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We welcome the opportunity to provide our submission to the Victorian Department of Energy, Environment and Climate Action (DEECA) in response to their Embedded Networks Review.

Consumer Action Law Centre (Consumer Action) strongly supports any reforms that would result in consumers in embedded networks being offered fairer and more affordable prices for their energy use. While we appreciate that the model of embedded networks should hypothetically provide cheaper energy than most offers available on the energy market, we consistently see on our frontlines that the savings providers make from buying energy in bulk are not passed on to their customers. As a result, these consumers are often charged well above cheaper offers on the market.

Consumer Action particularly welcomes DEECA’s objectives to ensure that embedded network providers comply with all of their regulatory obligations. While the consultation paper focuses on ensuring compliance with providers offering fair prices, Consumer Action also urges DEECA to consider reforms to ensure that embedded network providers are complying with their obligations under the Payment Difficulty Framework (PDF), outlined in the Energy Retail Code of Practice (ERCoP).

Also, while we appreciate that this falls outside the remit of DEECA, Consumer Action urges the Victorian Government to consider how concessions and government grants can be made more easily accessible for consumers in embedded networks.

Read the full submission and recommendations (PDF).