Consumer Action Law Centre welcomes the opportunity to provide a submission in response to the ESC’s draft decision on the minimum Feed-In Tariff (FiT) to apply for the 2018-19 financial year. We support the ESC working towards time-varying FiTs that would encourage Victorians generating energy on a small scale to provide this energy to the grid at the times of high demand where it is most useful to all Victorians. We also support the ESC enabling retailers to choose between a single flat rate and time-varying tariff in the upcoming financial year to ease the transition to this model.
However, Consumer Action is concerned that those without the technology to receive FiTs may be forced to cross subsidise those who do have the technology on an inequitable basis when energy affordability is a major concern in Victoria. We request that the ESC undertake further work for the final decision to resolve potential issues that may arise with the introduction of a time variable FiT. We identify several specific and general areas of concern in this submission and request that the ESC provide greater detail including the reconsideration of the estimated value of FiTs at peak times to give us confidence that the final decision will be effective in meeting policy objectives.
180126 SUB Consumer Action- ESC Minimum FIT 2018 2019 Final