The Consumer Action Law Centre (Consumer Action) welcomes the opportunity to comment on the National Energy Retail Amendment (Strengthening Protections for Customers in Hardship) Rule 2018 Draft Rule Determination (Draft Rule). We generally support the Draft Rule as it will improve the ability of the Australian Energy Regulator (AER) to address energy hardship and ensure compliance, albeit within the constraints of the current National Energy Retail Law (NERL). We also support the proposed timeframes for implementation and the proposal that AEMC recommend the COAG Energy Council make changes to the NERL so that retailers must always have approved hardship policies to operate.
We strongly recommend that the AEMC acknowledge the limitations of the NERL and this rule change to address the needs of the community. The AEMC can address this constraint by making a strong recommendation to the COAG Energy Council, urging the Energy Council to comprehensively reform the parts of the NERL addressing hardship and payment difficulty…181015-SUB-AEMC-draft-rule