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Consumer Action Law Centre (Consumer Action) welcomes the opportunity to comment on the Embedded Networks Review (the Review) Issues Paper.

We support the Victorian Government’s decision to ban embedded networks in new residential apartment buildings(with exemptions for buildings using microgrids to deliver low-cost renewable energy to consumers).

Despite the potential benefits of embedded networks,  often they have not been realised in practice, with too many customers finding themselves locked into effective monopolies for their energy supply, paying unfair prices while also lacking access to the protections afforded to consumers purchasing their electricity directly through the retail market.

In addition to the proposed ban, we also welcome several recent changes made by the Victorian Government for embedded network customers, including: enhanced consumer protection coverage; access to the Energy and Water Ombudsman (Victoria) for disputes; and a requirement that sellers obtain explicit and informed consent before creating an agreement.

Combined with the Essential Services Commission’s (ESC) decision to set the Victorian Default Offer (VDO) as the maximum price cap, there is now a much greater degree of equity of outcomes between customers in embedded networks and on-market customers. However, further reforms are necessary to ensure that all Victorians have access to the most competitive retail offers and consumer protections, regardless of how they purchase their electricity.

We consider there to be several gaps still to be addressed to improve protections and outcomes for consumers within legacy embedded networks, and new residential buildings which meet exemption requirements using microgrid technologies.

Read our submission (PDF).