AGL's submission to the Victorian energy fact sheets technical draft decision

AGL recently responded to the Essential Service Commission of Victoria’s (the Commission’s) draft decision on the technical draft decision for the implementation of new Victorian energy fact sheets. This technical draft decision is the Commission’s response to implementation recommendations 3B-3E of the Independent Review of Electricity and Gas Retail Markets Victoria (Thwaites review).

The aim of these changes is to provide Victorian energy consumers with simple and easy to understand information on pricing and key features of energy offer and help them make informed decisions about the best offer for their circumstances. AGL supports the purpose of the Thwaites recommendations to simplify the market and information available to consumers. AGL worked closely with the Australian Energy Regulator through their updating of Basic Product Information Disclosures (BPID), including providing access to consumer testing of the revised BPID, and the final design and structure of the BPID was significantly influenced from the consumer testing results.

AGL consider that these Thwaites reforms have the potential to further improve customer trust if implemented correctly. Retailers and the Commission must ensure that appropriate time is given to both the consideration of changes through consultation, as well as appropriate time to consider and implement these new changes. AGL therefore implore the Commission and the Government to focus on getting the new requirements right, and implemented in the right way for Victorian consumers, rather than pursuing an unnecessarily tight implementation time-frame.

As the image below shows, the Commission has taken additional time in considering the final requirements for implementing these recommendations which AGL supports. However, the same consideration should be provided to ensuring that implementation can occur properly and not adversely impact customers.

The changes that retailers must make are not just limited to ensuring IT systems are appropriately tested and integrated, but also require a program of change within retailers, including system management, staff training and the development of new information and materials for consumers.

AGL has provided substantial information to the government and the Commission to show that retailers need at least two months from the conclusion of VEC upgrades to implement the new requirements and this is detailed in our two submissions below. As it stands, there is no visibility on the timelines except for an expected final decision sometime in May 2019 (which was originally due on 30 January 2019), and a continued commitment to a 1 July 2019 implementation date.

We want to ensure that these changes are implemented in the right way for positive customer outcomes, but the time pressures created by a continued commitment to a 1 July 2019 start date increase the risks of getting it wrong. It is AGL’s view that taking additional time to get implementation right is in the interest of Victorian energy consumers.

You can find the full submission to the technical draft decision here.

Our previous submission raising these same concerns in February 2019 is available here.