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Embedded networks serve hundreds and thousands of Australians who live and work in apartment buildings, shopping centres, retirement villages, caravan parks and office buildings. These networks can provide cost benefits to those who draw energy from them by making use of innovative products and services. However, as the number of consumers using embedded networks has risen in the past few years, so too has the number of reports of negative experiences. The Australian Energy Market Commission (AEMC) has conducted a review into embedded networks, and made recommendations for changes to the laws and rules designed to strike a balance between protecting consumers and facilitating owners and operators.

As Australia’s population grows, our cities, suburbs and towns are changing and adapting. Our city skylines are growing more dense as multi-storey buildings are erected, and shopping centres are constructed and expanded, often to include high-density residential developments.

Meanwhile, our suburbs are being transformed, as houses are replaced by multi-dwelling developments.

In fact, according to the Australian Bureau of Statistics, the number of occupied apartments, including flats and units, has risen by 78 per cent in the past 25 years.

And this number is continuing to grow, with more than ten per cent of Australians calling an apartment home on the night of the last census.

Communal networks

Embedded networks are private electricity networks that enable owners to purchase energy as an “exempt seller” and then on-sell it to residents and business owners at the site.

These networks were originally designed for small networks, such as caravan parks, but in recent years have been developed to service apartment blocks and other facilities, such as retirement villages, shopping centres and office buildings.

In December 2016, the COAG Energy Council engaged the Australian Energy Market Commission (AEMC) to carry out a review of the regulatory arrangements for embedded networks.

This review was designed to determine whether the existing arrangements continue to be appropriate, identify and assess any issues, and suggest potential solutions.

AEMC released its report in 2017, which outlined that the framework that governs exempt sellers was “no longer fit for purpose in the face of the growth in the number and scope of embedded networks”.

The review found that while embedded networks could provide some benefits to consumers, the framework did “not strike an appropriate balance between innovation, consumer protection and facilitating consumer access to retail market competition”.

In particular, it revealed that in some cases consumers could not access competitive market prices because they didn’t have a market-compliant meter; they had difficulty accessing rebates and concessions; and were not afforded protection relating to life support arrangements and outage notifications.

In addition, there were reports of customers being overcharged, and not able to connect some appliances due to capacity limitations.

The review also identified that customers did not have access to ombudsmen, and that embedded networks were not bound by reliability standards and Guaranteed Service Levels.

According to the AEMC’s most recent Chief Executive, Anne Pearson, another outcome has been that many consumers are locked into uncompetitive arrangements.

“Everyone should have access to consumer protections on billing information, payment options, hardship support and notification of planned outages, no matter who they buy their electricity from,” Mrs Pearson said.

Actioning change 

Based on this review, the AEMC proposed law and rule changes to update the regulatory framework for embedded networks. It released a draft reform package for embedded networks in January 2019, and its final recommendations in July.

This followed extensive consultation with consumers, embedded network operators, retailers, developers, ombudsmen, state governments and renewable advocates.

Mrs Pearson said adopting the recommendations would give people in private networks the same protections as customers who were directly connected to the grid, by allowing obligations relating to consumer protections and retail market competition to apply directly to embedded networks and be more readily enforced.

“The changes would strengthen regulation so people in embedded networks can’t be treated as second-class customers,” Mrs Pearson said.

Blueprint to guide network into the future

Mrs Pearson said that once well regulated, embedded networks could offer benefits to consumers.

“Embedded networks can include innovative products and services to help manage energy costs such as on-site solar generation, battery storage and demand management services,” Mrs Pearson said.

“That’s why our recommendations aim to strike a balance by providing important consumer protections without placing undue costs on owners and operators of embedded networks.”

The changes would give embedded network customers:

  • Improved consumer protections in areas including disconnections, billing information, payment options and notification of planned outages
  • Access to customer hardship programs and continuity of supply in the event of retailer failure
  • Stronger regulation, enhancing the Australian Energy Regulator’s ability to enforce compliance with obligations to provide protections
  • Access to competitively priced market offers
  • Market-compliant meters that are registered with AEMO, which make it easier for customers to switch retailer and get better information about their usage and bills
  • The same rights as grid-connected customers when upgrading their connections
  • Improved access to state government services such as concession schemes and emergency financial assistance; access to independent dispute resolution; and reliability.

Implementing these reforms will require collaboration.

“The COAG Energy Council, Australian Energy Regulator and Australian Energy Market Operator, as well as state governments, regulators and ombudsman, all have a role to play in delivering these important reforms,” Mrs Pearson said.

The proposed framework will be implemented after the COAG Energy Council has redrafted electricity and energy retail laws, based on AEMC’s proposals, and the laws have been submitted to the South Australian Parliament and the South Australian Minister has made the proposed rule changes. It is anticipated this could occur by mid-2020.

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