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We welcome the opportunity to provide the Essential Services Commission (ESC) our submission in partnership with Westjustice.

Life support customers are some of the most vulnerable people in Australia, especially during power outage events. We agree that failure to accurately maintain life support registers can result in challenges to provide emergency response services during unplanned outage events.

We are concerned however, that the proposed rule changes do not address the underlying causes of inaccurate life support registers. If implemented as drafted, these reforms could exclude existing and prospective life support customers from the register, without providing any additional material outcomes to those who need it most.

We support stronger protections for life support customers across Australia and agree that harmonisation across energy market jurisdictions could support this outcome. We agree with the central issue identified in the discussion paper and rule change request that the current life-support registers are inaccurate and do not adequately identify customers who require priority support. However, the proposed approach, that requires documentation and imposes strict default timeframes and removal of potentially at-risk consumers from a lifeline, is heavy handed. The consequences of this approach could cost lives – and appears to run counter to the overall purpose of the register itself.

We support further progress of recommendations from the Network Resilience Review and Network Outage Review, which we consider provide expansive, outcomes-based, detailed views of the cross-sectoral measures needed to support people using life support equipment during an emergency event, without resorting to restricting life support register eligibility and introducing burdensome registration processes.

We discuss recommendations throughout this submission to that end.

Read the full submission (PDF).