AEMC – Review of energy market design in light of CPRS and MRET: 1st Interim report
This submission was prepared by the Consumer Utilities Advocacy Centre Ltd (CUAC), an independent consumer advocacy organisation, in association with the Australian Council of Social Service, the Consumer Action Law Centre, the Victorian Council of Social Service and the Alternative Technology Association.
This submission follows the AEMC Public Forum held on 1 May 2009 in Melbourne. The submission confirms in writing the comments expressed at the Forum that we were extremely disappointed that the AEMC failed to include small end consumer representation under Session 2 on the agenda, entitled Stakeholder Presentations. Consumer organisations are concerned that this reflects an AEMC view that small end consumer input is not of significant importance in this review.
The submission also confirms that the National Consumer Roundtable on Energy is a coalition of consumer bodies, social welfare organisations and environmental agencies who work on energy market reform. While the participants that form the Roundtable often support similar positions, they have a diversity of views.
We believe that a balance and diversity of stakeholder views is important to inform regulatory reviews such as this. Where consumers are characterised as having one voice or single stakeholder view, it can appear that in a technical review invariably dominated by industry participation, this does not facilitate balanced consideration of issues.
Without balanced consideration of issues, rule making and policy development is at risk of prioritising those who speak loudest and most often, particularly where there is a greater number of stakeholders (whose interests may still largely coalesce). Indicative of this, we see increasing pressure being levered by commercial entities to socialise risks and costs, such as carbon costs and network connection costs, that ultimately can only be managed, and therefore should be borne by, those commercial entities. Without balanced consideration of these issues, the appropriate and efficient allocation of risk may be compromised.
Click cuac_public-forum-submission_final1 to view the submission.
