Submissions

We develop submissions to influence policy and legislative changes that will affect Queensland energy or water consumers.

Our views consider the issues customers are contacting us about through our dispute resolution processes, as well as issues raised during stakeholder engagement and community outreach activities.

30 Result(s) found

The Australian Energy Market Commission has made a draft rule that would require newly connecting gas customers to pay the cost of their connection upfront. This is intended to address connection risks associated with the projected decline of residential and commercial gas demand. We supported a joint response with EWON and EWOSA supporting the full cost recovery of new connections to avoid cross subsidies and the risk of higher prices for remaining customers as connected customers diminish.  

EWOs were provided an opportunity to comment on the re-authorisation of the National Energy Technology Customer Code (NETCC) which is before the ACCC as it’s due to expire. The Code seeks to set consumer protection standards for signatories governing all aspects of the consumer experience in connection with the provision of New Energy Tech products and services, ranging from marketing, advertising and promotion through to offering, quoting, contracting, finance and payments, installation, operation, customer service, warranties and complaints.

EWOQ along with EWOV, EWON and EWOSA supported the continued role for the Code in bridging a gap in consumer protections for consumer energy resources (CER) through their signatories, but encouraged the ACCC to address some critical gaps to set out a pathway for alignment with a new consumer protection framework for CER as it emerges, and to ensure consumers can access independent external dispute resolution.

EWOs commented on the Australian Energy Market Commission’s proposed framework that would enable all consumers to request access to real time data from smart meters from 1 January 2028. We supported a joint response with EWON and EWOSA providing feedback on what upfront information will be valuable to customers to help minimise complaints, the approach for vulnerable customers, family violence protections and retailers’ obligation only to provide raw data. We endorsed the proposed requirement for metering service providers (MSP) to cooperate with retailers when they request information or assistance related to an ombudsman complaint or dispute and further reiterated our position to explore Ombudsman membership of MSPs as part of broader consumer protections and regulatory reforms.

EWOs were provided an opportunity to comment on the Draft Report of the National Electricity Market Wholesale Market Settings Review. We supported a joint response with EWON and EWOSA which focused on the customer related aspects of the Draft Report reiterating our support for a number of key positions including:

  • Strong support for Energy Ministers to prioritise the National CER Roadmap priority C1 to extend consumer protections to new energy services and in particular that the jurisdiction of EWOs be expanded to include third-party energy providers.
  • Support for the development of simple, multi-year fixed price retail contracts.
  • Support for more equitable network (and retail) tariff structures for consumers, particularly so that consumers who are unable to afford and/or install CER are not effectively cross-subsidising those who can.
  • Strong support for the introduction of an overarching consumer duty.

EWOs welcomed the long awaited Australian Energy Market Commission’s life support rule change consultation to improve the existing processes of retailers and distributors in registering and serving customers that require life support equipment at their premises. EWOQ contributed to a joint response with EWON and EWOSA in support of the proposed changes to:

  • Allow more targeted and rapid responses by retailers and distributors.
  • Support greater confidence for teams managing works which interact with life support customers.
  • Improve confidence in data held by the retailers and distributors to successfully deliver safe and reliable electricity services.

EWOQ led a joint submission with EWON and EWOSA on the Australian Energy Market Commission’s draft decision which aimed to improve the application of concessions to bills by requiring retailers at the time a consumer signs up to an energy plan to ask consumers about their eligibility for concessions or rebates and provide jurisdiction-specific information on concessions and rebates. Whilst we supported the proposed enhancements to the current requirements, we expressed disappointment that supplementary information provisions at additional touchpoints throughout the customer journey weren’t considered. The Commission also identified a series of other recommended actions to improve consumer access to energy concessions which EWOs supported.

EWOQ supported a joint response with EWON and EWOSA on the Australian Energy Market Commission’s draft decision to improve the ability of customers to switch to a better offer. Whilst the focus of the rule change had narrowed substantially from the initial consultation paper, we provided support for the amendments to the Better Bills guidelines to require comparative information be included in communication documents related to billing such as covering letters and emails. However, we expressed disappointment that the rule change would not address the switching complexity for consumers.

EWOs were provided an opportunity to comment on the federal government’s review to evaluate the effectiveness of the current Default Market Offer (DMO) framework in achieving its objectives of protecting customers from unreasonably high prices. We supported a joint response with EWON and EWOSA to the Department of Climate Change, Energy, Environment and Water welcoming consideration of a tariff based DMO being simpler to understand and support more intuitive market comparisons for consumers and the extension of a similar price cap protections to Embedded Network customers.

The ACCC initiated a review into unsolicited selling, including door-to-door and telesales and lead generation. EWOQ contributed to a joint response with EWON, EWOV and EWOSA strongly supporting a call to ban such activities advocating for stronger safeguards, clearer standards and greater accountability for this market to help ensure that consumers are protected and that the transition to net-zero is fair and accessible.

The Australian Energy Market Commission’s consultation considers the gas connection arrangements currently set out in the NGR as well as gas connection charges, temporary disconnections and permanent abolishments. EWOQ contributed to a joint response with EWON and EWOSA which generally supported the proposal to charge gas customers for the costs of the services – connection, temporary disconnection and permanent abolishment – that can be directly attributed to them compared to spreading the costs across all gas consumers. We however encouraged governments to provide appropriate and targeted funding to those gas consumers experiencing vulnerable circumstances who wish to permanently disconnect from the gas market where they can’t afford the abolishment cost.

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