AGL believes support is a shared responsibility across industry, government (and regulators) and the community sector to ensure our most vulnerable customers are supported to engage and navigate the energy market. Regulation and setting minimum standards of support, while important, is only one element of a holistic response. The shared responsibility approach ensures long term and holistic solutions that tackle the root causes of vulnerability, such as improved housing quality stock and social and community agency support to complement regulatory minimum standards, are identified. This provides the best possible economic and social inclusion outcomes.

In summary, the draft strategy should:

• ensure there is reasonable balance of interests including appropriate consultation with energy retailers,
• clarify the role of government and, if necessary, advocate for a greater role for government to assist customers facing vulnerability,
• demonstrate compliance with Section 8A of the ESC Act 2001,
• account for any additional costs and risks to service providers, and
• ensure that the Strategy delivers net benefits to all Victorian energy consumers.

The submission can be accessed here.