A coalition of advocates has taken the opportunity to comment on SCER’s National Smart Meter Consumer Protection and Safety Review Consultation Paper (Consultation Paper) and the National Energy Retail Rules Amendment Rule 2013 (Draft Amendment Rule). Our organisations represent the interests of residential and small business energy consumers – are particularly cognisant of the special needs of low income and vulnerable households – and have a keen interest in ensuring that consumers receive strong consumer protections with the introduction of smart meters.
The Consumer Utilities Advocacy Centre (CUAC), Consumer Action Law Centre (Consumer Action) and Uniting Care responded to draft policy paper 1 on 29 September 2009 in a joint consumer group submission with seven other consumer organisations. CUAC responded to draft policy paper 2 on 30 March 2012. We note that some of our suggestions have been included in SCER’s Official Report on the National Smart Meter Consumer Protection and Safety Review released in November 2012 (SCER’s Official Report).
Significant developments have occurred, in Victoria, since these papers were issued as Victoria progresses towards the completion of the AMI rollout. A mandatory rollout of smart meters to 2.5m households is largely due for completion at the end of 2013. Flexible pricing was also introduced in Victoria from September 2013. Consumer Action, CUAC and the Victorian Council of Social Service (VCOSS) have been involved in consultation processes with the Victorian government and the Essential Services Commission around the development of a comprehensive smart meter customer protection framework. We have also advocated for consumer information and education initiatives to accompany the roll out of this new technology and the introduction of flexible pricing. We have considered additional policy matters through our participation in these processes.
We are concerned about the potential detriment if consumers do not have sufficient information to understand the new technology and new products and services, and the need to provide adequate protection to ensure that the long term interests of consumers are served. We wish to comment in some detail on the following matters which are addressed in the Consultation Paper and Amendment Rule:
- Explicit informed consent
- Third parties
- Supply capacity control
- Direct load control
- Customer billing
- Data collection
- Other matters
We believe that some of the policy positions articulated in SCER’s Official Report, have not given adequate consideration to the implementation at the operational level including the business-to-business processes that need to be developed to support any new product offerings. Further, we share increasing concerns about the way in which consumers will interact with the energy market as it embraces the technology provided through smart meters and as such, support best practice consumer protection in essential services. This should be reflected in the overall approach towards enhancing the national framework in light of smart meters, regardless of the complexities involved.
A PDF of the joint submission is available here: National Smart Meter Consumer Protection and Safety Review.