information and consultation requirements, as did WINenergy. AGL also asked for clarification on the distinction between customers and property owners. Feedback suggests our proposed amendments will go some way towards addressing the information disclosure issues identified with respect to network conversions, but that more guidance is needed on how property owners should consult with customers, and more broadly. We will revise the Guideline accordingly. We agree with EWON that a measured approach should be taken to relaxing the consent requirements for network conversions to proceed, and therefore propose any relaxation be limited to business sites / premises only. Property owners proposing network conversions to residential sites / premises will continue to need to apply for an individual exemption. To clarify, our proposals relate only to retail exemptions. The Network Guideline will be reviewed and revised separately.