Robust reporting requirements for electricity licencees providing prepayment services, and stronger consumer protections are needed for community prepayment customers in Anangu Pitjantjatjara (APY) Lands and Yalata and Maralinga Tjarutja (Oak Valley) in South Australia.
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Submission to the Essential Services Commission of South Australia on the Limited review of small-scale networks reporting requirements and community prepayment customer protections – Draft Decision
September 2024
Overview
The Essential Services Commission of South Australia (Commission) is currently reviewing the consumer protections for ‘community prepayment customers’ and regulatory reporting requirements for small-scale networks – Guideline No. 5 (Guideline 5). The Commission published its draft decision on 25 July 2024 (Draft Decision) and has invited stakeholder feedback on the matters addressed.
The First Nations Clean Energy Network welcomes the opportunity to make a submission on this consultation.
As part of the review, the Commission is proposing several changes to community prepayment customer consumer protections and reporting requirements.
Community prepayment customers are Aboriginal tenants of public housing in remote parts of the state namely the Anangu Pitjantjatjara (APY) Lands, Yalata and Maralinga Tjarutja (Oak Valley) who are mandated to prepay for electricity services by the South Australian Government. User pays policy based on mandatory prepayment was implemented by government regulation gazetted on 9 December 2021 and commenced incrementally across remote Aboriginal communities from July 2022.
Our focus in this submission is on matters affecting ‘community prepayment customers’.
Generally, the Network:
- Supports the inclusion of strengthened consumer protections for remote Aboriginal households who are mandated to use prepayment
- Encourages transparent and robust public reporting requirements for electricity licensees which provide electricity services by prepayment in remote Aboriginal communities and in other remote locations across the state – including reporting of metrics that align with national reporting standards.
Mandatory prepayment in remote Aboriginal communities
The Network has been closely following the introduction of user pays policy for remote Aboriginal communities in South Australia based on mandatory prepayment. We observe that across Australia prepayment is generally targeted towards First Nations households, where its use is associated with known risks of disconnection from electricity supply with adverse impacts for social, health and wellbeing outcomes.
The Commission’s public reporting on the first year of mandatory prepayment use in remote Aboriginal communities in South Australia shows that households experienced an average of 13.1 prepayment meter self-disconnection events during 2022-23. This is concerning because any electricity disconnection disrupts the safe and healthy functioning of the household. The Commission’s reporting shows that approximately 32% of household disconnections lasted less than 1 hour while approximately 60% of household disconnections from electricity supply lasted between 3 – 24 hours. This is occurring in the context of households paying a reduced electricity tariff of 10 cents/kWh.
Improved consumer protections framework
In the Draft Decision, the Commission proposes to enhance consumer protections for mandatory prepayment households by the introduction of family violence protections, flexible payment arrangements for life support customers and additions to protected periods during which self-disconnection cannot occur. We support the strengthening of consumer protections for remote Aboriginal households using prepayment for electricity services.
In particular, the Network:
- Supports the addition of family violence protections and encourages the Commission to ensure that licensees comply with cultural safety training in the delivery of these protections while complementing the new framework with reporting requirements aligned to national standards
- Supports the inclusion of formalised flexible payments arrangements for life support customers whose meters are operating in post-payment mode, together with close monitoring of the situation where vulnerable customers are experiencing significant energy costs and debt – including through reporting requirements on flexible payment arrangements and debt levels
- Supports the expanded protected periods, noting they correspond with public holidays
- Encourages the Commission to implement extreme weather protections for prepayment customers, equivalent to the protections received by post-payment customers across South Australia
- Recommends that the Commission broaden the scope of the definition of life-support equipment to include medicine storage and other equipment certified by a registered medical professional.
Ensuring transparency of public reporting indicators for Aboriginal households using prepayment
The Commission is also proposing to make changes to the reporting requirements for licensees providing electricity services in remote Aboriginal communities based on mandatory prepayment. These reporting changes include:
● A new metric focused on household energy debt levels
● Amendments to existing metrics relating to prepayment meter self-disconnections and total electricity consumption
● Removal of existing friendly credit reporting requirements.
Generally, the Network supports robust reporting requirements to ensure transparency around the use of prepayment whether voluntary or mandatory.
In relation to the Commission’s proposals for mandatory prepayment customers, we recommend that any changes to reporting requirements should be additive, rather than replace or remove existing metrics—it is important to retain consistency in reporting metrics over time so that comparisons can be made.
Further, any changes to reporting should ensure the maximum possible comparability of metrics across South Australia and nationally because consistency in reporting across jurisdictions is important for understanding trends faced by prepayment customers. In relation to specific reporting changes, the Network:
- Encourages the Commission to include reporting requirements on average household energy debt levels for (1) prepayment customers and (2) life support customers alongside reporting across the proposed ranges – this should apply for mandatory and voluntary prepayment customers in small-scale networks across the state
- Supports reporting of total electricity consumption by meter, at the community level across ranges, while encouraging the Commission to maintain the reporting of total consumption data
- Supports existing reporting on the number and average duration of self-disconnections alongside the addition of more granular data collection relating to self-disconnections
- Observes that the different reasons for self-disconnections listed in the reporting proformas necessarily limits the lived experience of self-disconnection to those options – and that Original Power has been funded by Energy Consumers Australia to undertake 4 qualitative research about household experiences of prepayment across Australia that may provide better insights into the drivers of prepayment meter self-disconnections
- Encourages the Commission to maintain existing reporting requirements on the number of times that friendly credit was accessed for mandatory prepayment customers and extend this metric to voluntary prepayment customers
- Encourages the Commission to include reporting requirements for use of Centrepay, to improve transparency around how Centrepay is being used
- Supports the reporting of customer access to energy concessions across small-scale networks.