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.

Latest submissions

In response to the progressing reforms to deploy smart meters, the AEMC commenced consultations on enhanced customer safeguards for the accelerated smart meter rollout. EWOQ led a joint response with EWON and EWOSA which broadly supported improved consent provisions and information requirements on any proposed tariff change, as well as the consideration of a flat standing offer tariff.

EWOQ contributed to a joint response with EWOV, EWON and EWOSA on the draft Terms of Reference published by the AEMC for the review. Our feedback highlighted how a lack of fit-for-purpose consumer safeguards may impact on the benefits consumers receive from the packaging of CER services. We suggested the introduction of overarching consumer safeguards to ensure that the products and packages are either designed to benefit the customer, or adequate accessible information is provided to consumers on the benefits being sold to them.

EWOQ contributed to a joint response with EWOV, EWON and EWOSA on the review of Centrepay to reform and improve its policy and operation for consumers and businesses. Drawing on the insights of cases received by EWOs, we provided commentary on issues such as deduction arrangements, access and awareness of Centrepay and availability of EWOs to assist resolving their issues.

EWOQ contributed to a joint response with EWON and EWOSA on the AER’s review of the Payment Difficulties Framework in the NECF. The response also incorporated Insights from EWOV from their review of the operation and outcomes of the Victorian Payment Difficulty Framework.

EWOQ assisted in a joint submission with EWON and EWOSA providing general support of the AEMC’s draft rule determination to accelerate the rollout of smart meters, along with many aspects of the enhanced customer protections proposed in the Draft Rules. Concerns however were raised about the temporary nature of some of the consumer protections, the timing and content of retailer notifications, customers with remedial work, testing of legacy meters and customer switching.

EWOQ provided a general letter of support with EWON and EWOSA on the AER’s draft Retail compliance procedures and guidelines. The Guidelines set out the manner and form in which energy businesses in NECF must submit compliance information and data to the AER, and also provides guidance on conducting compliance audits. We considered reporting around family violence breaches and the material breach reporting a positive inclusion.

EWOQ contributed to a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) on the draft determination which sets out a voluntary framework to make it easier for households and businesses to capture the value of their CER (Clean Energy Resources – Solar, Batteries etc), exercise greater control over their energy bills, and support integration of CER in the power system. EWO’s were primarily concerned about consumer protections under the proposed model, noting arrangements are intended to be voluntary /choice.

EWOQ led the development of a joint submission with EWON and EWOSA in support of proposed enhancements to the retail performance reporting framework to better enable the AER to collect data to effectively monitor retail market outcomes. EWOs welcomed in particular the expansion of the guidelines to include new indicators covering embedded networks, life support customers and customers affected by family violence.

EWOQ provided a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) along with an individual response to the AER’s review of the embedded networks exemption framework which is aimed at better understanding the risks, harms and benefits facing embedded network customers and determining whether any action is required to strengthen the regulatory framework.

EWOQ assisted in a joint submission with EWON and EWOSA in support of the proposed changes to the Guidelines for recognising external dispute resolution schemes (the guidelines), which were largely about streamlining the guidelines and including the new arrangements applicable for Consumer Data Right, complaint handling, referrals and reporting.

EWOQ assisted developing a joint ANZEWON response in particular agreeing the key areas identified by the AER as requiring an uplift in consumer awareness and that DNSPs should have clear processes for handling consumer complaints and resolving disputes relating to the implementation and operation of flexible export limits.

EWOQ provided a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) supportive of a designated complaints function within the ACCC for consumer and small business advocates.

EWOQ provided a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) on a review to enhance community support and ensure that electricity transmission and renewable energy developments deliver for communities, landholders and traditional owners.

EWOQ was part of a joint submission led by EWOSA which reviewed the Terms of Reference of the Inquiry and responded to those elements that aligned with issues customers raise or are likely to raise as residential electrification progresses, or with each respective organisation’s operations, as well as with our concerns for low-income and vulnerable energy consumers.

EWOQ contributed to a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) on the AER’s Review of consumer protections to ensure it remains fit for purpose for the future energy market.

EWOQ prepared a joint response on behalf of EWON, EWOSA and EWOV in support of the commission's initial views to improve flexibility and trading of consumers’ energy resources (CER) and agrees the model should not apply to small businesses and residential customers.

EWOQ was part of a joint submission led by EWOSA, which supported the intention of and reasoning behind the proposed changes which provide EDR schemes with the ability to refer privacy issues back to the OAIC where the matter is not within jurisdiction. We also provided a number of suggestions including that the customer experience could be enhanced by the OAIC and EDR schemes committing to contact each other first when considering referrals, so as to avoid any potential refer backs.

EWOQ, in collaboration with EWOSA, EWON and EWOV, welcomed the Commission’s draft determination to enhance transmission network service providers engagement with communities early in the transmission planning process.

EWOQ contributed to a joint submission with EWON and EWOSA which strongly supported expanding the guideline to include the collection of data of residential and small business customers within embedded networks. Other recommended key data for inclusion included collection of life support customer data, family violence data, and enhanced monitoring of debt and tracking alternative debt arrangements.

EWOQ developed a joint submission with the ANZEWON working group (EWON, EWOSA and EWOV) on the final report on the Review of the Privacy Act 1988 (Commonwealth) which provided recommendations to strengthen the protection of personal information, and the control individuals have over their information.

EWOQ developed a joint submission with EWON, EWOV and EWOSA on a rule change request proposing modifications to the National Electricity Rules (NER) and National Energy Retail Rules (NERR) to unlock consumer energy resources benefits through flexible trading.

EWOQ developed a joint submission with EWON and EWOSA on the draft recommendations to help accelerate the deployment of smart meters in the National Electricity Market.

Previous submissions

31 January 2022 - AER - Better Bills Guideline (prepared with EWON and EWOSA)

25 February 2022 - AER - Draft consumer vulnerability strategy (prepared with EWOSA)

3 March 2022 - AEMC - Protecting customers affected by family violence (prepared with EWON and EWOSA)

8 March 2022 - AER - Draft export tariff guideline

March 2022 - Energy Charter - Draft national customer code for energy comparators and energy moving services

6 June 2022 - AER - Retailer authorisation and exemption review (prepared with EWOSA)

July 2022 - Qld Government - Proposed changes to Queensland's information privacy and right to information framework (submissions have not been published by the Queensland Government).

4 August 2022 - AEMC - Protecting customers affected by family violence (prepared with EWON and EWOSA)

19 August 2022 - ESB - Data strategy reforms consultation (prepared with EWOSA)

5 December 2022 - AER - Flexible export limits issues paper (prepared with EWOSA)

6 December 2022 - AER - Draft networks exemptions guideline version 7

13 December 2022 - Department of Social Services - Financial counselling industry funding model discussion paper (prepared with EWOSA, EWOV and EWON)

15 December 2022 - AER - Review of consumer protections for future energy services (prepared with EWON and EWOSA)

12 January 2021 - AEMC -  Maintaining life support registration draft rule

29 January 2021 - AEMC - Bill contents and requirements draft determination (prepared with EWON, EWOSA and EWOV)

11 February 2021 - AEMC - Review of metering regulatory framework

13 September 2021 - Department Treasury - Consumer Data Right in the energy sector (prepared with EWON, EWOSA and EWOV)

21 September 2021 - AER - Better Bills Guideline (prepared with EWOSA)

26 October 2021 - AEMC - Review of the regulatory framework for metering

6 January 2020 – ACCC – Prohibiting Energy Market Misconduct

31 January 2020 – DNRME – Review of Qld Energy Legislation

13 February 2020 – AEMC – Consumer protections new energy products

3 August 2020 – COAG Energy Council – Civil penalty regime

28 August 2020 – AEMC – Maintaining life support registration when switching

28 August 2020 – ACCC – Energy rules framework consultation

22 October 2020 – AEMC – Bill contents and billing requirements (prepared with EWON, EWOV and EWOSA)

11 January 2019 – AER – Hardship guideline

4 February 2019 – AEMC – Review of regulatory frameworks for stand-alone power systems

5 February 2019 – AEMC – Meter installation - advanced meter communications

27 February 2019 – AEMC – National Energy Retail Amendment (Customers with interval meters) Rule 2019 consultation paper

4 March 2019 – AER – Draft customer hardship policy guideline version 1

11 March 2019 – AEMC – Updating the regulatory frameworks for embedded networks

21 March 2019 – DNRME – National Energy Retail Law in Queensland

20 May 2019 – AEMC – National Energy Retail Amendment (Customers with interval meters) Rule 2019 draft determination

22 May 2019 – Clean Energy Council and Ors – New energy tech consumer code

30 May 2019 – ACCC – Guide to the electricity retail code

15 August 2019 – AER – Customer service incentive scheme

19 September 2019 – AEMC – Regulating conditional discounting

9 October 2019 – AEMC – Metering coordinator planned interruptions

12 March 2018 – AER’s Draft retail pricing information guidelines

21 March 2018 – AER’s Benefit change notice guidelines issue paper

28 March 2018 – QCA's Review of guaranteed service levels

17 April 2018 – AEMC's National Energy Retail Amendment (preventing discounts on inflated energy rates) Rule 2018

15 June 2018 – Review of Queensland energy legislation

29 June 2018 – AEMC's National Energy Retail Amendment (Strengthening protections for customers in hardship) Rule 2018 consultation paper

12 July 2018 – AEMC's National Electricity Amendment (Metering installation timeframes) Rule 2018 consultation paper

24 September 2018 – AEMC's National Electricity Amendment (Estimated meter reads) Rule 2018

18 October 2018 – AEMC's National Energy Retail Amendment (Strengthening protections for customers in hardship) Rule 2018

25 October 2018 – AEMC's National Electricity Amendment (Metering installation timeframes) Rule 2018 draft rule determination

5 December 2018 – AER's standardised statements customer hardship policies