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Consumer Action Law Centre (Consumer Action) welcomes the opportunity to provide feedback on the Essential Services Commission’s (the ESC) proposed amendments to the water customer service codes.

Overall, we broadly support the amendments proposed by the ESC. As one of the operators of the National Debt Helpline (NDH) in Victoria, Consumer Action is well placed to comment on how the proposed updates to the codes will impact the people who call our service seeking help with their utility bills, particularly people in financial difficulty or other vulnerable circumstances.

We typically receive only a small number of calls each year where people report water-related debt being the primary source of their financial hardship. However, we frequently hear from callers with multiple debts who report overdue water bills as one the debts they are dealing with.

Although water businesses have provided good support to customers in financial hardship over the past two years (as typified by the relatively low number of calls we receive from people to discuss water-related debts) we agree with the ESC that a key outcome of the review should be to embed many of the support measures developed during the pandemic, to ensure these improvements are maintained in the future. This enhanced support is critical given that access to water is a basic human right.

All Victorians are entitled to a supply of water necessary for an adequate standard of living. Furthermore, we note the importance of ensuring consistency in customer protections as another key outcome from this review. This relates both to consistency across water businesses, so that Victorians can expect to receive the same support irrespective of where they live, but also through increased alignment with the Energy Retail Code, so that customers receive consistent protections across all their utilities. More detailed comments in response to the proposed amendments, as well as several suggested further amendments, are provided below.

For ease of explanation, our submission refers to the clauses as numbered in the Draft Water Industry Standard–Urban Customer Service. However, all the changes we recommend be made to the urban code should also be reflected in the Rural Customer Service code.

Read the full submission PDF.