Submission: IPART consultation on billing requirements and pricing for embedded networks

The Tenants’ Union welcomes the opportunity to provide feedback on IPARTs consultation paper on billing requirements and setting maximum prices for residential embedded network customers. Despite a number of reviews the current regulatory system leaves embedded network customers in a weaker position compared with on-market customers. They can find themselves locked into uncompetitive pricing arrangements, and generally have access to considerably less information and fewer protections.The proposed changes are important positive steps in improving outcomes for embedded network customers. There is still significantly more work to be done in this area to ensure that customers in embedded networks have an equitable energy market experience.  In our response we have outlined additional reforms that will help to improve outcomes in particular for residents in land lease communities in NSW and ensure equality of outcomes for all NSW residents, regardless of where they reside. 

Recommendations

Recommendation 1: 

Include the customer’s distribution district in the standardised statement to assist customers to understand where the maximum price has been drawn from and provide enough information to enable cross checking of their rates against IPART’s 12 monthly determinations.

Recommendation 2: 

In the standardised statement on bills replace the term ‘weighted’ for a plain language term such as  ‘multiplied’ to make it clearer for customers.

Recommendation 3

Develop guidelines to ensure sellers establish fair price systems that balance customer affordability with costs for providing energy services, in line with ethical market practices.

Recommendation 4

Amend billing standards to require the following information to be included on bills:
- embedded network sellers' websites, where consumers can access concessional information, and
- details of the retailer at the parent meter.  

Recommendation 5

IPART to set benchmarks in July and based on a single point in time. 

Recommendation 6

Implement a maximum common factor of 0.35 at implementation and lower this maximum to 0.25 over time to incentivise upgrades and maintenance work to inefficient systems. 

Recommendation 7

Allow only one supply charge for a single fuel source. 

Recommendation 8

Implement maximum price and billing standard requirements within the next 6 months

Recommendation 9

Provide guidance to embedded network sellers to ensure that residents in land lease communities are not priced differently due to their tenure status 

Recommendation 10

IPART to investigate if their powers allow oversight of parent meter charges and contracts in land lease communities.

Recommendation 11

IPART to use its existing powers to investigate the different experience of customers in land lease communities by way of requesting any and all documents or information associated with the engagement of a retailer, embedded network seller and embedded network operator to determine a fairer maximum price methodology for land lease communities. 

Recommendation 12

IPART to investigate options to ensure exempt sellers are required to provide notice periods to customers for price changes

Recommendation 13

IPART to confer with NSW Government about limiting any new embedded network commodities in land lease communities 

Recommendation 14

IPART to establish and maintain information specific to embedded networks on their website to assist customers navigate the complexity of living in an embedded network