SEQ Retail Electricity Market Monitoring: 2016–17

Market Monitoring Report

SEQ retail electricity market monitoring: 2016–17

November 2017

We wish to acknowledge the contribution of the following staff to this report: Adam Liddy, Alicia Toohey, Darren Page, Electra Papas, Shannon Murphy & Zach Zhang

The Queensland Competition Authority has no objection to this material being reproduced, made available online or electronically but only if it is recognised as the owner of the copyright and this material remains unaltered.

Queensland Competition Authority Contents

Contents

THE ROLE OF THE QCA – TASK, TIMING AND CONTACTS IV

1 INTRODUCTION 1 1.1 Retail electricity market monitoring in SEQ 1 1.2 Market monitoring 1 1.3 The QCA's process 2 1.4 Retailers operating in SEQ 3

2 PRICES AND VARIATIONS 5 2.1 Background 5 2.2 Minister's Direction 7 2.3 QCA methodology 7 2.4 QCA monitoring 10 2.5 Distribution non-network charges 57 2.6 Conclusion 59

3 DISCOUNTS, SAVINGS AND BENEFITS 61 3.1 Background 61 3.2 Minister's Direction 61 3.3 QCA methodology 61 3.4 QCA monitoring 62 3.5 Conclusion 79

4 FEES AND CHARGES 81 4.1 Background 81 4.2 Minister's Direction 81 4.3 QCA methodology 81 4.4 QCA monitoring 81 4.5 GST on fees 90 4.6 Fees that 'may' have applied 91 4.7 Additional fee information on Energy Made Easy 91 4.8 Conclusion 91

5 TRENDS IN STANDING AND MARKET OFFER PRICES 93 5.1 Minister's Direction 93 5.2 QCA methodology 93 5.3 QCA monitoring 93 5.4 Conclusion 101

6 SWITCHING TO MARKET OFFERS 102 6.1 Background 102 6.2 Minister's Direction 102 6.3 QCA methodology 103

Queensland Competition Authority Contents

6.4 Proposed data requirements 105 6.5 Submissions 105 6.6 QCA monitoring 108 6.7 Conclusion 114

7 HARDSHIP AND REBATE CUSTOMERS 116 7.1 Background 116 7.2 Minister's direction 116 7.3 QCA methodology 116 7.4 QCA data requirements 117 7.5 Submissions 118 7.6 QCA monitoring 119 7.7 Conclusion 133

8 NEW RETAIL TARIFF STRUCTURES AND PLANS 134 8.1 Background 134 8.2 Minister's Direction 135 8.3 QCA methodology 135 8.4 QCA monitoring 135 8.5 QCA commentary 138

9 STANDING OFFERS FEE TYPES RESTRICTION 139 9.1 Background 139 9.2 Minister's Direction 140 9.3 QCA methodology 140 9.4 QCA monitoring 140 9.5 Retailers' awareness of the fee types restriction 142 9.6 Significant issues 143

10 QCA INFORMATION NOTICE 145 10.1 Electricity Act 145 10.2 Contents of information notice 145 10.3 Initial timeframes for information notice 145 10.4 Submissions 146 10.5 Energy Made Easy parts of the information notice 147 10.6 Switching, hardship and rebate customers part of the information notice 149

GLOSSARY 151

APPENDIX A : MINISTER'S LETTER (JULY 2016) 154

APPENDIX B : MINISTER'S LETTER AND DIRECTION NOTICE (FEB 2017) 155

APPENDIX C : SUBMISSIONS 158 Submissions on the scoping paper 158

APPENDIX D : RESPONSES TO ADDITIONAL ISSUES RAISED IN SUBMISSIONS 159 Legislative framework 159

Queensland Competition Authority Contents

Electricity supply costs 161 Prices and variations to prices 162 Discounts, savings and benefits 167 Fees and charges 169 Switching to market offers 171 Hardship and concession customers 174 New types of retail tariff structures and plans 177 Standing offer fee types restriction 178 QCA information notice 178

APPENDIX E : KEY ASSUMPTIONS IN PRICE ANALYSIS 181 Point-in-time approach 181 Number of days in a year 181 Annual bills—standing offers 181 Annual bills—market offers 182 Annual bill—average market offer prices 182 GST 183 Residential offers available to small business customers 183 Small business offers available to residential customers 183 Calculating annual bills using our published dataset 184

APPENDIX F : SWITCHING CUSTOMERS (LOCATION) FULL POSTCODE DATA 185 Residential customers 185 Small business customers 191 Postcodes excluded from the analysis 197

REFERENCES 198

iii

Queensland Competition Authority The Role of the QCA – Task, Timing and Contacts

THE ROLE OF THE QCA – TASK, TIMING AND CONTACTS

The Queensland Competition Authority (QCA) is an independent statutory body which promotes competition as the basis for enhancing efficiency and growth in the Queensland economy. The QCA's role with respect to monitoring south east Queensland's (SEQ) retail electricity market is set out in part 2, chapter 4 of the Electricity Act 1994 (Qld) (the Electricity Act). In accordance with section 89B of the Electricity Act, the QCA has been directed by the Minister for Energy, Biofuels and Water Supply to report on the operation of SEQ's retail electricity market for 2016–17.

Key dates The QCA's timetable for SEQ retail electricity market monitoring for 2016–17 is shown below.

Release scoping paper 14 October 2016

Submissions on scoping paper due 30 November 2016

Consult on, issue, and review responses to, information notices February – August 2017

Prepare report September – October 2017

Provide report to Minister for Energy, Biofuels and Water Supply No later than 30 November 2017

Publish report on QCA website 30 November 2017

Contacts Enquiries regarding this project should be directed to: Attention: Mr Shannon Murphy Contact: www.qca.org.au/Contact-us

Queensland Competition Authority Introduction

1 INTRODUCTION

1.1 Retail electricity market monitoring in SEQ The Queensland Government removed regulation of retail electricity prices for residential and small business customers in south east Queensland (SEQ), effective from 1 July 2016.1 The government also introduced 'market monitoring' and 'competition review' functions to the Electricity Act 1994 (Qld) (the Electricity Act) to ensure customers have the opportunity to benefit from price deregulation in SEQ.2 In July 2016, the Minister for Energy, Biofuels and Water Supply (the Minister) directed the QCA to monitor the operation of the SEQ retail electricity market for residential and small business customers for the year from 1 July 2016 to 30 June 2017.

1.2 Market monitoring This market monitoring report provides information on:  generally available standing and market offer prices (Chapter 2)  discounts, savings and benefits generally available to customers (Chapter 3)  retail fees and charges (Chapter 4)  quarterly trends in prices over the period 1 July 2015 to 30 June 2017 (Chapter 5)  customers switching from standing to market offers with their retailer (Chapter 6)  prices paid by hardship and rebate customers (Chapter 7)  new types of retail tariff structures and retail electricity plans (Chapter 8)  retailers' compliance with the restriction on the types of fees chargeable to their standing offer customers (Chapter 9)  the QCA's approach to requiring retailers to provide information to support the review (Chapter 10). We expect that the market monitoring report will promote customers' awareness of prices in SEQ's retail electricity market and inform their engagement with the SEQ retail electricity market.

1.2.1 Effectiveness of competition The report does not draw conclusions about the effectiveness of competition in the SEQ retail electricity market. We consider this approach is consistent with the government's policy intent reflected in the Minister's Direction (the Direction), and outlined in the explanatory notes to the Electricity Competition and Protection Legislation Amendment Bill 2014.3

1 ECPLA Act, part 3; ECPLA Act Proclamation; ECPLA (Postponement) Regulation; Electricity Act, section 89B. 2 Electricity Act, sections 89B and 89D; ECPLA Bill, explanatory notes, page 2. The Electricity Act, the ECPLA Act, proclamation and postponement regulation, and the ECPLA Bill and explanatory notes, can be accessed on the OQPC (https://www.legislation.qld.gov.au/OQPChome.htm) and Lawlex (https://lawlex.com.au/) websites. 3 ECPLA Bill, explanatory notes, page 2.

Queensland Competition Authority Introduction

For analysis of the state of retail electricity competition in Queensland, stakeholders may refer to the preliminary report of the Australian Competition and Consumer Commission's (ACCC) inquiry into retail electricity pricing and the Australian Energy Market Commission's (AEMC) annual retail electricity competition reports.4 Also, the Australian Energy Regulator (AER) publishes a range of information on electricity retailers' performance which may be of interest to stakeholders.5

1.3 The QCA's process 1.3.1 Scoping paper In October 2016, the QCA released a scoping paper as the first stage of the 2016–17 market monitoring review. The purposes of the paper were to present the:  QCA's interpretation of the Direction  type of information the QCA intended to present in the market monitoring report  type of information the QCA would need to collect to complete the report  QCA's timeframes for the review.6 The scoping paper was written prior to our collection of any data. The paper explained that, while we were endeavouring to anticipate the issues the market monitoring report would address and explain how we would report on them, other issues might arise as we analysed the data and other information before publishing the report. The paper also commented that developments in the market between October 2016 and the end of June 2017 may influence our market monitoring report. Therefore, we considered that we were not constrained from reporting in a different way to what we outlined in the scoping paper if we considered the Direction would be best addressed in a different way.7

1.3.2 Submissions on the scoping paper We received eight submissions on the scoping paper, which were due on 30 November 2016.8 In response to these submissions, we made some adjustments to our approach to monitoring the market. These are detailed in the relevant chapters of this report. Additional issues raised in submissions that did not lead to a change in our methodology are addressed in Appendix D. In its submission on the scoping paper, QCOSS recommended that the QCA provide feedback to stakeholders "much earlier" (i.e. by January 2017) on the outcome of its consultation on the scoping paper, and the changes it is making to its approach as a result of the consultation.9 The Direction does not require us to have undertaken any consultation prior to publishing the market monitoring report. We published a scoping paper in October 2016 to inform stakeholders and retailers of, and seek feedback on, how we intended to monitor the market. However, in recognition of the length of time between submissions on the scoping paper and publication of this report, we met with QCOSS in March 2017 to provide it with a response to its

4 ACCC 2017; AEMC, www.aemc.gov.au/. 5 AER, www.aer.gov.au. 6 QCA 2016a, section 1.2. 7 QCA 2016a, section 1.2. 8 A list of organisations who made submissions is at Appendix C. 9 QCOSS 2016, chapter 7 (Recommendation 22).

Queensland Competition Authority Introduction

submission. The meeting was also attended by the Queensland Consumers' Association and COTA10.

1.3.3 Change to publication date In February 2017, the Minister changed the publication date for the market monitoring report from 31 October 2017 to 30 November 2017.11 The extension allowed the QCA to change the due date for retailers to respond to part 2 of the information notice, from mid-July 2017 to 31 August 2017.12

1.3.4 Information notice The QCA issued information notices to 19 retailers who were active in the market in 2016–17.13 The information notice was divided into three parts:  Parts 1 and 3 covered information included by retailers in their 2016–17 offers on Energy Made Easy.  Part 2 covered switching, hardship and rebate customers, and an optional section on new retail tariff structures and plans. The obligations imposed on the QCA and retailers regarding information notices, the QCA's approach to issuing information notices, and retailers' responses to the notices are discussed in Chapter 10.

1.4 Retailers operating in SEQ Using the AER's Energy Made Easy website, the QCA identified the retailers shown in the table below as providing electricity offers to SEQ's residential and small business customers in 2016– 17.

10 COTA is a national organisation that represents the rights, needs and interest of older Australians. See COTA website, http://www.cota.org.au/australia/faqs.aspx. 11 The Minister's letter of July 2016 to the QCA is at Appendix A; the Minister's letter and revised Direction of February 2017 to the QCA are at Appendix B. 12 The scoping paper suggested a due date of mid-July 2017 for retailers' responses to information notices. See QCA 2016a, section 7.3. 13 The QCA did not issue a notice to Urth Energy, as it entered into administration in February 2017. See AER 2017a.

Queensland Competition Authority Introduction

Table 1 Retailers with residential and small business offers in SEQ, 2016–17

Retailer Residential Small business

AGL Sales Pty Ltd  

Click Energy Pty Ltd  

Diamond Energy Pty Ltd  

Dodo Power & Gasa  —

EnergyAustralia Pty Ltd  

Energy Locals Pty Ltd  

ERM Power Retail Pty Ltd — 

Lumo Energy (Qld) Pty Ltd  

Mojo Power Pty Ltd  —

Momentum Energy Pty Ltd  

Next Business Energy Pty Ltd  

Origin Energy Retail Ltd  

People Energy Pty Ltd  —

Powerdirect Pty Ltd  

Powershop Pty Ltd  

QEnergy Limited  

Red Energy Pty Ltd  

Sanctuary Energy Pty Ltd  —

Simply Energyb  

Urth Energy Pty Ltdc  

a The applicant for Dodo Power & Gas's retail authorisation is M2 Energy Pty Ltd. b The applicant for Simply Energy's retail authorisation is IPower Pty Ltd. c Urth Energy's retail authorisation was revoked by the AER in February 2017 following the company's entry into administration.14 Notes: A tick () indicates the retailer published at least one offer on Energy Made Easy for 2016–17 and a dash (—) indicates the retailer did not publish any offers on Energy Made Easy for 2016–17 for the applicable small customer type. Not all retailers had offers published in each quarter of 2016–17. For more information on retail authorisations, see the AER's public register of authorised retailers on the retail markets section of the AER's website, https://www.aer.gov.au/. Source: Energy Made Easy.

14 AER 2017a.

Queensland Competition Authority Prices and variations

2 PRICES AND VARIATIONS

This chapter compares and assesses:  retailers' standing offer prices and generally available market offer prices, including fixed and variable charges, which were available to customers on a quarterly basis in 2016–17  variations to retailers' generally available market offer prices, including fixed and variable charges, which were available to customers to customers in 2016–17.

2.1 Background 2.1.1 Types of contracts/offers Electricity retailers operating in SEQ are required to provide customer retail services to small customers either under a standard retail contract or market retail contract.15 Small customers are residential customers or business customers who consume less than 100 megawatt hours of electricity per annum.16

Standing offers Standing offers are basic offers with terms and conditions that are specified by the National Energy Retail Rules (NERR).17 While the standing offer is the default offer that a retailer provides to customers who have not accepted a market offer, the standing offer may also apply where a customer:  has moved into a new premises and started consuming electricity without contacting a retailer  has been transferred to a retailer of last resort as a result of the failure of their retailer  has not signed a new market contract when their existing market contract ended.18 In SEQ, where prices have been deregulated, standing offer prices are set by retailers.19 Standing offer prices are generally higher than market offer prices. For the first year of deregulation (2016–17), once standing offer prices were set, retailers could not increase these prices.20

Market offers Market offers contain a minimum set of terms and conditions that are specified in the NERR, and other terms that are agreed between the retailer and the small customer.21 These offers may be either generally available or offered only to specific customers, and may either have a fixed term or an ongoing term ('evergreen' contracts). Some retailers may also provide offers that have a fixed benefit period (e.g. a discount might apply for a period that is less than the

15 National Energy Retail Law, section 20. 16 National Energy Retail Law, section 5; National Energy Retail Regulations, section 7. 17 National Energy Retail Rules, rule 12 and schedule 1. 18 National Energy Retail Rules, rule 54; National Energy Retail Law, section 145(4). 19 In regional Queensland, standing offer prices are the notified prices that are decided under the Electricity Act, section 90(1). 20 National Energy Retail Law, section 23(9), as per section 16 of the schedule to the Queensland NERL Act. 21 National Energy Retail Rules, rule 14.

Queensland Competition Authority Prices and variations

term of the contract). Prices under market offers are set by the retailer. Retailers can also differentiate their market offers through:  different types of discounts: conditional discounts only apply where a customer satisfies certain requirements or conditions, such as paying bills on time; unconditional discounts are guaranteed and do not require a particular action or behaviour to be performed by the customer  benefits such as frequent flyer points and gift cards  cash rebates  fees (e.g. payment processing22, late payment or early termination23 fees)  more innovative and tailored offers that match customers' needs and preferences (e.g. fixed price plans or plans that provide customers with the option to support renewable or environmentally friendly sources of electricity generation through programs such as GreenPower24 for an additional charge). In SEQ, if a retailer increases market contract prices, customers must be notified at least 10 business days in advance; if prices are to decrease, customers can be notified on their next bill.25

2.1.2 Disclosure of standing and market offer prices (Energy Made Easy) Electricity retailers operating in SEQ are required to present standing and market offer prices in accordance with the AER's Retail Pricing Information Guidelines (AER pricing guidelines).26 The AER has developed a price comparator which is available on its Energy Made Easy website27 to assist small customers to compare published standing and market offers.28

2.1.3 Prices, fees and charges included in a retail electricity contract The bill that a customer receives under an electricity offer consists of fixed and variable charges, as well as other fees and charges.

Fixed and variable charges Tariff structures typically include fixed and variable charges:  The fixed (daily supply) charge is charged daily to cover the costs of maintaining electricity supply to a premises, including the costs associated with the provision of network infrastructure (i.e. poles and wires) and general administration. Retailers may also include metering charges levied by Energex or a meter service provider under this component.

22 The Competition and Consumer Act, part IVC, may prevent retailers from levying excessive payment processing fees on customers. For more information, see ACCC 2016. 23 An early termination fee must be a reasonable estimate of the retailer's costs resulting from early termination, and the manner of calculating the fee must be detailed in the contract (National Energy Retail Rules, rule 49A). 24 GreenPower is a voluntary program that enables a retailer to purchase renewable energy on the customer's behalf. 25 National Energy Retail Rules, rule 46(4)–(5), as per section 8 of schedule 5 to the Queensland NERL Regulation. The AER regulates this rule. 26 National Energy Retail Law, section 24. 27 Energy Made Easy website, https://www.energymadeeasy.gov.au/. 28 National Energy Retail Law, section 62.

Queensland Competition Authority Prices and variations

 The variable (usage) charge varies according to a customer's consumption (measured in kilowatt hours (kWh)). It may include a time-of-use charge, which differs, depending on when customers use electricity—a 'peak' (higher cost) period and an 'off-peak' (lower cost) period apply.

Other fees and charges Electricity offers can also include a number of additional fees and charges. These may be distribution charges passed on from Energex to customers, or retailers' own fees and charges.

2.1.4 Types of tariffs Prior to deregulation of the retail electricity market in SEQ, retail standing offers were based on retail tariffs determined by the QCA under the 'network plus retail' (N+R) cost build-up methodology.29 The most common retail tariff for residential customers was tariff 11 (flat rate), where customers paid the same rate for each unit of electricity consumed plus a fixed daily charge. However, many customers on tariff 11 were also on one of the 'off-peak' or 'controlled load' tariffs—tariffs 31 and 33—for uses such as water heating and pool pumps.30 Controlled load is electricity supplied to specific appliances, which are often separately metered. A controlled load tariff is generally a lower rate, as these appliances operate during off-peak hours (usually overnight). The most common retail tariff for small business customers was tariff 20 (flat rate).31 Since prices were deregulated in SEQ, retail tariffs have been set by retailers in line with their business models and customer preferences. However, in 2016–17, retailers generally offered similar types of tariffs as before deregulation, but named their tariffs differently (flat rate tariff, controlled load tariff, time-of-use tariff, etc.).

2.2 Minister's Direction Sections 2(a) and (b) of the Direction require the market monitoring report to include a comparison and assessment of: (a) retailers' standing offer prices and generally available market offer prices—published on the AER's Energy Made Easy website–which were available to customers in 2016–17 (on a quarterly basis). Where relevant, the QCA should also provide a comparison of the lowest, highest and average prices for each retailer (b) variations to those generally available market offer prices in 2016–17.

2.3 QCA methodology 2.3.1 Comparison and assessment of retailers' standing and market offer prices We obtained information on each SEQ retailer's published standing and market offer prices— including fixed and variable charges—from Energy Made Easy on the last day of each quarter in 2016–17. Given that standing and market offers may contain different types of charges, we are presenting prices as an annual bill for a median consumption level customer—the 'typical SEQ customer'—

29 QCA 2016b, chapter 3. 30 QCA 2016b, chapter 8. 31 QCA 2016b, chapter 8.

Queensland Competition Authority Prices and variations

to provide the most meaningful comparison between individual price components. Differences and savings between bills are described on an annual basis, regardless of the quarter in which the offer was published. Information on customer numbers and consumption32 was sourced from Energex. This approach is consistent with the 'annual bill outcome' approach that has been adopted by regulators for reporting in other states33 and by consumer groups such as the St Vincent de Paul Society in its annual pricing analysis of electricity retail offers.34 We found that the most common tariffs and tariff combinations for 2016–17 were:  for residential customers  a flat rate tariff  a combination of a flat rate tariff and either a controlled load super economy tariff or a controlled load economy tariff  for small business customers  a flat rate tariff  a time-of-use tariff. The table below shows the median consumption levels for the most common tariffs and tariff combinations. Table 2 Most common tariffs and tariff combinations for small customers

Customer type Tariff name Median consumption (kWh) Residential Flat rate (tariff 11) 4,000 Residential Flat rate (tariff 11) + controlled load super 4,100 + 1,900 economy (tariff 31)a Residential Flat rate (tariff 11) + controlled load economy 3,600 + 1,800 (tariff 33)b Small business Flat rate (tariff 20) 6,400 Small business Time-of-use (tariff 22) 21,400 (peak: 10,679; off-peak: 10,721)c Notes: a Controlled load super economy is available for a minimum of eight hours per day, but the times when supply is available is subject to variation at Energex's absolute discretion (Energex 2016b, Appendix 3). b Controlled load economy is available for a minimum of 18 hours per day, but the times when supply is available is subject to variation at Energex's absolute discretion (Energex 2016b, Appendix 3). c Small business time-of-use median consumption is split between peak and off-peak as per proportions advised by Energex. Source (of median consumption data): Energex, unpublished data for 2015–16. 2.3.2 Retailers' lowest, highest and average market offer prices Reporting on averages (in this case, retailers' lowest and highest market offer prices in terms of annual bills) can be useful, particularly when dealing with large datasets such as in this review. It allows the data to be usefully summarised for the purposes of reporting and analysis. However, average price information has some shortcomings, given that average prices do not correspond to actual prices in the market, and many offers are not directly comparable.

32 Consumption data was from 2015–16. 33 See QCA 2016a, section 2.2; and subsequent price, competition and market monitoring reports published by the AEMC, ESC, ESCOSA and IPART. 34 St Vincent de Paul 2016.

Queensland Competition Authority Prices and variations

The Direction does not specify the method that we should use to calculate average market offer prices for each retailer. We believe the simplest and most practical approach is to apply a simple (unweighted) average of the annual bill calculations of each retailer's portfolio of relevant offers. We have followed the same approach for estimating the overall average—that is, across all SEQ retailers—for each quarter of 2016–17. We also consider that weighted averages would limit the extent to which we can highlight the dispersion of retailers' offers, and that this would reduce our ability to meet the requirement of the Direction to report on each retailer's prices. By publishing the lowest and highest offers of each retailer, we also address some of the issues raised by QCOSS in respect of a simple average (see Appendix D). The tables in section 2.4 below are supplemented with a dataset, including fixed and variable charges for each standing and market offer, for each of the most common residential and small business tariffs and tariff combinations for the four quarters of 2016–17 as a separate downloadable spreadsheet (on our website) for stakeholders seeking more detail. This report identifies:  which retailer had the cheapest (lowest) market offer  which retailer had the most expensive (highest) market offer  the savings that a customer on a standing offer could have received had the customer switched to the lowest market offer A separate solar feed-in tariff monitoring report has been published by the QCA (October 2017) on the solar feed-in tariffs offered by retailers in 2016–17. Further, all annual bills in this report include Goods and Services Tax (GST) unless otherwise indicated, some figures do not add due to rounding, and retailers are listed in alphabetical order in tables and graphs. Further information on the key assumptions used to calculate annual bills appears in Appendix E. Finally, some retailers' higher priced market offers may have been for solar customers only. As retailers did not apply a common approach to identifying solar-only offers in offers published on Energy Made Easy in 2016–17, we did not remove any market offers from our analysis.

2.3.3 Metering charges As stated in section 2.1.3, retailers may include metering charges in their offers. For example, AGL and Powerdirect noted in some of their offers published on Energy Made Easy that the fixed daily supply charge included a metering charge.35 Energy Made Easy does not, however, require retailers to specify whether a metering charge is included in their offers' fixed charge. We observed that most retailers did not specify on Energy Made Easy whether their fixed charges included metering charges, nor did they identify metering charges as a separate fee type. Through information notices issued under section 89C of the Electricity Act, we asked retailers to specify whether their fixed charges included a metering service charge. All retailers advised that they included or absorbed metering charges in their fixed charges. Therefore, we have not made adjustments to retailers' charges published on Energy Made Easy to account for the inclusion or otherwise of metering charges in fixed charges. As offers

35 Energy Made Easy, AGL and Powerdirect offers published as at the last day of each quarter of 2016–17.

Queensland Competition Authority Prices and variations

included a metering charge in the fixed charge, metering charges are included in the bill calculations in this report. We consider that all retailers should clearly identify their metering charges, or state that they do not levy metering charges if that is the case, in their offers on Energy Made Easy. This would improve the clarity of information for customers and assist comparability between offers.

2.3.4 Distribution non-network charges Retailers' offers published on Energy Made for 2016–17 generally included some distribution non-network charges. The AER pricing guidelines list reconnection and disconnection fees as 'key fees' which must be specified on Energy Made Easy.36 While distribution non-network charges are payable by customers, we have no data on the 'typical' SEQ customer's liability for these fees in 2016–17, and they are only charged when specific services are provided. As a result, they are usually not charged on a quarterly basis as is the case with fixed and variable charges.

2.4 QCA monitoring 2.4.1 Residential flat rate offers September quarter For the September quarter, 15 retailers had standing offers for the residential flat rate tariff published on Energy Made Easy. Ten of these retailers also had at least one residential flat rate market offer published on Energy Made Easy. Table 3 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,479 1,334 1,310 1,385

Click Energy 1,556 1,499 1,371 1,603

Diamond Energy 1,575 n/a n/a n/a

Dodo Power & Gas 1,446 1,349 1,349 1,349

EnergyAustralia 1,509 1,413 1,364 1,449

Lumo Energy 1,458 1,376 1,313 1,458

Mojo Power 1,886 1,491 1,408 1,573

Momentum Energy 1,504 n/a n/a n/a

Next Business Energy 2,070 n/a n/a n/a

Origin Energy 1,491 1,430 1,389 1,491

Powerdirect 1,479 1,412 1,392 1,417

QEnergy 1,559 n/a n/a n/a

Sanctuary Energy 1,446 n/a n/a n/a

36 AER 2015a, section 3.5.

Queensland Competition Authority Prices and variations

Simply Energy 1,446 1,346 1,318 1,375

Urth Energy 1,577 1,433 1,433 1,433

Simple average 1,565 1,408 1,365 1,453

Notes: n/a—The retailer did not have a residential flat rate market offer published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 1 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate offers)

Notes: The standing offers for Mojo Power ($1,886) and Next Business Energy ($2,070) are not included in this graph, as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, Next Business Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The September quarter table and graph show that for a typical residential flat rate tariff customer:  The difference between the average standing offer and the average lowest market offer was $201, with the difference across retailers ranging from $87 (Powerdirect) to $478 (Mojo Power).37  The difference between the average standing offer and the average market offer was $157, with the difference across retailers ranging from $58 (Click Energy) to $396 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $89, with the difference across all retailers ranging from $0 (Dodo Power & Gas and Urth Energy) to $233 (Click Energy).38

37 Powerdirect Residential Electricity Standing Offer and Powerdirect Residential Electricity Market Offer; Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer.

Queensland Competition Authority Prices and variations

Five retailers—Diamond Energy, Momentum Energy, Next Business Energy, QEnergy and Sanctuary Energy—published residential flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

December quarter For the December quarter, 19 retailers had offers for the residential flat rate tariff published on Energy Made Easy. Eighteen of these retailers had residential flat rate standing offers, and 13 of the retailers had at least one residential flat rate market offer, published on Energy Made Easy. Powershop published its residential market offers in the December quarter and its residential standing offer at the beginning of January. Table 4 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,479 1,334 1,310 1,385

Click Energy 1,556 1,499 1,371 1,603

Diamond Energy 1,575 n/a n/a n/a

Dodo Power & Gas 1,446 1,349 1,349 1,349

EnergyAustralia 1,509 1,406 1,343 1,449

Energy Locals 1,538 1,538 1,538 1,538

Lumo Energy 1,458 1,355 1,313 1,458

Mojo Power 1,886 1,491 1,408 1,573

Momentum Energy 1,504 n/a n/a n/a

Next Business Energy 2,070 n/a n/a n/a

Origin Energy 1,491 1,444 1,389 1,491

People Energy 1,446 n/a n/a n/a

Powerdirect 1,479 1,412 1,392 1,417

Powershop n/a 1,367 1,367 1,367

QEnergy 1,559 n/a n/a n/a

Red Energy 1,458 1,313 1,313 1,313

Sanctuary Energy 1,446 n/a n/a n/a

Simply Energy 1,446 1,333 1,290 1,375

Urth Energy 1,577 1,433 1,433 1,433

Simple average 1,551 1,406 1,370 1,442

38 Dodo Power & Gas had one market offer; therefore, the difference between the highest and the lowest market offer is zero. Urth Energy's four market offers yielded that same annual average bill; therefore, the difference between the highest and the lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 Only (highest market offer) and People Power—Tariff 11 Only (lowest market offer).

Queensland Competition Authority Prices and variations

Notes: n/a—The retailer did not have a residential flat rate standing or market offer published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 2 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate offers)

Notes: The standing offers for Mojo Power ($1,886) and Next Business Energy ($2,070) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The December quarter table and graph show that for a typical residential flat rate tariff customer:  The difference between the average standing offer and average lowest market offer was $181, with the difference across retailers ranging from $0 (Energy Locals) to $478 (Mojo Power).39  The difference between the average standing offer and average market offer was $146, with the difference across retailers ranging from $0 (Energy Locals) to $396 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $72, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Powershop, Red Energy and Urth Energy) to $233 (Click Energy).40

39 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore the difference between the standing offer and market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 40 Dodo Power & Gas, Energy Locals and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop and Urth Energy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the

Queensland Competition Authority Prices and variations

Six retailers—Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy—published residential flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

March quarter For the March quarter, 18 retailers had standing offers for the residential flat rate tariff published on Energy Made Easy. Twelve of these retailers also had at least one residential flat rate market offer published on Energy Made Easy. Table 5 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,479 1,340 1,321 1,385

Click Energy 1,556 1,499 1,371 1,603

Diamond Energy 1,575 n/a n/a n/a

Dodo Power & Gas 1,446 1,349 1,349 1,349

EnergyAustralia 1,509 1,406 1,343 1,449

Energy Locals 1,538 1,538 1,538 1,538

Lumo Energy 1,458 1,313 1,313 1,313

Mojo Power 1,886 1,491 1,408 1,573

Momentum Energy 1,504 n/a n/a n/a

Next Business Energy 2,070 n/a n/a n/a

Origin Energy 1,491 1,433 1,369 1,491

People Energy 1,446 n/a n/a n/a

Powerdirect 1,479 1,412 1,392 1,417

Powershop 1,519 1,367 1,367 1,367

QEnergy 1,559 n/a n/a n/a

Red Energy 1,458 1,313 1,313 1,313

Sanctuary Energy 1,446 n/a n/a n/a

Simply Energy 1,446 1,333 1,290 1,375

Simple average 1,548 1,399 1,364 1,431

Notes: n/a—The retailer did not have a residential flat rate market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

highest and the lowest market offer for each retailer is zero. Click Energy's Shine Reward—Tariff 11 Only (highest market offer) and People Power—Tariff 11 Only (lowest market offer).

Queensland Competition Authority Prices and variations

Figure 3 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate offers)

Notes: The standing offers for Mojo Power ($1,886) and Next Business Energy ($2,070) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The March quarter table and graph show that, for a typical residential flat rate tariff customer:  The difference between the average standing offer and the average lowest market offer was $184, with the difference across retailers ranging from $0 (Energy Locals) to $478 (Mojo Power).41  The difference between the average standing offer and the average market offer was $149, with the difference across retailers ranging from $0 (Energy Locals) to $396 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $67, with the difference across all retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Lumo Energy, Powershop, Red Energy) to $233 (Click Energy).42 Six retailers—Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy—published residential flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

41 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 42 Dodo Power & Gas, Energy Locals, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop's two market offers yielded that same annual average bill; therefore, the difference between the highest and the lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 Only (highest market offer) and People Power— Tariff 11 Only (lowest market offer).

Queensland Competition Authority Prices and variations

June quarter For the June quarter, 18 retailers had standing offers for the residential flat rate tariff published on Energy Made Easy. Eleven of these retailers also had at least one residential flat rate market offer published on Energy Made Easy. Table 6 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,479 1,357 1,326 1,385

Click Energy 1,556 1,499 1,371 1,603

Diamond Energy 1,575 n/a n/a n/a

Dodo Power & Gas 1,446 1,349 1,349 1,349

EnergyAustralia 1,509 1,406 1,343 1,449

Energy Locals 1,538 1,538 1,538 1,538

Lumo Energy 1,458 n/a n/a n/a

Mojo Power 1,886 1,584 1,502 1,667

Momentum Energy 1,504 n/a n/a n/a

Next Business Energy 2,070 n/a n/a n/a

Origin Energy 1,491 1,433 1,369 1,491

People Energy 1,446 n/a n/a n/a

Powerdirect 1,479 1,412 1,392 1,417

Powershop 1,519 1,367 1,367 1,367

QEnergy 1,559 n/a n/a n/a

Red Energy 1,458 1,344 1,344 1,344

Sanctuary Energy 1,446 n/a n/a n/a

Simply Energy 1,446 1,333 1,290 1,375

Simple average 1,548 1,420 1,381 1,453

Notes: n/a—The retailer did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 4 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate offers)

Notes: The standing offers for Mojo Power ($1,886) and Next Business Energy ($2,070) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The June quarter table and graph show that for a typical residential flat rate tariff customer:  The difference between the average standing offer and the average lowest market offer was $167, with the difference across retailers ranging from $0 (Energy Locals) to $384 (Mojo Power).43  The difference between the average standing offer and the average market offer was $128, with the difference across retailers ranging from $0 (Energy Locals) to $302 (Mojo Power).  The difference between the average highest market offer and the average lowest market offer was $72, with the difference across all retailers ranging from $0 (Dodo Power &Gas, Energy Locals, Powershop and Red Energy) to $233 (Click Energy).44 Seven retailers—Diamond Energy, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy—published residential flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

43 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 44 Dodo Power &Gas, Energy Locals and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop's two market offers yielded that same annual average bill; therefore, the difference between the highest and the lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 Only (highest market offer) and People Power—Tariff 11 Only (lowest market offer).

Queensland Competition Authority Prices and variations

QCA assessment Increase in retailers publishing offers In the first quarter that electricity prices were deregulated, 15 retailers published residential flat rate offers—either market or standing—on Energy Made Easy. This increased to 19 retailers in the second quarter and remained steady at 18 retailers, after the exit of Urth Energy from the market, for the last two quarters. Six retailers—Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy—published residential flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer. Lumo Energy expired its market offers (early) in the June quarter, although it had published both market and standing offers in previous quarters. Standing offer bills were higher than market offer bills Standing offer bills were generally higher than market offer bills in each of the four quarters.45 Standing offer customers would have saved on electricity bills at any point during the year by switching to the lowest market offer available in the market. Between the June and September 2016 quarters, the average standing offer increased by 8.3 per cent (from $1,446 to $1,565).46 Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to:  AGL's lowest market offer ($1,310) in the September quarter47  Simply Energy's lowest market offer ($1,290) in the December, March and June quarters.48 To lower their electricity bills, customers need to regularly compare offers on Energy Made Easy, especially at the beginning of the financial year. The difference between the average standing offer and the average lowest market offer ranged between $201 (September quarter) and $167 (June quarter). Customers on a standing offer could generally save on electricity bills by moving to a market offer. This report does not characterise the difference between the highest standing offer (Next Business Energy's $2,070 bill) and the lowest market offer as a potential saving for customers. We understand no customers had accepted the highest standing offer in 2016–17 and therefore such savings could not have been achieved by any customer.49 Market offer price variations Customers on market offers also had the opportunity to save on electricity bills by switching to the lowest market offer available. For example, the difference between the highest and lowest market offers in the June quarter was $377. The difference between the average highest market offer and the average lowest market offer ranged between $89 (September quarter) and $67 (March quarter). Retailers applied a variety

45 This does not apply for one retailer (Click Energy) that had a residential flat rate market offer (Shine Reward—Tariff 11 Only) that was $47 higher than its standing offer. 46 See Chapter 5, section 5.3.1. 47 AGL's Savers eBill. 48 Plus 15 Online. 49 Next Business Energy 2017, response to part 2 of the QCA's information notice (unpublished).

Queensland Competition Authority Prices and variations

of discounts and incentives to market offers which could have lowered the overall electricity bill for customers.50 While the general trend was for a small increase in the average market offer (less than 1 per cent between the September and June quarters), three retailers chose to decrease their lowest market offers at different points during the year:  EnergyAustralia decreased its lowest market offer by $21 from $1,364 (September quarter) to $1,343 (December to June quarters).51  Origin Energy decreased its lowest market offer by $20 from $1,389 (September to December quarters) to $1,369 (March to June quarters).52  Simply Energy decreased its lowest market offer by $28 from $1,318 (September quarter) to $1,290 (December to June quarters).53

2.4.2 Residential flat rate with controlled load super economy offers September quarter For the September quarter, 14 retailers had standing offers that combined a residential flat rate tariff with a controlled load super economy tariff published on Energy Made Easy. Ten of these retailers also had at least one market offer published for this tariff combination. Table 7 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate with controlled load super economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,818 1,630 1,572 1,688

Click Energy 1,986 1,910 1,749 2,037

Diamond Energy 1,931 n/a n/a n/a

Dodo Power & Gas 1,742 1,623 1,623 1,623

EnergyAustralia 1,840 1,716 1,650 1,767

Lumo Energy 1,792 1,692 1,613 1,792

Mojo Power 2,285 1,779 1,696 1,861

Momentum Energy 1,843 n/a n/a n/a

Origin Energy 1,829 1,748 1,694 1,829

Powerdirect 1,818 1,705 1,705 1,705

QEnergy 1,885 n/a n/a n/a

Sanctuary Energy 1,731 n/a n/a n/a

50 See Chapter 3 for detail on discounts, savings and benefits attached to offers in 2016–17. 51 Anytime Saver (Home – No Exit Fees) market offer. 52 Origin Maximiser market offer (September to December quarters); Solar Boost Plus (March to June quarters). A condition of the Solar Boost Plus offer is that the customer was required to purchase an eligible solar PV system from Origin Energy. 53 Simply Plus 15 market offer (September quarter); Simply Plus 15 Online market offer (March to June quarters).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Simply Energy 1,742 1,710 1,671 1,748

Urth Energy 1,917 1,730 1,730 1,730

Simple average 1,869 1,724 1,670 1,778

Notes: n/a—The retailer did not have a market offer for this tariff combination published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 5 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate with controlled load super economy offers)

Notes: Mojo Power's standing offer ($2,285) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The September quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load super economy tariff:  The difference between the average standing offer and the average lowest market was $198, with the difference across retailers ranging from $71 (Simply Energy) to $589 (Mojo Power).54  The difference between the average standing offer and the average market offer was $144, with the difference across retailers ranging from $33 (Simply Energy) to $507 (Mojo Power).

54 Simply Energy's Residential Standing Offer (Peak Only—Tariff 8400) with Control Load 1 (9000) and Simply Plus 15 market offer; Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Monthly EnergyPass) market offer.

Queensland Competition Authority Prices and variations

 The difference between the average highest market offer and the average lowest market offer was $108, with the difference across retailers ranging from $0 (Dodo Power & Gas, Powerdirect and Urth Energy) to $288 (Click Energy).55 Four retailers—Diamond Energy, Momentum Energy, QEnergy and Sanctuary Energy— published residential standing offers but did not publish a corresponding market offer.

December quarter For the December quarter, 18 retailers had offers that combined a residential flat rate tariff with a controlled load super economy tariff published on Energy Made Easy. Seventeen of these retailers had standing offers, and 13 had at least one market offer, for this tariff combination. Powershop published its market offers in the December quarter and its standing offer at the beginning of January. Table 8 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate with controlled load super economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,818 1,630 1,572 1,688

Click Energy 1,986 1,910 1,749 2,037

Diamond Energy 1,931 n/a n/a n/a

Dodo Power & Gas 1,742 1,623 1,623 1,623

EnergyAustralia 1,840 1,707 1,623 1,767

Energy Locals 1,987 1,987 1,987 1,987

Lumo Energy 1,792 1,667 1,613 1,792

Mojo Power 2,285 1,779 1,696 1,861

Momentum Energy 1,843 n/a n/a n/a

Origin Energy 1,829 1,767 1,694 1,829

People Energy 1,731 n/a n/a n/a

Powerdirect 1,818 1,705 1,705 1,705

Powershop n/a 1,768 1,767 1,768

QEnergy 1,885 n/a n/a n/a

Red Energy 1,792 1,613 1,613 1,613

Sanctuary Energy 1,731 n/a n/a n/a

Simply Energy 1,742 1,696 1,644 1,748

Urth Energy 1,917 1,730 1,730 1,730

55 Dodo Power & Gas and Powerdirect each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Urth Energy's four market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Simple average 1,863 1,737 1,694 1,781

Notes: n/a—The retailer did not have a standing or market offer for this tariff combination published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 6 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate with controlled load super economy offers)

Notes: Mojo Power's standing offer ($2,285) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The December quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load super economy tariff:  The difference between the average standing offer and the average lowest market offer was $169, with the difference across retailers ranging from $0 (Energy Locals) to $589 (Mojo Power).56  The difference between the average standing offer and the average market offer was $126, with the difference across retailers ranging from $0 (Energy Locals) to $507 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $87, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Powerdirect, Powershop, Red Energy and Urth Energy) to $288 (Click Energy).57

56 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and the market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer.

Queensland Competition Authority Prices and variations

Five retailers—Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy—published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

March quarter For the March quarter, 17 retailers had standing offers that combined a residential flat rate tariff with a controlled load super economy tariff published on Energy Made Easy. Twelve of these retailers also had at least one market offer published for this tariff combination. Table 9 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate with controlled load super economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,818 1,644 1,621 1,688

Click Energy 1,986 1,910 1,749 2,037

Diamond Energy 1,931 n/a n/a n/a

Dodo Power & Gas 1,742 1,623 1,623 1,623

EnergyAustralia 1,840 1,707 1,623 1,767

Energy Locals 1,987 1,987 1,987 1,987

Lumo Energy 1,792 1,613 1,613 1,613

Mojo Power 2,285 1,779 1,696 1,861

Momentum Energy 1,843 n/a n/a n/a

Origin Energy 1,829 1,752 1,667 1,829

People Energy 1,731 n/a n/a n/a

Powerdirect 1,818 1,705 1,705 1,705

Powershop 1,964 1,768 1,767 1,768

QEnergy 1,885 n/a n/a n/a

Red Energy 1,792 1,613 1,613 1,613

Sanctuary Energy 1,731 n/a n/a n/a

Simply Energy 1,742 1,696 1,644 1,748

Simple average 1,866 1,733 1,692 1,770

57 Dodo Power & Gas, Energy Locals, Powerdirect, and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop and Urth Energy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Figure 7 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate with controlled load super economy offers)

Notes: Mojo Power's standing offer ($2,285) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The March quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load super economy tariff:  The difference between the average standing offer and average lowest market offer was $173, with the difference across retailers ranging from $0 (Energy Locals) to $589 (Mojo Power).58  The difference between the average standing offer and average market offer was $133, with the difference across retailers ranging from $0 (Energy Locals) to $507 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $78, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Lumo Energy, Powerdirect, Powershop and Red Energy) to $288 (Click Energy).59

58 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and the market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 59 Dodo Power & Gas, Energy Locals, Lumo Energy, Powerdirect and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 33 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

June quarter For the June quarter, 17 retailers had standing offers that combined a residential flat rate tariff with a controlled load super economy tariff published on Energy Made Easy. Eleven of these retailers also had at least one market offer published for this tariff combination. Table 10 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate with controlled load super economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,818 1,666 1,635 1,695

Click Energy 1,986 1,884 1,749 2,032

Diamond Energy 1,931 n/a n/a n/a

Dodo Power & Gas 1,742 1,623 1,623 1,623

EnergyAustralia 1,840 1,707 1,623 1,767

Energy Locals 1,987 1,987 1,987 1,987

Lumo Energy 1,792 n/a n/a n/a

Mojo Power 2,285 1,906 1,823 1,988

Momentum Energy 1,843 n/a n/a n/a

Origin Energy 1,829 1,752 1,667 1,829

People Energy 1,731 n/a n/a n/a

Powerdirect 1,818 1,705 1,705 1,705

Powershop 1,964 1,768 1,767 1,768

QEnergy 1,885 n/a n/a n/a

Red Energy 1,792 1,682 1,682 1,682

Sanctuary Energy 1,731 n/a n/a n/a

Simply Energy 1,742 1,696 1,644 1,748

Simple average 1,866 1,761 1,719 1,802

Notes: n/a—The retailer did not have a market offer for this tariff combination published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' response to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 8 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate with controlled load super economy offers)

Notes: Mojo Power's standing offer ($2,285) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Lumo Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The June quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load super economy tariff:  The difference between the average standing offer and the average lowest market offer was $147, with the difference across retailers ranging from $0 (Energy Locals) to $462 (Mojo Power).60  The difference between the average standing offer and the average market offer was $104, with the difference across retailers ranging from $0 (Energy Locals) to $380 (Mojo Power).  The difference between the average highest market offer and the average lowest market offer was $84, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Powerdirect, Powershop and Red Energy) to $283 (Click Energy).61

60 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and the market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 61 Dodo Power & Gas, Energy Locals, Powerdirect and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Connect—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Six retailers—Diamond Energy, Lumo Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy—published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

QCA assessment Increase in retailers publishing offers In the first quarter that electricity prices were deregulated, 14 retailers published offers—either market or standing—which combined a residential flat rate with a controlled load super economy tariff, on Energy Made Easy. This increased to 18 retailers in the second quarter and remained steady at 17 retailers, after the exit of Urth Energy from the market, for the last two quarters. Five retailers—Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy—published standing offers for this tariff combination but did not publish a corresponding market offer. Lumo Energy expired its market offers (early) in the June quarter, although it had both market and standing offers published in previous quarters. Next Business Energy did not publish residential market or standing offers that included controlled load, although it had published flat rate standing offers for all quarters. Standing offer bills were higher than market offer bills Similar to residential flat rate standing offers, standing offer bills for this tariff combination were generally higher than market offer bills in each of the four quarters.62 Standing offer customers would have saved on electricity bills at any point during the year by switching to the lowest market offer available in the market. Between the June and September 2016 quarters, the average standing offer increased by 5.4 per cent (from $1,772 to $1,869).63 Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to:  AGL's lowest market offer ($1,572) in the September and December quarters64  either of Lumo Energy's or Red Energy's lowest market offers ($1,613) in the March quarter65  either of Dodo Power & Gas's or EnergyAustralia's lowest market offers ($1,623) in the June quarter.66 The difference between the average standing offer and the average lowest market offer ranged between $198 (September quarter) and $147 (June quarter). Customers on a standing offer could generally save on electricity bills by moving to their retailer's market offers, or by comparing market offers across retailers.

62 This does not apply for two retailers: Click Energy's highest market offer (Connect—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) in the March quarter) was $51 higher than its standing offer; Simply Energy's highest market offer (Simply Save 10) was $6 higher than its standing offer. 63 See Chapter 5, section 5.3.2. 64 AGL Savers eBill. AGL expired this offer in January 2017. 65 Lumo Business Advantage (Residential Tariffs Only) and Easy Saver 10%–Residential respectively. Lumo Energy's offer was available to residential and small business customers but we included it in the residential tariff reporting: see Appendix E for detail. Lumo Energy and Red Energy expired these offers in April 2017. 66 Energex Res & Controlled Load No Term Market Offer and Flexi Saver (Home – Peak with Controlled Load 1 – No Exit Fees) respectively.

Queensland Competition Authority Prices and variations

Market offer price variations Customers on market offers also had the opportunity to save on electricity bills by switching to the lowest market offer available. For example, the difference between the highest and lowest market offer in the September quarter was $466. The difference between the average highest market offer and the average lowest market offer ranged between $108 (September quarter) and $78 (March quarter). By comparing retailers' market offers for this tariff combination, customers had the opportunity to switch to a better market offer. Retailers applied a variety of discounts and incentives to market offers which could have lowered the overall electricity bill for customers.67 While the average market offer increased by just over 2 per cent between the September and June quarters, three retailers chose to decrease their lowest market offers at different points during the year. These are the same retailers that decreased their residential flat rate market offers:  EnergyAustralia decreased its lowest market offer by $27 from $1,650 (September quarter) to $1,623 (December to June quarters).68  Origin Energy decreased its lowest market offer by $27 from $1,694 (September to December quarters) to $1,667 (March to June quarters).69  Simply Energy decreased its lowest market offer by $27 from $1,671 (September quarter) to $1,644 (December to June quarters).70

2.4.3 Residential flat rate with controlled load economy offers September quarter For the September quarter, 14 retailers had standing offers that combined a residential flat rate tariff with a controlled load economy tariff published on Energy Made Easy. Ten of these retailers also had at least one market offer published for this tariff combination. Table 11 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate with controlled load economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,776 1,596 1,553 1,651

Click Energy 1,908 1,835 1,680 1,958

Diamond Energy 1,877 n/a n/a n/a

Dodo Power & Gas 1,734 1,611 1,611 1,611

EnergyAustralia 1,791 1,671 1,608 1,720

Lumo Energy 1,752 1,653 1,576 1,752

Mojo Power 2,216 1,729 1,647 1,812

67 See Chapter 3 for detail on discounts, savings and benefits attached to offers in 2016–17. 68 Flexi Saver (Home) Peak With Controlled Load 1 (No Exit Fees) (all quarters). A condition of the Solar Boost Plus offer is that the customer was required to purchase an eligible solar PV system from Origin Energy. 69 Origin Maximiser market offer (December quarter) and Solar Boost Plus market offer (March quarter). 70 Simply Plus 15 market offer (September quarter) and Simply Plus 15 Online market offer (December quarter).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Momentum Energy 1,801 n/a n/a n/a

Origin Energy 1,795 1,716 1,663 1,795

Powerdirect 1,776 1,667 1,667 1,667

QEnergy 1,857 n/a n/a n/a

Sanctuary Energy 1,722 n/a n/a n/a

Simply Energy 1,734 1,658 1,621 1,696

Urth Energy 1,872 1,691 1,691 1,691

Simple average 1,829 1,683 1,632 1,735

Notes: n/a—The retailer did not have a market offer for this tariff combination published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 9 Annual bills for a typical residential customer, by retailer, 30 September 2016 (residential flat rate with controlled load economy offers)

Notes: Mojo Power's standing offer ($2,216) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The September quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load economy tariff:

Queensland Competition Authority Prices and variations

 The difference between the average standing offer and the average lowest market offer was $198, with the difference across retailers ranging from $110 (Powerdirect) and $569 (Mojo Power).71  The difference between the average standing offer and the average market offer was $147, with the difference across retailers ranging from $73 (Click Energy) to $487 (Mojo Power).  The difference between the average highest market offer and the average lowest market offer was $103, with the difference across retailers ranging from $0 (Dodo Power & Gas, Powerdirect and Urth Energy) to $278 (Click Energy).72 Four retailers—Diamond Energy, Momentum Energy, QEnergy and Sanctuary Energy— published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

December quarter For the December quarter, 18 retailers had offers that combined a residential flat rate tariff with a controlled load economy tariff published on Energy Made Easy. Seventeen of these retailers had a standing offer for this tariff combination, and 13 retailers had at least one market offer for this combination. Powershop published its market offers in the December quarter and its standing offer at the beginning of January. Table 12 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate with controlled load economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,776 1,596 1,553 1,651

Click Energy 1,908 1,835 1,680 1,958

Diamond Energy 1,877 n/a n/a n/a

Dodo Power & Gas 1,734 1,611 1,611 1,611

EnergyAustralia 1,791 1,663 1,582 1,720

Energy Locals 1,895 1,895 1,895 1,895

Lumo Energy 1,752 1,628 1,576 1,752

Mojo Power 2,216 1,729 1,647 1,812

Momentum Energy 1,801 n/a n/a n/a

Origin Energy 1,795 1,734 1,663 1,795

People Energy 1,722 n/a n/a n/a

71 Powerdirect Residential Electricity Standing Offer and Powerdirect Residential Electricity Market Offer; Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass). 72 Dodo Power & Gas and Powerdirect each had one market offer; therefore, the difference between the highest and lowest market offer for each retailers is zero. Urth Energy's four market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Powerdirect 1,776 1,667 1,667 1,667

Powershop n/a 1,686 1,686 1,686

QEnergy 1,857 n/a n/a n/a

Red Energy 1,752 1,576 1,576 1,576

Sanctuary Energy 1,722 n/a n/a n/a

Simply Energy 1,734 1,645 1,594 1,696

Urth Energy 1,872 1,691 1,691 1,691

Simple average 1,822 1,689 1,648 1,731

Notes: n/a—The retailer did not have a standing or market offer for this tariff combination published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. Figure 10 Annual bills for a typical residential customer, by retailer, 31 December 2016 (residential flat rate with controlled load economy offers)

Notes: Mojo Power's standing offer ($2,216) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The December quarter table and graph show that, for a typical customer on a combined residential flat rate with controlled load economy tariff:

Queensland Competition Authority Prices and variations

 The difference between the average standing offer and average lowest market offer was $175, with the difference across retailers ranging from $0 (Energy Locals) to $569 (Mojo Power).73  The difference between the average standing offer and the average market offer was $133, with the difference across retailers ranging from $0 (Energy Locals) to $487 (Mojo Power).  The difference between the average highest market offer and the average lowest market offer was $84, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Powerdirect, Powershop, Red Energy, Urth Energy) to $278 (Click Energy).74 Five retailers—Diamond Energy, Momentum Energy, People Energy, QEnergy, Sanctuary Energy—published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

March quarter For the March quarter, 17 retailers had standing offers that combined a residential flat rate tariff with a controlled load economy tariff published on Energy Made Easy. Twelve of these retailers also had at least one market offer published for this tariff combination. Table 13 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate with controlled load economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,776 1,607 1,584 1,651

Click Energy 1,908 1,835 1,680 1,958

Diamond Energy 1,877 n/a n/a n/a

Dodo Power & Gas 1,734 1,611 1,611 1,611

EnergyAustralia 1,791 1,663 1,582 1,720

Energy Locals 1,895 1,895 1,895 1,895

Lumo Energy 1,752 1,576 1,576 1,576

Mojo Power 2,216 1,729 1,647 1,812

Momentum Energy 1,801 n/a n/a n/a

Origin Energy 1,795 1,720 1,637 1,795

People Energy 1,722 n/a n/a n/a

Powerdirect 1,776 1,667 1,667 1,667

73 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and the market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 74 Dodo Power & Gas, Energy Locals, Powerdirect and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer was zero. Powershop and Urth Energy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Powershop 1,873 1,686 1,686 1,686

QEnergy 1,857 n/a n/a n/a

Red Energy 1,752 1,576 1,576 1,576

Sanctuary Energy 1,722 n/a n/a n/a

Simply Energy 1,734 1,645 1,594 1,696

Simple average 1,822 1,684 1,645 1,720

Notes: n/a—The retailer did not have a market offer for this tariff combination published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. Figure 11 Annual bills for a typical residential customer, by retailer, 31 March 2017 (residential flat rate with controlled load economy offers)

Notes: Mojo Power's standing offer ($2,216) is not included in this graph as it is above the range of other standing offers and its inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The March quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load economy tariff:

Queensland Competition Authority Prices and variations

 The difference between the average standing offer and average lowest market offer was $178, with the difference across retailers ranging from $0 (Energy Locals) to $569 (Mojo Power).75  The difference between the average standing offer and average market offer was $138, with the difference across retailers ranging from $0 (Energy Locals) to $487 (Mojo Power).  The difference between the average highest market offer and the average lowest market offer was $76, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Lumo Energy, Powerdirect, Powershop and Red Energy) to $278 (Click Energy).76 Five retailers—Diamond Energy, Momentum Energy, People Energy, QEnergy, Sanctuary Energy—published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

June quarter For the June quarter, 17 retailers had standing offers that combined a residential flat rate tariff with a controlled load economy tariff published on Energy Made Easy. Eleven of these retailers also had at least one market offer published for this tariff combination. Table 14 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate with controlled load economy offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 1,776 1,628 1,597 1,657

Click Energy 1,908 1,810 1,680 1,952

Diamond Energy 1,877 n/a n/a n/a

Dodo Power & Gas 1,734 1,611 1,611 1,611

EnergyAustralia 1,791 1,663 1,582 1,720

Energy Locals 1,895 1,895 1,895 1,895

Lumo Energy 1,752 n/a n/a n/a

Mojo Power 2,216 1,832 1,750 1,915

Momentum Energy 1,801 n/a n/a n/a

Origin Energy 1,795 1,720 1,637 1,795

People Energy 1,722 n/a n/a n/a

75 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 76 Dodo Power & Gas, Energy Locals, Lumo Energy, Powerdirect and Red Energy each had one market offer; therefore, the difference between the highest and lowest market for each retailer is zero. Powershop's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer).

Queensland Competition Authority Prices and variations

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

Powerdirect 1,776 1,667 1,667 1,667

Powershop 1,873 1,686 1,686 1,686

QEnergy 1,857 n/a n/a n/a

Red Energy 1,752 1,626 1,626 1,626

Sanctuary Energy 1,722 n/a n/a n/a

Simply Energy 1,734 1,645 1,594 1,696

Simple average 1,822 1,707 1,666 1,747

Notes: n/a—The retailer did not have a market offer for this tariff combination published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. Figure 12 Annual bills for a typical residential customer, by retailer, 30 June 2017 (residential flat rate with controlled load economy offers)

Notes: Mojo Power's standing offer ($2,216) is not included in this graph as it is above the range of other standing and market offers and its inclusion would make comparisons between other market and standing offers difficult. Diamond Energy, Lumo Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy did not have a market offer for this tariff combination published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The June quarter table and graph show that for a typical customer on a combined residential flat rate with controlled load economy tariff:

Queensland Competition Authority Prices and variations

 The difference between the average standing offer and the average lowest market offer was $157, with the difference across retailers ranging from $0 (Energy Locals) to $466 (Mojo Power).77  The difference between the average standing offer and the average market offer was $115, with the difference across retailers ranging from $0 (Energy Locals) to $384 (Mojo Power).  The difference between the average highest market offer and average lowest market offer was $81, with the difference across retailers ranging from $0 (Dodo Power & Gas, Energy Locals, Powerdirect, Powershop and Red Energy) to $272 (Click Energy).78 Six retailers—Diamond Energy, Lumo Energy, Momentum Energy, People Energy, QEnergy and Sanctuary Energy—published residential standing offers on Energy Made Easy but did not publish a corresponding market offer.

77 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Mojo Power's Energy Without Benefits standing offer and Energy With Benefits (Annual EnergyPass) market offer. 78 Dodo Power & Gas, Energy Locals, Powerdirect and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powershop's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Click Energy's Connect—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (highest market offer) and People Power—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) (lowest market offer). 79 This does not apply to Click Energy, as its highest market offer (Shine Reward—Tariff 11 and Tariff 31 (Night Rate) and Tariff 33 (Controlled Supply) for the September to March quarters) was $50 higher than its standing offer.

Queensland Competition Authority Prices and variations

Between the June and September 2016 quarters, the average standing offer increased by 4.0 per cent (from $1,760 to $1,829).80 Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to:  AGL's lowest market offer ($1,553) in the September and December quarters81  either of Lumo Energy's or Red Energy's lowest market offers ($1,576) in the March quarter82  EnergyAustralia's lowest market offer in the June quarter ($1,582).83 The difference between the average standing offer and the average lowest market offer ranged between $198 (September quarter) to $157 (June quarter). Customers on a standing offer could generally save on electricity bills by either moving to their retailer's market offer, or by comparing market offers across retailers. Market offer price variations Customers on market offers also had the opportunity to save on electricity bills by switching to the lowest market offer available. For example, the difference between the highest and lowest market offer in the September quarter was $406. The difference between the average highest market offer and the average lowest market offer ranged between $103 (September quarter) and $76 (March quarter). By comparing retailer market offers for this tariff combination, customers had the opportunity to switch to a better market offer. Retailers applied a variety of discounts and incentives to market offers which could have lowered the overall electricity bill for customers.84 While the average market offer increased by around 1.5 per cent between the September and June quarters, three retailers chose to adjust (decrease) their lowest market offers at different points during the year. These are the same retailers that adjusted their residential flat rate market offers:  EnergyAustralia decreased its lowest market offer by $26 from $1,608 (September quarter) to $1,582 (December to June quarters).85  Origin Energy decreased its lowest market offer by $26 from $1,663 (September to December quarters) to $1,637 (March to June quarters).86  Simply Energy decreased its lowest market offer by $27 from $1,621 (September quarter) to $1,594 (December to June quarters).87

80 See Chapter 5, section 5.3.3. 81 AGL Savers eBill. AGL expired this offer in January 2017. 82 Lumo Business Advantage (Residential Tariffs Only) and Easy Saver 10%–Residential respectively. Lumo Energy's offer was available to small business customers but we included it in the residential tariff reporting: see Appendix E for detail. Lumo Energy and Red Energy expired these offers in April 2017. 83 Flexi Saver (Home – Peak with Controlled Load 2 – No Exit Fees). 84 See Chapter 3 for detail on discounts, savings and benefits attached to offers in 2016–17. 85 Flexi Saver (Home) Peak With Controlled Load 2 (No Exit Fees) market offer (all quarters). 86 Origin Maximiser market offer (December quarter) and Solar Boost Plus market offer (March quarter). 87 Simply Plus 15 (all quarters).

Queensland Competition Authority Prices and variations

2.4.4 Small business flat rate offers September quarter For the September quarter, 13 retailers had small business flat rate standing offers published on Energy Made Easy. Ten of these retailers also had at least one small business flat rate market offer published on Energy Made Easy. Table 15 Annual bills for a typical small business customer, by retailer, 30 September 2016 (small business flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 2,377 2,136 2,103 2,165

Click Energy 2,384 2,217 2,217 2,217

Diamond Energy 2,430 n/a n/a n/a

EnergyAustralia 2,277 2,139 2,072 2,192

ERM Power 2,917 2,215 2,215 2,215

Lumo Energy 2,334 2,133 2,091 2,175

Momentum Energy 2,378 n/a n/a n/a

Next Business Energy 3,218 n/a n/a n/a

Origin Energy 2,387 2,229 2,150 2,387

Powerdirect 2,377 2,194 2,194 2,194

QEnergy 2,594 2,594 2,594 2,594

Simply Energy 2,129 2,165 2,165 2,165

Urth Energy 2,410 2,170 2,170 2,170

Simple average 2,478 2,219 2,197 2,247

Notes: n/a—The retailer did not have a small business flat rate market offer published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 13 Annual bills for a typical small business customer, by retailer, 30 September 2016 (small business flat rate offers)

Notes: The standing offers for ERM Power ($2,917) and Next Business Energy ($3,218) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The September quarter table and graph show that, for a typical customer on a small business flat rate tariff:  The difference between the average standing offer and the average lowest market offer was $281, with the difference across retailers ranging from -$36 (Simply Energy) to $701 (ERM Power).88  The difference between the average standing offer and the average market offer was $258, with the difference across retailers ranging from -$36 (Simply Energy) to $701 (ERM Power).  The difference between the average highest market offer and the average lowest market offer was $50, with the difference across retailers ranging from $0 (Click Energy, ERM Power, Powerdirect, QEnergy, Simply Energy and Urth Energy) to $237 (Origin Energy).89 Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

88 Simply Energy's SME Standing Offer (Peak Only) standing offer and Business Save 10 market offer. ERM Power's Business Energy standing offer and Business Energy Adjustable—Single Rate market offer. 89 Click Energy, ERM Power and Simply Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powerdirect, QEnergy and Urth Energy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Origin Energy's Supply (Tariff 20) (highest market offer) and BusinessSaver Electricity Usage Discount (Tariff 20) and Business eSaver Off Electricity Usage Discount (Tariff 20) (both lowest market offers).

Queensland Competition Authority Prices and variations

December quarter For the December quarter, 16 retailers had small business flat rate offers published on Energy Made Easy. Fifteen of these retailers had small business flat rate standing offers, and 13 had at least one small business flat rate market offer published on Energy Made Easy. Powershop published its market offers in the December quarter and its standing offer at the beginning of January. Table 16 Annual bills for a typical small business customer, by retailer, 31 December 2016 (small business flat rate market offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 2,377 2,136 2,103 2,165

Click Energy 2,384 2,217 2,217 2,217

Diamond Energy 2,430 n/a n/a n/a

EnergyAustralia 2,277 2,127 2,022 2,192

Energy Locals 2,479 2,479 2,479 2,479

ERM Power 2,917 2,215 2,215 2,215

Lumo Energy 2,334 2,091 2,091 2,091

Momentum Energy 2,378 n/a n/a n/a

Next Business Energy 3,218 n/a n/a n/a

Origin Energy 2,387 2,229 2,150 2,387

Powerdirect 2,377 2,194 2,194 2,194

Powershop n/a 2,258 2,258 2,258

QEnergy 2,594 2,594 2,594 2,594

Red Energy 2,334 2,100 2,100 2,100

Simply Energy 2,129 2,151 2,137 2,165

Urth Energy 2,410 2,170 2,170 2,170

Simple average 2,468 2,228 2,210 2,248

Notes: n/a—The retailer did not have a small business flat rate standing or market offer published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 14 Annual bills for a typical small business customer, by retailer, 31 December 2016 (small business flat rate offers)

Notes: The standing offers for ERM Power ($2,917) and Next Business Energy ($3,218) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business flat rate market offer published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The December quarter table and graph show that, for a typical customer on a small business flat rate tariff:  The difference between the average standing offer and the average lowest market offer was $258, with the difference across retailers ranging from -$8 (Simply Energy) to $701 (ERM Power).90  The difference between the average standing offer and the average market offer was $240, with the difference across retailers ranging from -$22 (Simply Energy) to $701 (ERM Power).  The difference between the average highest market offer and the average lowest market offer was $38, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, Powerdirect, Powershop, QEnergy, Red Energy and Urth Energy) to $237 (Origin Energy).91

90 Simply Energy's Residential Standing Offer (Peak Only–Tariff 8400) standing offer and Business Save 10 Online market offer. ERM Power's Business Energy standing offer and Business Energy Adjustable—Single Rate market offer. 91 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powerdirect, Powershop and Urth Energy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each of these retailers is zero. Origin Energy's Supply (Tariff 20) (highest market offer) and BusinessSaver Electricity Usage Discount (Tariff 20) and Business eSaver Off Electricity Usage Discount (Tariff 20) (both lowest market offers).

Queensland Competition Authority Prices and variations

Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer.

March quarter For the March quarter, 15 retailers had small business flat rate standing offers published on Energy Made Easy. Twelve of these retailers also had at least one small business flat rate market offer published on Energy Made Easy. Table 17 Annual bills for a typical small business customer, by retailer, 31 March 2017 (small business flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 2,377 2,136 2,103 2,165

Click Energy 2,384 2,217 2,217 2,217

Diamond Energy 2,430 n/a n/a n/a

EnergyAustralia 2,277 2,139 2,072 2,192

Energy Locals 2,479 2,479 2,479 2,479

ERM Power 2,917 2,215 2,215 2,215

Lumo Energy 2,334 2,091 2,091 2,091

Momentum Energy 2,378 n/a n/a n/a

Next Business Energy 3,218 n/a n/a n/a

Origin Energy 2,387 2,229 2,150 2,387

Powerdirect 2,377 2,194 2,194 2,194

Powershop 2,509 2,258 2,258 2,258

QEnergy 2,594 2,594 2,594 2,594

Red Energy 2,334 2,100 2,100 2,100

Simply Energy 2,129 2,137 2,110 2,165

Simple average 2,475 2,233 2,215 2,255

Notes: n/a—The retailer did not have a small business flat rate market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 15 Annual bills for a typical small business customer, by retailer, 31 March 2017 (small business flat rate offers)

Notes: The standing offers for ERM Power ($2,917) and Next Business Energy ($3,218) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business flat rate market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The March quarter table and graph show that, for a typical customer on a small business flat rate tariff:  The difference between the average standing offer and the average lowest market offer was $259, with the difference across retailers ranging from $0 (Energy Locals and QEnergy) to $701 (ERM Power).92  The difference between the average standing offer and the average market offer was $242, with the difference across retailers ranging from -$8 (Simply Energy) to $701 (ERM Power).  The difference between the average highest market offer and the average lowest market offer was $39, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, Powerdirect, Powershop, QEnergy and Red Energy) to $237 (Origin Energy).93

92 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Similarly, the difference between QEnergy's standing offer and market offers is zero. ERM Power's Business Energy Standing Offer and Business Energy Adjustable—Single Rate market offer. 93 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each of these retailers is zero. Powerdirect, Powershop and QEnergy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Origin Energy's Supply (Tariff 20) (highest market offer) and BusinessSaver Electricity Usage Discount (Tariff 20) and Business eSaver Off Electricity Usage Discount (Tariff 20) (both lowest market offers).

Queensland Competition Authority Prices and variations

 Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business flat rate standing offers but did not publish a corresponding market offer.

June quarter For the June quarter, 15 retailers had small business flat rate offers published on Energy Made Easy. Fourteen of these retailers had small business flat rate standing offers, and 12 had at least one small business flat rate market offer. Simply Energy did not have a small business flat rate standing offer published on Energy Made Easy in the June quarter (as at 30 June 2017). Table 18 Annual bills for a typical small business customer, by retailer, 30 June 2017 (small business flat rate offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 2,377 2,136 2,103 2,165

Click Energy 2,384 2,217 2,217 2,217

Diamond Energy 2,430 n/a n/a n/a

EnergyAustralia 2,277 2,114 1,972 2,192

Energy Locals 2,479 2,479 2,479 2,479

ERM Power 2,917 2,335 2,335 2,335

Lumo Energy 2,334 2,174 2,174 2,174

Momentum Energy 2,378 n/a n/a n/a

Next Business Energy 3,218 n/a n/a n/a

Origin Energy 2,387 2,229 2,150 2,387

Powerdirect 2,377 2,194 2,194 2,194

Powershop 2,509 2,258 2,258 2,258

QEnergy 2,594 2,805 2,805 2,805

Red Energy 2,334 2,172 2,172 2,172

Simply Energy n/a 2,137 2,110 2,165

Simple average 2,500 2,271 2,247 2,295

Notes: n/a—The retailer did not have a small business flat rate standing or market offer published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 16 Annual bills for a typical small business customer, by retailer, 30 June 2017 (small business flat rate offers)

Notes: The standing offers for ERM Power ($2,917) and Next Business Energy ($3,218) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business flat rate market offer, and Simply Energy did not have a small business flat rate standing offer, published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The June quarter table and graph show that, for a typical customer on a small business flat rate tariff:  The difference between the average standing offer and the average lowest market offer was $252, with the difference across all retailers ranging from -$211 (QEnergy) to $582 (ERM Power).94  The difference between the average standing offer and the average market offer was $229, with the difference across retailers ranging from -$211 (QEnergy) to $582 (ERM Power).  The difference between the average highest market offer and the average lowest market offer was $48, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, Powerdirect, Powershop, QEnergy and Red Energy) to $237 (Origin Energy).95 Three retailers—Diamond Energy, Momentum Energy, Next Business Energy—published small business flat rate standing offers but did not publish a corresponding market offer.

94QEnergy Biz Your Way Single Rate standing offer and Biz Saver Single Rate and Freedom Biz Single Rate market offers. ERM Power's Business Energy standing offer and Business Energy Adjustable—Single Rate market offer. 95 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. Powerdirect, Powershop and QEnergy's several market offers yielded the same annual average bill for each retailer; therefore, the difference between the highest and lowest market offer for each retailer is zero.

Queensland Competition Authority Prices and variations

QCA assessment Increase in retailers publishing offers In the first quarter that electricity prices were deregulated, 13 retailers published small business flat rate offers—either market or standing—on Energy Made Easy. This increased to 16 retailers in the second quarter and remained steady at 15 retailers, after the exit of Urth Energy from the market, for the last two quarters. Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business flat rate standing offers on Energy Made Easy but did not publish a corresponding market offer. Standing offer bills were higher than market offer bills Standing offer bills were generally higher than market offer bills for small business flat rate customers. Standing offer customers would have saved on electricity bills at any point during the year by switching to the lowest market offer available in the market. Between the June and September 2016 quarters, the average standing offer increased by 15.7 per cent (from $2,142 to $2,478).96 Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to:  EnergyAustralia's lowest market offer ($2,072) in the September quarter97  EnergyAustralia's (new) lowest market offer ($2,022) in the December quarter98  EnergyAustralia's (new) lowest offer ($2,072) in the March quarter99  EnergyAustralia's (new) lowest offer ($1,972) in the June quarter.100 The offers in December and June quarters were lower (by $50 and $100 respectively) because EnergyAustralia's lowest offers then included sign-up incentives. The difference between the average standing offer and the average lowest market offer ranged between $281 (September quarter) to $252 (June quarter). Customers on a standing offer could generally save on electricity bills by moving to their retailer's market offer, or by comparing market offers across retailers. This report does not characterise the difference between the highest standing offer (Next Business Energy's $3,218 bill) and the lowest market offer as a potential saving for customers. We understand no customers had accepted the highest standing offer in 2016–17 and therefore such savings could not have been achieved by any customer.101 We also understand that only a very small number of customers were contracted to ERM Power's standing offer ($2,917 bill) during (part of) the year.102

96 See Chapter 5, section 5.3.4. 97 Everyday Saver (Business). This offer was available from 29 September to 19 December 2016. 98 Everyday Saver (Business). This offer was available from 19 December 2016 to 2 January 2017. 99 Basic Saver (Business). This offer was available from 9 March to 18 May 2017. 100 Basic Saver (Business). This offer was available from 18 May to 3 July 2017, and included a $100 credit (GST incl.) off the first electricity bill. The small business flat rate market offers EnergyAustralia published in July and August 2017 (for the 2017–18 financial year) did not include sign-up incentives (source: Energy Made Easy). 101 Next Business Energy 2017, response to part 2 of the QCA's information notice (unpublished). 102 ERM Power 2017, response to part 2 of the QCA's information notice (unpublished).

Queensland Competition Authority Prices and variations

Market offer price variations Customers on market offers also had the opportunity to save on electricity bills at any point during the year by switching to the lowest market offer available. For example, the difference between the highest market offer and the lowest market offer in the June quarter was $833. The difference between the average highest market offer and average lowest market offer ranged between $38 (December quarter) and $50 (September quarter). By comparing retailers' market offers, small business customers had the opportunity to switch to a better market offer. Retailers applied a variety of discounts and incentives to market offers which could have lowered the overall electricity bill for customers.103 While the average market offer increased by almost 2.5 per cent between the September and June quarters, two retailers chose to adjust (decrease) their lowest market offer at different points during the year:  EnergyAustralia decreased its lowest market offer by $50 from $2,072 (September quarter) to $2,022 (December quarter), and by $100 from $2,072 (March quarter) to $1,972 (June quarter).104  Simply Energy decreased its lowest market offer by $28 from $2,165 (September quarter) to $2,137 (December quarter), and by a further $27 to $2,110 (March to June quarters).105

2.4.5 Small business time-of-use offers September quarter For the September quarter, 13 retailers had small business time-of-use offers published on Energy Made Easy. Twelve of these retailers had small business time-of-use standing offers, and 10 of the retailers had at least one small business time-of-use market offer. Simply Energy did not publish a small business time-of-use standing offer on Energy Made Easy until the March quarter.

103 See Chapter 3 for detail on discounts, savings and benefits attached to offers in 2016–17. 104 Basic Saver (Business) market offer (all quarters). 105 Business Save 10 Online market offer (all quarters).

Queensland Competition Authority Prices and variations

Table 19 Annual bills for a typical small business customer, by retailer, 30 September 2016 (small business time-of-use offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 6,535 5,763 5,637 5,876

Click Energy 6,468 6,015 6,015 6,015

Diamond Energy 6,519 n/a n/a n/a

EnergyAustralia 6,062 5,630 5,402 5,819

ERM Power 7,941 6,312 6,312 6,312

Lumo Energy 6,388 5,822 5,718 5,926

Momentum Energy 6,537 n/a n/a n/a

Next Business Energy 9,190 n/a n/a n/a

Origin Energy 6,543 6,025 5,766 6,543

Powerdirect 6,535 5,949 5,937 5,962

QEnergy 7,091 7,091 7,091 7,091

Simply Energy n/a 5,811 5,811 5,811

Urth Energy 6,931 6,006 5,714 6,103

Simple average 6,895 6,042 5,940 6,146

Notes: n/a—The retailer did not have a small business TOU standing or market offer published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 17 Annual bills for a typical small business customer, by retailer, 30 September 2016 (small business time-of-use offers)

Notes: The standing offers for ERM Power ($7,941) and Next Business Energy ($9,190) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business TOU market offer, and Simply Energy did not have a small business TOU standing offer, published on Energy Made Easy as at 30 September 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The September quarter table and graph show that, for a typical customer on a small business time-of-use tariff:  The difference between the average standing offer and the average lowest market offer was $954, with the difference across retailers ranging from $0 (QEnergy) to $1,628 (ERM Power).106  The difference between the average standing offer and the average market offer was $852, with the difference across retailers ranging from $0 (QEnergy) to $1,628 (ERM Power).  The difference between the average highest market offer and average lowest market offer was $206, with the difference across retailers ranging from $0 (Click Energy, ERM Power, QEnergy and Simply Energy) to $777 (Origin Energy).107

106 QEnergy's standing offer and lowest market offer yielded the same annual average bill; therefore the difference between the standing offer and market offer is zero. ERM Power's Business Energy Standing Offer and Business Energy Adjustable—TOU market offer. 107 Click Energy, ERM Power and Simply Energy each had one market offer; therefore the difference between the highest and lowest market offer for each retailer is zero. QEnergy's two market offers yielded the same annual average bill; therefore the difference between the highest and lowest market offer is zero. Origin Energy's Supply (Tariff 22) (highest market offer) and Business eSaver Off Electricity Usage Discount (Tariff 22) and BusinessSaver Electricity Usage Discount (Tariff 22) (lowest market offers).

Queensland Competition Authority Prices and variations

Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business time-of-use of standing offers on Energy Made Easy but did not publish a corresponding market offer.

December quarter For the December quarter, 16 retailers had small business time-of-use offers published on Energy Made Easy. Fourteen of these retailers had small business time-of-use standing offers, and 13 had at least one small business time-of-use market offer. Powershop published its market offers in the December quarter and its standing offer at the beginning of January. Simply Energy did not publish a small business time-of-use standing offer until the March quarter. Table 20 Annual bills for a typical small business customer, by retailer, 31 December 2016 (small business time-of-use offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 6,535 5,763 5,637 5,876

Click Energy 6,468 6,015 6,015 6,015

Diamond Energy 6,519 n/a n/a n/a

EnergyAustralia 6,062 5,618 5,352 5,819

Energy Locals 6,824 6,824 6,824 6,824

ERM Power 7,941 6,312 6,312 6,312

Lumo Energy 6,388 5,718 5,718 5,718

Momentum Energy 6,537 n/a n/a n/a

Next Business Energy 9,190 n/a n/a n/a

Origin Energy 6,543 6,025 5,766 6,543

Powerdirect 6,535 5,949 5,937 5,962

Powershop n/a 6,266 6,265 6,266

QEnergy 7,091 7,091 7,091 7,091

Red Energy 6,388 5,749 5,749 5,749

Simply Energy n/a 5,784 5,756 5,811

Urth Energy 6,931 6,006 5,714 6,103

Simple average 6,853 6,086 6,010 6,161

Notes: n/a—The retailer did not have a small business TOU standing or market offer published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 18 Annual bills for a typical small business customer, by retailer, 31 December 2016 (small business time-of-use offers)

Notes: The standing offers for ERM Power ($7,941) and Next Business Energy ($9,190) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business TOU market offer, and Simply Energy did not have a small business TOU standing offer, published on Energy Made Easy as at 31 December 2016. Sources: Energy Made Easy; retailers' responses to part 1 of the QCA information notice; QCA analysis. The December quarter table and graph show that, for a typical customer on a small business time-of-use tariff:  The difference between the average standing offer and the average lowest market offer was $843, with the difference across retailers ranging from $0 (Energy Locals and QEnergy) to $1,628 (ERM Power).108  The difference between the average standing offer and average market offer was $767, with the difference across retailers ranging from $0 (Energy Locals and QEnergy) to $1,628 (ERM Power).  The difference between the average highest market offer and average lowest market offer was $150, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, QEnergy and Red Energy) to $777 (Origin Energy).109

108 Energy Locals' standing offer and lowest market offer yielded the same annual average bill; therefore, the difference between the standing offer and market offer is zero. Similarly, the difference between QEnergy's standing offer and market offers is zero. ERM Power's Business Energy Standing Offer and Business Energy Adjustable—TOU market offer. 109 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore the difference between the highest and lowest market offer for each retailer is zero. QEnergy's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Origin Energy's Supply (Tariff 22) (highest market offer) and Business eSaver Off Electricity Usage Discount (Tariff 22) and BusinessSaver Electricity Usage Discount (Tariff 22) (lowest market offers).

Queensland Competition Authority Prices and variations

Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business time-of-use standing offers on Energy Made Easy but did not publish a corresponding market offer.

March quarter For the March quarter, 15 retailers had small business time-of-use standing offers published on Energy Made Easy. Twelve of these retailers also had at least one small business time-of-use market offer published on Energy Made Easy. Table 21 Annual bills for a typical small business customer, by retailer, 31 March 2017 (small business time-of-use offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 6,535 5,763 5,637 5,876

Click Energy 6,468 6,015 6,015 6,015

Diamond Energy 6,519 n/a n/a n/a

EnergyAustralia 6,062 5,630 5,402 5,819

Energy Locals 6,824 6,824 6,824 6,824

ERM Power 7,941 6,312 6,312 6,312

Lumo Energy 6,388 5,718 5,718 5,718

Momentum Energy 6,537 n/a n/a n/a

Next Business Energy 9,190 n/a n/a n/a

Origin Energy 6,543 6,025 5,766 6,543

Powerdirect 6,535 5,949 5,937 5,962

Powershop 6,961 6,266 6,265 6,266

QEnergy 7,091 7,091 7,091 7,091

Red Energy 6,388 5,749 5,749 5,749

Simply Energy 5,708 5,784 5,756 5,811

Simple average 6,779 6,094 6,039 6,165

Note: n/a—The retailer did not have a small business TOU market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 19 Annual bills for a typical small business customer, by retailer, 31 March 2017 (small business time-of-use offers)

Notes: The standing offers for ERM Power ($7,941) and Next Business Energy ($9,190) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business TOU market offer published on Energy Made Easy as at 31 March 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The March quarter table and graph show that, for a typical customer on a small business time- of-use tariff:  The difference between the average standing offer and average lowest market offer was $740, with the difference across retailers ranging from -$48 (Simply Energy) to $1,628 (ERM Power).110  The difference between the average standing offer and average market offer was $685, with the difference across retailers ranging from -$75 (Simply Energy) to $1,628 (ERM Power).  The difference between the average highest market offer and average lowest market offer was $126, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, QEnergy and Red Energy) to $777 (Origin Energy).111 Three retailers—Diamond Energy, Momentum Energy, Next Business Energy—published small business time-of-use standing offers on Energy Made Easy but did not publish a corresponding market offer.

110Simply Energy SME Standing Offer (TOU) standing offer and Business Save 10 Online market offer. ERM Power's Business Energy standing offer and Business Energy Adjustable—TOU market offer. 111 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. QEnergy's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Origin Energy's Supply (Tariff 22) (highest market offer) and Business eSaver Off Electricity Usage Discount (Tariff 22) and BusinessSaver Electricity Usage Discount (Tariff 22) (lowest market offers).

Queensland Competition Authority Prices and variations

June quarter For the June quarter, 15 retailers had small business time-of-use offers published on Energy Made Easy. Fourteen of these retailers had small business time-of-use standing offers, and 12 had at least one small business time-of-use market offer. Simply Energy did not have a small business time-of-use standing offer published on Energy Made Easy as at 30 June 2017. Table 22 Annual bills for a typical small business customer, by retailer, 30 June 2017 (small business time-of-use offers)

Retailer Standing offer ($) Average market Lowest market Highest market offer ($) offer ($) offer ($)

AGL 6,535 5,763 5,637 5,876

Click Energy 6,468 6,015 6,015 6,015

Diamond Energy 6,519 n/a n/a n/a

EnergyAustralia 6,062 5,605 5,302 5,819

Energy Locals 6,824 6,824 6,824 6,824

ERM Power 7,941 6,808 6,808 6,808

Lumo Energy 6,388 6,109 6,109 6,109

Momentum Energy 6,537 n/a n/a n/a

Next Business Energy 9,190 n/a n/a n/a

Origin Energy 6,543 6,025 5,766 6,543

Powerdirect 6,535 5,949 5,937 5,962

Powershop 6,961 6,266 6,265 6,266

QEnergy 7,091 7,669 7,669 7,669

Red Energy 6,388 6,095 6,095 6,095

Simply Energy n/a 5,784 5,756 5,811

Simple average 6,856 6,243 6,182 6,316

Notes: n/a—The retailer did not have a small business TOU standing or market offer published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis.

Queensland Competition Authority Prices and variations

Figure 20 Annual bills for a typical small business customer, by retailer, 30 June 2017 (small business time-of-use offers)

Notes: The standing offers for ERM Power ($7,941) and Next Business Energy ($9,190) are not included in this graph as they are above the range of other standing offers and their inclusion would make comparisons between other offers difficult. Diamond Energy, Momentum Energy and Next Business Energy did not have a small business TOU market offer, and Simply Energy did not have a small business TOU standing offer, published on Energy Made Easy as at 30 June 2017. Sources: Energy Made Easy; retailers' responses to part 3 of the QCA information notice; QCA analysis. The June quarter table and graph show that, for a typical customer on a small business time-of- use tariff:  The difference between the average standing offer and average lowest market offer was $674, with the difference across retailers ranging from -$578 (QEnergy) to $1,133 (ERM Power).112  The difference between the average standing offer and average market offer was $613, with the difference across retailers ranging from -$578 (QEnergy) to $1,133 (ERM Power).  The difference between the average highest market offer and average lowest market offer was $134, with the difference across retailers ranging from $0 (Click Energy, Energy Locals, ERM Power, Lumo Energy, QEnergy and Red Energy) to $777 (Origin Energy).113 Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business time of use standing offers on Energy Made Easy but did not publish a corresponding market offer.

112QEnergy Biz Your Way Time Of Use standing offer and Freedom Biz Time Of Use and Biz Saver TOU market offers. ERM Power's Business Energy standing offer and Business Energy Adjustable—TOU market offer. 113 Click Energy, Energy Locals, ERM Power, Lumo Energy and Red Energy each had one market offer; therefore, the difference between the highest and lowest market offer for each retailer is zero. QEnergy's two market offers yielded the same annual average bill; therefore, the difference between the highest and lowest market offer is zero. Origin Energy's Supply (Tariff 22) (highest market offer) and Business eSaver Off Electricity Usage Discount (Tariff 22) and BusinessSaver Electricity Usage Discount (Tariff 22) (lowest market offers).

Queensland Competition Authority Prices and variations

QCA assessment Increase in retailers publishing offers In the first quarter that electricity prices were deregulated, 13 retailers published small business time-of-use offers—either market or standing—on Energy Made Easy. This number increased to 16 retailers in the second quarter and remained steady at 15 retailers, after the exit of Urth Energy from the market, for the last two quarters. Three retailers—Diamond Energy, Momentum Energy and Next Business Energy—published small business time of use standing offers on Energy Made Easy but did not publish a corresponding market offer. Standing offer bills were higher than market offer bills Similar to small business flat rate offers, standing offer bills were generally higher than market offer bills for small business time-of-use customers. Standing offer customers would have saved on electricity bills at any point during the year by switching to the lowest market offer available in the market. Between the June and September 2016 quarters, the average standing offer increased by 20.9 per cent (from $5,703 to $6,895).114 Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to:  EnergyAustralia's lowest market offer ($5,402) in the September quarter115  EnergyAustralia's (new) lowest market offer ($5,352) in the December quarter116  EnergyAustralia's (new) lowest offer ($5,402) in the March quarter117  EnergyAustralia's (new) lowest offer ($5,302) in the June quarter.118 The reason for the $50 and $100 decreases in the December and June quarters respectively was the inclusion of sign-up incentives on EnergyAustralia's lowest offers. The difference between the average standing offer and the average lowest market offer ranged from $954 (September quarter) to $674 (June quarter). Customers on a standing offer could generally save on electricity bills by moving to their retailer's market offer, or by comparing market offers across retailers. This report does not characterise the difference between the two highest standing offers (Next Business Energy's $9,190 bill and ERM Power's $7,941 bill) and the lowest market offer as a potential saving for customers. We understand no customer had accepted the two highest

114 See Chapter 5, section 5.3.5. 115 Everyday Saver (Business – 5 Day Time Of Use). This offer was available from 29 September to 19 December 2016. 116 Everyday Saver (Business – 5 Day Time Of Use). This offer was available from 19 December 2016 to 2 January 2017. 117 Basic Saver (Business – 5 Day Time Of Use). This offer was available from 9 March to 18 May 2017. 118 Basic Saver (Business – 5 Day Time Of Use). This offer was available from 18 May to 3 July 2017, and included a $100 credit (GST incl.) off first electricity bill. The small business time-of-use market offers EnergyAustralia published in July and August 2017 (for the 2017–18 financial year) did not include sign-up incentives (source: Energy Made Easy).

Queensland Competition Authority Prices and variations

standing offers in 2016–17 and therefore such savings could not have been achieved by any customer.119 Market offer price variations Customers on market offers also had the opportunity to save on electricity bills at any point during the year by switching to the lowest market offer available. For example, the difference between the highest market offer and the lowest market offer in the June quarter was $2,366. The difference between the average highest market offer and average lowest market offer ranged from $206 (September quarter) to $126 (March quarter). By comparing retailers' market offers, small business customers had the opportunity to switch to a better market offer. Retailers applied a variety of discounts and incentives to market offers which could have lowered the overall electricity bill for customers.120 While the average market offer increased by over 3 per cent between the September and June quarters, two retailers chose to adjust (decrease) their lowest market offer at different points during the year:  EnergyAustralia decreased its lowest market offer by $50 from $5,402 (September quarter) to $5,352 (December quarter), and by $100 from $5,402 (March quarter) to $5,302 (June quarter);121  Simply Energy decreased its lowest market offer by $55 from $5,811 (September quarter) to $5,756 (December to June quarters).122

2.5 Distribution non-network charges 2.5.1 Residential flat rate offers The table below summarises the reconnection and disconnection fees identified on retailers' residential flat rate standing and market offers published on Energy Made Easy as at 30 June 2017. Table 23 Reconnection and disconnection fees included on residential flat rate offers, 30 June 2017

Retailer Reconnection fee ($) Disconnection fee ($)

AGL 10.75 when move into new address —

Dodo Power & Gas 101.90 after hours, fee may have — applied (market offer only)

Lumo Energy 10.75 generally applied for any move- — in request

Mojo Power Up to 108.87 Up to 108.87

Momentum Energy 10.75 10.75

119 ERM Power and Next Business Energy 2017, responses to part 2 of the QCA's information notice (unpublished). 120 See Chapter 3 for detail on discounts, savings and benefits attached to offers in 2016–17. 121 Everyday Saver (Business) 5 Day Time Of Use market offer (September quarter) and Basic Saver (Business) 5 Day Time Of Use market offer (June quarter). 122 Business Save 10 market offer (September quarter) and Business Save 10 Online market offer (December quarter).

Queensland Competition Authority Prices and variations

Retailer Reconnection fee ($) Disconnection fee ($)

Next Business Energy 10.75 may have applied 10.75 may have applied

Origin Energy 10.75 may have applied 10.75 may have applied

Red Energy 10.75 generally applied for any move- 10.75 generally applied for any move- in request out request

Simply Energy 8.58 additional after hours charges — may have applied

Notes: Click Energy, Diamond Energy, EnergyAustralia, Energy Locals, People Energy, Powerdirect, Powershop, QEnergy and Sanctuary Energy did not include any reconnection or disconnection fees on their residential flat rate standing or market offers published on Energy Made Easy as at 30 June 2017. A dash (–) means the retailer did not include the fee type in any of its residential flat rate standing or market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a reconnection or disconnection fee identified, it did not necessarily attach that fee to all of the residential flat rate standing or market offers it published on Energy Made Easy in 2016–17. All fees were reported as being GST inclusive. QCA assessment Seven of the nine retailers who included reconnection and/or disconnection fees on their offers identified fees in the range of $8.58 to $10.75 for these two fee types. Dodo Power & Gas and Mojo Power included much higher fees, being $101.90 to $108.87 respectively. The offers published by Dodo Power & Gas and Mojo Power did not describe the reason for these high charges.

2.5.2 Small business flat rate offers The table below summarises the reconnection and disconnection fees identified on retailers' residential flat rate standing and market offers published on Energy Made Easy as at 30 June 2017. Table 24 Reconnection and disconnection fees included on small business flat rate offers, 30 June 2017

Retailer Reconnection fee ($) Disconnection fee ($)

AGL 10.75 when moving into new address —

Lumo Energy 10.75 generally applied for any move- — in request

Momentum Energy 10.75 10.75

Next Business Energy 10.75 may have applied 10.75 may have applied

Origin Energy 10.75 may have applied 10.75 may have applied

Red Energy 10.75 generally applied for any move- 10.75 generally applied for any move- in request out request

Simply Energy 8.58 additional after hours charges — may have applied

Notes: Click Energy, Diamond Energy, EnergyAustralia, Energy Locals, ERM Power, Powerdirect, Powershop and QEnergy did not include any reconnection or disconnection fees on their small business flat rate standing or market offers published on Energy Made Easy as at 30 June 2017. A dash (–) means the retailer did not include the fee type in any of its small business flat rate standing or market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a reconnection or disconnection fee identified, it did not necessarily attach that fee to all of the small business flat rate standing or market offers it published on Energy Made Easy in 2016–17. All fees were reported as being GST inclusive.

Queensland Competition Authority Prices and variations

QCA assessment The seven retailers who included reconnection and/or disconnection fees on their offers identified fees in the range of $8.58 to $10.75 for these two fee types.

2.5.3 Additional fee information on Energy Made Easy Some retailers included information on their flat rate offers on Energy Made Easy referring to the potential for distribution non-network charges—other than those listed on Energy Made Easy—to be levied on customers. For example:  Click Energy's standing offers noted that customers should call Energex for a complete list of Energex's fees.  Diamond Energy's standing offers noted that other fees, such as meter special reads, meter installation, meter reconfiguration, energisation and de-energisation, may have applied. Diamond Energy suggested customers see its website or contact it for details.  Dodo Power & Gas's market offer stated that reconnection and disconnection fees did not apply during normal business hours.  EnergyAustralia's Basic Home and Basic Business offers referred to a page on its website (www.energyaustralia.com.au/other-charges) for other possible distributor fees.  Energy Locals' standing and market offers stated that all "normal fees" were listed on Energy Made Easy, but that, in some circumstances, the distributor may charge fees for certain additional services. Energy Locals referred to a page on its website (www.energylocals.com.au/fees) for more information.  ERM Power's small business offers stated that it may also pass on any charges from the customer's distributor or metering provider. ERM Power also referred customers to a page on its website (www.ermpower.com.au/electricity-sales-regulatory) for more details.  Lumo Energy's residential and small business offers also included a disconnection fee, noting that it generally applied for any move-out request, but the fee value was $0.  Next Business Energy's and Origin Energy's offers stated that the reconnection and disconnection fees were passed through from the distributor and may vary; the retailers advised customers to visit Energex's website to find out the current fee.  People Energy's and Sanctuary Energy's offers noted that services performed by the distributor would be passed on at cost. The retailers added that other fees and charges may have applied, and were outlined on their websites (www.peopleenergy.com.au and www.sanctuaryenergy.com respectively) or Energex's website (www.energex.com.au).  Simply Energy's market offers noted that the reconnection fee was passed through by the distributor and may vary. We consider all retailers should clearly identify on Energy Made Easy where customers can obtain information on distribution non-network charges that apply, or may apply, to their offers.

2.6 Conclusion The box below summarises the key points of our comparison and assessment of standing and market offer prices for 2016–17.

Queensland Competition Authority Prices and variations

Comparison and assessment Standing and generally available market offers (1) Standing offer bills were generally higher than market offer bills in each of the four quarters of 2016–17. (2) Standing offer customers could have saved on electricity bills by switching to one of their retailer's market offers, or by switching to a market offer from another retailer. (3) Some of the highest standing offers had no, or very few, customers contracted to them. (4) To get the lowest bill, customers need to regularly compare offers on Energy Made Easy, especially at the beginning of the financial year. Residential customers (5) Customers on standing offers, moving to a generally available market offer, would have saved the most by switching to the lowest market offer available. (6) Customers on market offers also had the opportunity to save on electricity bills by switching to the lowest market offer available. (7) Six retailers—Diamond Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy—published standing offers, but no market offers, on Energy Made Easy for 2016–17. Small business customers (8) Fewer retailers published offers—standing or market—on Energy Made Easy for small business customers than residential customers. Eighteen retailers had residential offers published, compared to 15 retailers having small business offers published, in the last two quarters of 2016–17. (9) Three retailers—Diamond Energy, Momentum Energy and Next Business Energy— published flat rate standing offers, but no market offers, on Energy Made Easy for 2016–17. Clarity on (non-retail) fees and charges (10) We consider that all retailers should clearly identify on Energy Made Easy their metering charges, or state that they do not levy metering charges if that is the case, in their offers. This would improve the clarity of information for customers, and assist comparability between offers. (11) We consider all retailers should clearly identify on Energy Made Easy where customers can obtain information on additional distribution non-network charges that apply, or may apply, to their offers. This would improve the clarity of information for customers, and assist comparability between offers.

Queensland Competition Authority Discounts, savings and benefits

3 DISCOUNTS, SAVINGS AND BENEFITS

This chapter compares and assesses the types of discounts, savings and benefits generally available to customers in 2016–17.

3.1 Background As mentioned in Chapter 2, retailers can vary their market offers in a number of ways, including via:  different types and levels of guaranteed and/or conditional discounts  setting different prices for different offers  other incentives and benefits (such as 'first month free' electricity offer, vouchers for use in retail stores, magazine subscriptions)  more innovative and tailored offers that match customers' needs and preferences (e.g. contribution to renewable energy generation (GreenPower options) or fixed priced plans). The types and levels of discounts or incentives attached to a market offer should be an important consideration for SEQ customers, as these elements can materially affect customers' bills. Where market contracts for SEQ customers include a fixed benefit period, retailers are required to notify residential and small business customers when the fixed benefit period is due to expire. The notice is to be given between 20 and 40 days before the fixed benefit period will expire. Further, the notice must state:  the date the fixed benefit period will expire  information about the contractual options available to the customer  information about the customer's ability to choose an alternative retailer after the fixed benefit period expires  the termination—and any other—fees that will apply if the customer ends the contract  details of the prices after the fixed benefit period expires.123

3.2 Minister's Direction Section 2(c) of the Direction requires the market monitoring report to include a comparison and assessment of the types of discounts, savings and benefits generally available to small customers in 2016–17.

3.3 QCA methodology As outlined in our scoping paper, we have compared and assessed the types of discounts and benefits generally available in retailers' market offers using information from Energy Made Easy

123 National Energy Retail Rules, rule 48A, as per section 9 of schedule 5 of the Queensland NERL Regulation. The AER regulates this section of the NERR. We note that the AEMC amended the NERR in November 2017 to require retailers to give customers on market contracts notice at the end of benefit periods. See AEMC 2017a–c for detail.

Queensland Competition Authority Discounts, savings and benefits

on the last day of each quarter in 2016–17.124 While we originally envisaged seeking supporting information from individual retailer websites, for consistency with our approach to monitoring prices, fees and charges, we have relied on Energy Made Easy data to monitor discounts, savings and benefits. We also supplement our report with a downloadable spreadsheet (on the QCA website) for stakeholders seeking more detail than we provide in this chapter. This chapter includes tables summarising the following:  the types of guaranteed and conditional discounts attached to retailers' generally available market offers.  the types of benefits and incentives attached to retailers' generally available market offers.  the GreenPower options attached to retailers' generally available market offers. GreenPower is a scheme that enables households and business to displace their electricity usage with certified renewable energy, which is added to the electricity grid on their behalf.125 These tables are presented by retailer, rather than by type of discount or benefit as envisaged in the scoping paper.126 Further, tables and graphs are included to show how much a customer could have saved, had the customer fulfilled the conditions to receive the price discounts attached to the retailer's lowest market offer.127 The savings are shown as at the end of the June quarter for each of the most common residential and small business tariffs and tariff combinations.

3.4 QCA monitoring The type and value (in dollar and percentage terms) of discounts, savings and benefits for each retailer did not vary significantly:  across the four quarters of 2016–17, or  between the three residential tariffs and combinations, or  between the two small business tariffs. Therefore, the tables in this chapter that summarise the types of discounts and benefits only report for the last day of the June quarter for residential flat rate, and small business flat rate, market offers.

3.4.1 Residential flat rate market offers Discounts Residential flat rate market offers published on Energy Made Easy as at 30 June 2017 included the following discounts and discount combinations:  guaranteed discounts  pay on time discounts  direct debit discounts

124 QCA 2016a, section 2.3.2. 125 GreenPower website, http://www.greenpower.gov.au/. 126 See QCA 2016a, section 2.3.2 (Tables 3–5). 127 See QCA 2016a, section 2.3.2 (Figure 2).

Queensland Competition Authority Discounts, savings and benefits

 direct debit and e-billing discounts combined  pay on time, direct debit and e-billing discounts combined  online saver discounts. The table below shows the discounts attached to residential flat rate market offers in the June quarter. Table 25 Discounts attached to residential flat rate market offers, 30 June 2017

Retailer Guaranteed Pay on time Direct debit Direct debit Pay on time, Online saver and e- direct debit billing and e-billing

AGL 8% off billa 8% and 11% 10% off — — — off usaged usagei

Click Energy — — — — 5%, 7%, 9% — and 15% off billk

Dodo Power & — 15% off — — — — Gas usagee

EnergyAustralia 8% off 16% off — — — — usageb usagef

Origin Energy 5% and 12% 8% off — 10% off — — off usagec usageg usagej

Powerdirect — 8% off — — — — usageh

Powershop — — — — — 8.16% and 10% off billl

Red Energy — 10% off bill — — — —

Simply Energy — 10% and — — — — 15% off usageh

a Applied to Everyday offer only. b Applied to Anytime Saver (Home) offer only. c 5% applied to Everyday and Solar Boost offers only, and 12% applied to Solar Boost Plus offer only. d 8% applied to Savers offer effective 4 May 2017 (offer ID AGL200230MR) only, and 11% applied to Savers offer effective 1 September 2016 (offer ID AGL337591MR) only. e Dodo's market offer was only available via automatic payment plan from credit card or direct debit. f Applied to Flexi Saver (Home) offer only. g Applied to Saver offer only. h 10% applied to Save 10 and Save 10 Online offers, and 15% applied to Plus 15 and Plus 15 Online offers. i Applied to Set and Forget offer only. j Applied to Maximiser offer only. k 5% applied to Shine Reward offer (net of solar export) only, 7% applied to Connect, Easy and Shine (net of solar export) offers only, 9% applied to Elite offer only, and 15% applied to People Power and Shine Budget (net of solar export) offers only. Discounts only available to customers receiving bills by email and paying by the due date by approved payment methods; Click Energy's Market Retail Contract Terms and Conditions (March 2016) list Bpay, over the phone, internet and direct debit as approved payment methods (Click Energy 2016). l 8.16% applied to Standard Saver offer, and 10% applied to Base Rates offer — paper bills not available on these offers.

Queensland Competition Authority Discounts, savings and benefits

Notes: Diamond Energy, ERM Power, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Energy Locals and Mojo Power had at least one residential flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any guaranteed or conditional discounts on their offer(s). A dash (—) means the retailer did not include the discount type in any of its residential flat rate market offers published on Energy Made Easy as at 30 June 2017. Diamond Energy's Energy Made Easy Price Fact Sheets for its residential standing offers stated that it offered pay on time discounts (7% off the bill) for customers who agreed to receive invoices by email and paid in full by an approved payment method by due date, and direct debit discounts (3% off the bill) for customers who agreed to receive invoices by email and paid in full by automated direct debit. In the Energy Made Easy data we downloaded from the database, the pay on time discount was 3%, not 7%. Where a retailer has a discount identified, it did not necessarily attach that discount to all of the residential flat rate market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis. QCA assessment Nine of the 11 retailers with residential market offers published on Energy Made Easy as at 30 June 2017 attached guaranteed and/or conditional discounts to at least one of their offers. Energy Locals and Mojo Power did not attach discounts to any of their residential market offers. Most retailers did not apply the same discount types and/or values to each of their respective residential market offers. The following subsections outline our assessment of each discount type for the nine retailers with discounts attached to at least one offer.

Guaranteed discounts EnergyAustralia and Origin Energy included guaranteed discounts, ranging from 5 to 12 per cent, off the usage charges of some of their offers. AGL was the only retailer to offer a guaranteed discount off the total bill, with its 8 per cent discount on its Everyday offer.

Pay on time discounts Six of the nine retailers included discounts on usage charges for paying on time on at least one of their offers. Discounts off usage charges ranged from 8 per cent for some of AGL's and Origin Energy's offers, and each of Powerdirect's offers, to 16 per cent for EnergyAustralia's Flexi Saver (Home) offer. Red Energy included a 10 per cent discount off the total bill on each of its offers.

Direct debit discounts Only AGL's Set and Forget offer included a direct debit (only) discount, being 10 per cent off usage charges.

Discount combinations Click Energy combined pay on time, direct debit and e-billing discounts off the total bill on its offers. The discounts ranged from 5 to 15 per cent and were only available to customers receiving bills by email and paying by the due date by approved payment methods. Click Energy's combined discounts were also notable for applying to fixed and variable charges that were higher than the retailer's standing offer, as summarised in table below. Click Energy's residential flat rate standing offer is added to the first row of the table for reference.

Queensland Competition Authority Discounts, savings and benefits

Table 26 Click Energy residential flat rate market offer discounts, 30 June 2017

Offer(s) Discount Fixed charge Fixed charge (% Usage charge Usage charge (% off bill (cents/day) above standing (cents/kWh) above standing (%) offer) offer)

Standing — 118.000 — 24.600 —

Shine Reward 5% 134.520 14.0 26.076 6.0%

Connect 7% 129.800 10.0 27.060 10.0%

Easy 7% 118.000 0.0 24.600 0.0%

Shine 7% 134.520 14.0 26.076 6.0%

Elite 9% 118.000 0.0 24.600 0.0%

People Power 15% 122.248 3.6 25.486 3.6%

Shine Budget 15% 134.520 14.0 26.076 6.0%

Notes: Discounts on Shine Reward, Shine and Shine Budget offers applied net of solar export. Source: Energy Made Easy. Online saver discounts Powershop included discounts of 8.16 and 10 per cent respectively on its Standard Saver and Base Rates offers where customers selected its Online Saver pack.128

Other incentives and benefits The table below shows the other incentives and benefits attached to residential flat rate market offers in the June quarter. Table 27 Other incentives and benefits attached to residential flat rate market offers, 30 June 2017

Retailer Other incentives and benefits

AGL Online sign-up: $25 (GST incl.) online sign-up credit (Fixed, Set and Forget, (one) Savers, and (one) Everyday offers only).a Fixed price: No details of terms and conditions, other than being reported as a fixed price offer on Energy Made Easy (Fixed offer only). One month free supply: Receive free electricity for the twelfth month of the benefit period.b

Dodo Power & Gas General incentive: Promotional offers; from time to time, Dodo Power & Gas may provide promotional offers (including one-off payments and/or products) though promotional codes, which may be redeemed when signing up. These codes do not change the rates, fees or charges of the offer.

EnergyAustralia Fixed price: No price rises for the next two years; including no government, network or CPI increases, and no premium added before the rate is fixed (Rate Fix (Home) offer only). GreenPower benefit: Supply the PureEnergy20 component of the plan at no extra cost for 12 months when customer selects the PureEnergy20 option (Flexi Saver (Home) offer only).

Simply Energy Online sign-up: $25 (GST excl.) first bill online sign-up credit (Simply Save 10 Online and Simply Plus 15 Online offers only).

128 See Chapter 8, section 8.4.3 for details of Powershop's 'Powerpacks' plans.

Queensland Competition Authority Discounts, savings and benefits

a In the AGL residential flat rate market offers published as at the last day of the September, December and March quarters—which included a $25 online sign-up credit—the $25 was listed as being GST exclusive. b The offers including this benefit were published by AGL in May 2017; therefore the benefits would not have been realised by customers in 2016–17. Notes: Diamond Energy, ERM Power, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Click Energy, Energy Locals, Mojo Power, Origin Energy, Powerdirect, Powershop and Red Energy had at least one residential flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any other incentives or benefits on their offer(s). Where a retailer has an incentive or benefit identified, it did not necessarily attach the incentive or benefit to all of its residential flat rate market offers in 2016–17. Source: Energy Made Easy. QCA assessment A small number of retailers offered other incentives and benefits in 2016–17. In terms of incentives that provided direct savings to customers, these related to signing up online.

GreenPower The table below shows the GreenPower options attached to residential flat rate market offers in the June quarter. Table 28 GreenPower options attached to residential flat rate market offers, 30 June 2017

Retailer GreenPower options

AGL AGL provided the following options: • Energy equal to 10% of usage fed into the grid from accredited GreenPower generators for $1.10 per week. • Energy equal to 20% of usage fed into the grid from accredited GreenPower generators for $1.80 per week. • Energy equal to 100% of usage fed into the grid from accredited GreenPower generators for $0.055 per kWh.

Click Energy Allowed customers to reduce their emissions by 25%, with GreenPower charges included in the rates (Natural offer only).

Dodo Power & Gas Dodo Power & Gas provided the following options: • Electricity equal to 10% of usage sourced from GreenPower for $0.099 per kWh. • Electricity equal to 100% of usage sourced from GreenPower for $0.099 per kWh.a Discounts did not apply to Dodo Power & Gas's GreenPower options.

EnergyAustralia PureEnergy options (Flexi Saver (Home) and Anytime Saver (Home) offers only): • PureEnergy 10%—$0.0847 x 10% of total usage. • PureEnergy 20%—$0.0847 x 20% of total usage. • PureEnergy 100%—$0.0847 per kWh.

Energy Locals GreenPower options: • 10% of total usage offset with accredited GreenPower renewable energy for $0.0101 per kWh. • 20% of total usage offset with accredited GreenPower renewable energy for $0.0202 per kWh. • 50% of total usage offset with accredited GreenPower renewable energy for $0.0506 per kWh. • 100% of total usage offset with accredited GreenPower renewable energy

Queensland Competition Authority Discounts, savings and benefits

Retailer GreenPower options for $0.1012 per kWh.

Origin Energy GreenPower options: • 25% of usage matched with electricity from accredited GreenPower sources for $2.00 per week. • 50% of usage matched with electricity from accredited GreenPower sources for $0.0281 per kWh. • 100% of usage matched with electricity from accredited wind GreenPower for $0.0561 per kWh.

Powershop 100% GreenPower for $0.10 per kWh (no discounts applied to GreenPower charges) (Standard Saver offer only).

Red Energy 100% GreenPower for extra $0.0583 per kWh.

a Dodo Power & Gas included GreenPower options for 10% and 100% of a customer's usage for $0.099 per kWh (GST incl.) on both of its residential market offers. Notes: Diamond Energy, ERM Power, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Diamond Energy and QEnergy did, however, attach GreenPower options to their standing offers. Mojo Power, Powerdirect and Simply Energy had at least one residential flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any GreenPower options on their offer(s). Where a retailer has a GreenPower option identified, it did not necessarily attach the option to all of its residential flat rate market offers in 2016–17. GreenPower charges on Energy Made Easy are GST inclusive. Source: Energy Made Easy. QCA assessment Most of the retailers with market offers attached GreenPower options to their offers in 2016– 17. The offers generally allowed customers to select a proportion of their electricity to be supplied from GreenPower accredited sources for a price in terms of dollars per week or dollars per kilowatt hour of usage.

3.4.2 Small business flat rate market offers Discounts Small business flat rate market offers published on Energy Made Easy as at 30 June 2017 included the following discounts and discount combinations:  guaranteed discounts  pay on time discounts  e-billing discounts  pay on time, direct debit and e-billing discounts combined  online saver discounts. The table below shows the guaranteed and conditional discounts attached to small business flat rate market offers in the June quarter.

Queensland Competition Authority Discounts, savings and benefits

Table 29 Discounts attached to small business flat rate market offers, 30 June 2017

Retailer Guaranteed Pay on time e-billing Pay on time & Online saver direct debit & e-billing

AGL 7% and 13% off 8% off usaged — — — usagea

Click Energy — — — 7% off bill —

EnergyAustralia 7% and 10% off 5% off usagee — — — usageb

Origin Energy 13% off usagec — 13% off usagef — —

Powershop — — — — 8.16% and 10% off billg

Red Energy — 10% off bill — — —

Simply Energy 10% off usage — — — —

a 7% applied to Business Maximiser offer only and 13% applied to Business Savers offer only. b 7% applied to Basic Saver (Business) offer only and 10% applied to Everyday Saver (Business) offer only. c Applied to BusinessSaver offer only. d Applied to Business Maximiser offer only. e Applied to Basic Saver (Business) and Flexi Saver (Business) offers only. f Applied to Business eSaver off Electricity Usage Discount offer only. g 8.16% applied to Standard Saver offer, and 10% applied to Base Rates offer—paper bills not available on these offers. Notes: Diamond Energy, Dodo Power & Gas, Mojo Power, Momentum Energy, Next Business Energy, People Energy and Sanctuary Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 June 2017. Energy Locals, ERM Power, Lumo Energy, Powerdirect and QEnergy had at least one small business flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any guaranteed or conditional discounts on their offer(s). A dash (—) means the retailer did not include the discount type in any of its small business flat rate market offers published on Energy Made Easy as at 30 June 2017. Diamond Energy's Energy Made Easy Price Fact Sheets for its small business standing offers stated that it offered pay on time discounts (7% off the bill) for customers who agreed to receive invoices by email and paid in full by an approved payment method by due date, and direct debit discounts (3% off the bill) for customers who agreed to receive invoices by email and paid in full by automated direct debit. In the Energy Made Easy data we downloaded from the database, the pay on time discount was 3%, not 7%. Where a retailer has a discount identified, it did not necessarily attach that discount to all of the small business market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis. QCA assessment Seven of the 12 retailers with small business market offers published on Energy Made Easy as at 30 June 2017 attached guaranteed and/or conditional discounts to at least one of their offers. Energy Locals, ERM Power, Lumo Energy, Powerdirect and QEnergy did not attach discounts to any of their small business market offers. Most retailers did not apply the same discount types and/or values to each of their respective small business market offers. The following subsections outline our assessment of each discount type for the seven retailers with discounts attached to at least one offer.

Guaranteed discounts AGL, EnergyAustralia and Origin Energy offered guaranteed discounts, ranging from 7 to 13 per cent, off the usage charges of some of their offers. Simply Energy offered a 10 per cent discount off usage charges for all of its offers.

Pay on time discounts AGL and EnergyAustralia included discounts on usage charges for paying on time on at least one of their offers. The discounts were 8 per cent for AGL's Business Maximiser offer, and 5 per cent

Queensland Competition Authority Discounts, savings and benefits

for EnergyAustralia's Basic Saver (Business) and Flexi Saver (Business) offers. Red Energy included a 10 per cent discount off the total bill on each of its offers.

e-billing discounts Only Origin Energy's Business eSaver off Electricity Usage Discount offer included an e-billing (only) discount, being 13 per cent off usage charges.

Discount combinations Click Energy included a 7 per cent off the total bill combined pay on time, direct debit and e- billing discount on its offer. The offer was only available to customers receiving bills by email and paying by the due date by approved payment methods. In contrast to its residential flat rate market offers, the fixed and variable charges for Click Energy's small business flat rate market and standing offers were the same.

Online saver discounts Powershop included discounts of 8.16 and 10 per cent respectively on its Standard Saver and Base Rates offers where customers selected its Online Saver pack.129

Other incentives and benefits The table below shows the other incentives and benefits attached to small business flat rate market offers in the June quarter. Table 30 Other incentives and benefits attached to small business flat rate market offers, 30 June 2017

Retailer Other incentives and benefits

AGL Fixed price: No details of terms and conditions, other than being reported as a fixed price offer on Energy Made Easy (Business Fixed offer only).

EnergyAustralia General incentive: $100 credit (GST incl.) off first electricity bill (Basic Saver (Business) offer only).a Fixed price: No price rises for the next two years; including no government, network or CPI increases, and no premium added before the rate is fixed (Rate Fix (Business) offer only).

ERM Power General incentive: simple pricing; no confusing conditional discounts; price reviewed only once each 12 month period.

Lumo Energy General incentive: dedicated account management team during business hours.

Simply Energy Online sign-up: $50 (GST excl.) first bill online sign-up credit (Business Save 10 Online offer only).

a This incentive was listed as a guaranteed discount on Energy Made Easy. Notes: Diamond Energy, Dodo Power & Gas, Mojo Power, Momentum Energy, Next Business Energy, People Energy and Sanctuary Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 June 2017. AGL, Click Energy, Energy Locals, Origin Energy, Powerdirect, Powershop, QEnergy and Red Energy had at least one small business flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any other incentives or benefits on their offer(s). Where a retailer has an incentive or benefit identified, it did not necessarily attach the incentive or benefit to all of its small business flat rate market offers in 2016–17. Source: Energy Made Easy.

129 See Chapter 8, section 8.4.3 for details of Powershop's 'Powerpacks' plans.

Queensland Competition Authority Discounts, savings and benefits

QCA assessment A small number of retailers offered other incentives and benefits in 2016–17. In terms of incentives that provided direct savings to customers, these related to signing up to the offer.

GreenPower The table below shows the GreenPower options attached to small business flat rate market offers in the June quarter. Table 31 GreenPower options attached to small business flat rate market offers, 30 June 2017

Retailer Other benefits

AGL 100% of usage fed into the grid from accredited GreenPower generators for $0.0550 per kWh.

EnergyAustralia PureEnergy options (Flexi Saver, Everyday Saver and Basic Saver offers only): • PureEnergy 10%—$0.0847 x 10% of total usage. • PureEnergy 20%—$0.0847 x 20% of total usage. • PureEnergy 100%—$0.0847 per kWh.

Energy Locals GreenPower options: • 10% of total usage offset with certified renewable energy for $0.0101 per kWh. • 20% of total usage offset with certified renewable energy for $0.0202 per kWh. • 50% of total usage offset with certified renewable energy for $0.0506 per kWh. • 100% of total usage offset with certified renewable energy for $0.1012 per kWh.

Origin Energy GreenPower options: • 25% of usage matched with electricity from accredited GreenPower sources for $0.0204 (GST incl.) per kWh • 50% of usage matched with electricity from accredited GreenPower sources for $0.0281 (GST incl.) per kWh • 100% of usage matched with electricity from accredited wind GreenPower for $0.0561 (GST incl.) per kWh.

Powershop 100% GreenPower for $0.10 per kWh (no discounts applied to GreenPower charges) (Standard Saver offer only).

QEnergy QGreen could be added to electricity plan as an additional charge: • 10% for $0.0066 per kWh. • 50% for $0.0330 per kWh. • 100% for $0.0660 per kWh.

Red Energy 100% GreenPower for extra $0.0583 per kWh.

Notes: Diamond Energy, Dodo Power & Gas, Mojo Power, Momentum Energy, Next Business Energy, People Energy and Sanctuary Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 June 2017. Diamond Energy did, however, attach GreenPower options to its standing offers. Click Energy, ERM Power, Lumo Energy, Powerdirect and Simply Energy had at least one small business flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any GreenPower options on their offer(s). Where a retailer has a GreenPower option identified, it did not necessarily attach the option to all of its small business flat rate market offers in 2016–17. GreenPower charges on Energy Made Easy are GST inclusive. Source: Energy Made Easy.

Queensland Competition Authority Discounts, savings and benefits

QCA assessment GreenPower options attached to offers in 2016–17 generally allowed customers to select a proportion of their electricity to be supplied from GreenPower accredited sources, for a price in terms of dollars per week or dollars per kilowatt hour of usage.

3.4.3 Complexity of discounting We note that three recent reports—the ACCC's retail electricity pricing inquiry preliminary report, Dr Alan Finkel's report of the review into the future security of the NEM, and the report of the independent review into Victoria's electricity and gas retail markets—have commented on the complexity of discounting in retail electricity markets.130 Based on our analysis of generally available market offers for this review, we consider that:  Discounts were clearly stated in terms of what they were based on—usually the variable usage charge.  The different fixed and usage charges of retailers could make it difficult, and/or time- consuming, for customers to determine the value to them of various discount options.  Customers would also need to consider their current and future consumption levels, discount benefit periods, their willingness and ability to meet conditions attached to discounts, any incentives, the fees attached to offers, and whether discounts apply to charges before or after solar feed-in tariffs are applied, to decide which discount would offer them the best value in terms of bills.

3.4.4 Annual bill impacts—before and after conditional price discounts and incentives The tables and figures below show how much a customer could have saved had the customer received all conditional discounts and benefits attached to the retailer's lowest/best market offer, compared to not receiving the conditional discounts and incentives on the same offer. The tables and figures are for the most common tariffs and tariff combinations, for offers published on Energy Made Easy as at 30 June 2017.

Residential flat rate market offers In the June quarter, 11 retailers had residential flat rate market offers published on Energy Made Easy. The table and figure below show the differences between annual bills for a typical customer on each retailer's lowest offer, before and after conditional discounts and incentives.

130 ACCC 2017, section 4.3.2; Finkel 2017, section 6.2; Thwaites, Faulkner and Mulder 2017, industry practices and regulation chapter. See also Appendix D (responses to additional issues raised in submissions) of this report (discounts, savings and benefits subsection).

Queensland Competition Authority Discounts, savings and benefits

Table 32 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (residential flat rate offers)

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

AGL Fixed (AGL336130MR) 1,351 1,326 25

Click Energy People Power—Tariff 11 Only 1,613 1,371 242 (CLI363025MR)

Dodo Power & Gas Energex Res No Term Market Offer – 1,505 1,349 156 (DOD194446MR)

EnergyAustralia Flexi Saver (Home) (ENE275471MR) 1,509 1,343 166

Energy Locals Lock Down (Residential – Anytime) 1,538 1,538 0 (LCL333795MR)

Mojo Power Energy with Benefits (Annual 1,502 1,502 0 EnergyPass (MOJ332608MR)

Origin Energy Solar Boost Plus (ORI277911MR)a 1,369 1,369 0

Powerdirect Powerdirect Residential Electricity 1,479 1,392 87 Market Offer (POW330756MR)

Powershop Base Rates (PSH374765MR) 1,519 1,367 152

Red Energy Easy Saver 10% (Residential) 1,494 1,344 149 (RED335783MR)

Simply Energy Simply Save 10 (SIM348646MR) 1,489 1,290 199

a A condition of this offer is that the customer was required to purchase an eligible solar PV system from Origin Energy. Notes: More information on the terms and conditions for the lowest market offers can be found in the published dataset on the QCA website. Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this table. The cheapest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis.

Queensland Competition Authority Discounts, savings and benefits

Figure 21 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (residential flat rate offers)

$1,700

$1,600

$1,500

$1,400

$1,300

$1,200

$1,100

Before conditional discounts & incentives After conditional discounts & incentives

Note: Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this figure. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis. Residential flat rate with controlled load super economy offers In the June quarter, 11 retailers had residential flat rate with controlled load super economy market offers published on Energy Made Easy. The table and figure below show the differences between annual bills for a typical customer on each retailer's lowest offer, before and after conditional discounts. Table 33 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (residential flat rate with controlled load super economy offers)

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

AGL Fixed (AGL336129MR) 1,660 1,635 25

Click Energy People Power—Tariff 11 and Tariff 31 2,058 1,749 309 (Night Rate) and Tariff 33 (Controlled Supply) (CLI363022MR)

Dodo Power & Gas Energex Res & Controlled Load No Term 1,825 1,623 202 Market Offer (DOD194448MR)

EnergyAustralia Flexi Saver (Home – Peak with 1,840 1,623 217 Controlled Load 1 – No Exit Fees) (ENE275470MR)

Energy Locals Lock Down (Residential – Anytime with 1,987 1,987 0

Queensland Competition Authority Discounts, savings and benefits

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($) controlled Load 1) (LCL333877MR)

Mojo Power Energy with Benefits (Annual 1,823 1,823 0 EnergyPass) (MOJ332584MR)

Origin Energy Solar Boost Plus (ORI277914MR)a 1,667 1,667 0

Powerdirect Powerdirect Residential Electricity 1,818 1,705 113 Market Offer (POW330755MR)

Powershop Base Rates (PSH374764MR) 1,964 1,767 196

Red Energy Easy Saver 10% (Residential) 1,868 1,682 187 (RED335780MR)

Simply Energy Simply Plus 15 Online (SIM348640MR) 1,903 1,644 259

a A condition of this offer is that the customer was required to purchase an eligible solar PV system from Origin Energy. Notes: More information on the terms and conditions for the lowest market offers can be found in the published dataset on the QCA website. Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this table. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis. Figure 22 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives (residential flat rate with controlled load super economy offers)

$2,100

$2,000

$1,900

$1,800

$1,700

$1,600

$1,500

$1,400

Before conditional discounts & incentives After conditional discounts & incentives

Queensland Competition Authority Discounts, savings and benefits

Residential flat rate with controlled load economy offers In the June quarter, 11 retailers had residential flat rate with controlled load economy market offers published on Energy Made Easy. The table and figure below show the differences between annual bills for a typical customer on each retailer's lowest offer, before and after conditional discounts. Table 34 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (residential flat rate with controlled load economy offers)

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

AGL Fixed (AGL336129MR) 1,622 1,597 25

Click Energy Click People Power—Tariff 11 and Tariff 1,977 1,680 296 31 (Night Rate) and Tariff 33 (Controlled Supply) (CLI363022MR)

Dodo Power & Gas Energex Res & Controlled Load No Term 1,811 1,611 200 Market Offer (DOD194448MR)

EnergyAustralia Flexi Saver (Home – Peak with 1,791 1,582 209 Controlled Load 2 – No Exit Fees) (ENE275469MR)

Energy Locals Lock Down – Residential – Anytime with 1,895 1,895 0 controlled Load 2 offer (LCL333889MR)

Mojo Power Energy with Benefits – Annual 1,750 1,750 0 EnergyPass (MOJ332596MR)

Origin Energy Solar Boost Plus (ORI277908MR)a 1,637 1,637 0

Powerdirect Powerdirect Residential Electricity 1,776 1,667 110 Market Offer (POW330755MR)

Powershop Base Rates (PSH374763MR) 1,873 1,686 187

Red Energy Easy Saver 10% – Residential 1,806 1,626 181 (RED335777MR)

Simply Energy Simply Plus 15 Online (SIM348649MR) 1,844 1,594 251

a A condition of this offer is that the customer was required to purchase an eligible solar PV system from Origin Energy. Notes: More information on the terms and conditions for the lowest market offers can be found in the published dataset on the QCA website. Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this table. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis.

Queensland Competition Authority Discounts, savings and benefits

Figure 23 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (residential flat rate with controlled load economy offers)

$2,000

$1,900

$1,800

$1,700

$1,600

$1,500

$1,400

Before conditional discounts & incentives After conditional discounts & incentives

Note: Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this figure. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis. Small business flat rate market offers In the June quarter, 12 retailers had small business flat rate market offers published on Energy Made Easy. The table and figure below show the differences between annual bills for a typical customer on each retailer's lowest offer, before and after conditional discounts. Table 35 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (small business flat rate offers)

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

AGL Business Maximiser (AGL198338MS) 2,249 2,103 146

Click Energy Business—Tariff 20 Only (CLI362939MS) 2,384 2,217 167

EnergyAustralia Basic Saver (Business) (ENE336681MS) 2,057 1,972 86

Energy Locals Lock Down (Small Business – Anytime 2,479 2,479 0 Offer) (LCL333807MS)

ERM Power Business Energy Adjustable – Single 2,335 2,335 0 Rate (ERM356213MS)

Lumo Energy Business Premium – No Exit Fee 2,174 2,174 0 (LUM338932MS)

Queensland Competition Authority Discounts, savings and benefits

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

Origin Energy Business eSaver Off Electricity Usage 2,387 2,150 237 Discount – Tariff 20 (ORI222194MS)a

Powerdirect Powerdirect Small Business Electricity 2,194 2,194 0 Market Offer (POW330722MS)

Powershop Base Rates (PSH374762MS) 2,509 2,258 251

QEnergy Biz Saver Single Rate (QEN337967MS) 2,805 2,805 0

Red Energy Easy Saver 10% (Business) 2,413 2,172 241 (RED335795MS)

Simply Energy Business Save 10 Online 2,165 2,110 55 (SIM348598MS)

a There are two Origin Energy market offers that yield the lowest bill after the application of all discounts and incentives. For the purposes of showing how much of the savings may be conditional, we use the offer that actually offers the discount as conditional (ORI222194MS) rather than the offer that did not offer the discount as conditional (ORI222201MS). Notes: More information on the terms and conditions for the lowest market offers can be found in the published dataset on the QCA website. Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this table. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis. Figure 24 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (small business flat rate offers)

$2,800

$2,600

$2,400

$2,200

$2,000

$1,800

Before conditional discounts & incentives After conditional discounts & incentives

Queensland Competition Authority Discounts, savings and benefits

Sources: Energy Made Easy; QCA analysis. Small business time-of-use offers In the June quarter, 12 retailers had small business time-of-use market offers published on Energy Made Easy. The table and figure below show the differences between annual bills for a typical customer on each retailer's lowest offer, before and after conditional discounts. Table 36 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (small business time-of-use offers)

Retailer Offer name (ID) Before After Saving conditional conditional ($) discounts and discounts and incentives ($) incentives ($)

AGL Business Maximiser – Queensland Small 6,116 5,637 479 Business Electricity Market Offer (AGL198340MS)

Click Energy Business – Tariff 22 Only 6,468 6,015 453 (CLI362938MS)

EnergyAustralia Basic Saver (Business – 5 Day Time of 5,577 5,302 275 Use) (ENE336697MS)

Energy Locals Lock Down (Small Business – Time of 6,824 6,824 0 Use Offer) (LCL333850MS)

ERM Power Business Energy Adjustable – TOU 6,808 6,808 0 (ERM356202MS)

Lumo Energy Business Premium – No Exit Fee 6,109 6,109 0 (LUM338936MS)

Origin Energy Business eSaver Off Electricity Usage 6,543 5,766 777 Discount – Tariff 22 (ORI222203MS)a

Powerdirect Powerdirect Small Business Electricity 5,937 5,937 0 Market Offer (POW330717MS)

Powershop Base Rates (PSH374843MS) 6,961 6,265 696

QEnergy Freedom Biz Time of Use 7,669 7,669 0 (QEN337979MS)

Red Energy Easy Saver 10% (Business) 6,773 6,095 677 (RED335830MS)

Simply Energy Business Save 10 Online 5,811 5,756 55 (SIM352146MS)

a There are two Origin Energy market offers that yielded the same annual bills after conditional discounts and incentives. For the purposes of showing how much of the savings may be conditional, we use the offer that actually offers the discount as conditional (ORI222203MS) rather than the offer that did not offer the discount as conditional (ORI222205MS). Notes: More information on the terms and conditions for the lowest market offers can be found in the published dataset on the QCA website. Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this table. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis.

Queensland Competition Authority Discounts, savings and benefits

Figure 25 Annual bills for a typical customer on a retailer's lowest market offer, before and after conditional discounts and incentives, 30 June 2017 (small business time-of-use offers)

$7,800

$7,400

$7,000

$6,600

$6,200

$5,800

$5,400

$5,000

Before conditional discounts & incentives After conditional discounts & incentives

Note: Guaranteed discounts and incentives (where applicable) have been applied to all bill calculations in this figure. The lowest market offer for each retailer has been determined after accounting for all (guaranteed and conditional) discounts and incentives. Sources: Energy Made Easy; QCA analysis. QCA assessment The analysis shows that most retailers offered conditional discounts that yielded savings for customers when the discounts were realised by the customer. These savings could be moderate in comparison to the bill without the conditional discounts being taken advantage of, or they may have been significant relative to the bill without conditional discounts. The analysis also shows that even though some retailers had different prices across their different market offers, the retailer's lowest price market offer generally incorporated the highest conditional discount or incentive. While some retailers did not offer conditional discounts at all, these retailers' annual bills for typical customers were often significantly higher than the after-discount bills for other retailers.

3.5 Conclusion The box below summarises the key points of our comparison and assessment of discounts, savings and benefits for 2016–17.

Queensland Competition Authority Discounts, savings and benefits

Comparison and assessment (1) The most common form of discounts available in 2016–17 were related to customers' payment arrangements, and usually were applied only to the variable usage charge rather than to both variable usage and fixed supply charges. (2) A small number of retailers offered other incentives and benefits in 2016–17. Incentives that provided direct savings to customers related to signing up to the offer. (3) Most of the retailers with market offers attached GreenPower options to their offers in 2016–17. The offers generally allowed customers to select a proportion of their electricity to be supplied from GreenPower accredited sources for a price in terms of dollars per week or dollars per kilowatt hour of usage. (4) Most retailers offered conditional discounts that yielded savings for customers when the discounts were realised by the customer. These savings could be moderate in comparison to the bill without the conditional discounts being taken advantage of, or they may have been significant relative to the bill without conditional discounts. (5) Even though some retailers had different prices across their different market offers, the retailer's lowest price market offer generally incorporated the highest conditional discount or incentive. (6) While some retailers did not offer conditional discounts at all, these retailers' annual bills for typical customers were often significantly higher than the after-discount bills for other retailers.

Queensland Competition Authority Fees and charges

4 FEES AND CHARGES

This chapter compares and assesses retailers' fees and charges regarding the sale of electricity to customers in 2016–17.

4.1 Background Electricity offers can include a number of additional fees levied by retailers for customer retail services. Examples of retail fees and charges include account establishment fees, payment processing fees, early termination fees and late payment fees. Retailers also pass through to customers certain fees/charges levied by distributors (distribution non-network charges). These include metering charges, connection, disconnection and reconnection fees, special meter reading fees and meter inspection fees.131

4.2 Minister's Direction Section 2(d) of the Direction requires the market monitoring report to include a comparison and assessment of retailers' fees and charges relating to the sale of electricity to customers in 2016– 17.

4.3 QCA methodology As outlined in the scoping paper, we have compared and assessed retailers' fees and charges relating to the sale of electricity to customers using information obtained from Energy Made Easy on the last day of the final quarter of 2016–17 (i.e. 30 June 2017).132 Section 2(d) of the Direction only applies to retailers' fees and charges relating to the sale of electricity to customers. Therefore, we do not include any assessment of distribution non- network charges (levied by Energex and passed on by retailers) in this chapter of the report.

4.4 QCA monitoring The type and value of retail fees and charges for each retailer did not vary significantly:  across the four quarters of 2016–17, or  between the three residential tariffs and combinations, or  between the two small business tariffs. Therefore, the tables in this chapter that summarise the types of retail fees and charges only report for the last day of the June quarter for residential flat rate, and small business flat rate, market and standing offers. The scoping paper mentioned the possibility of supplementing the reporting on retail fees and charges with a more detailed downloadable spreadsheet (on the QCA website) for stakeholders seeking more detail. However, we have not included retail fees and charges in the dataset on our website for mainly two reasons:

131 For more information, see Chapter 2, sections 2.3.4 and 2.5 of this report, Energex 2016a, and the Electricity Regulation, section 226 and schedule 8. 132 QCA 2016a, section 2.3.3.

Queensland Competition Authority Fees and charges

 The retail fees and charges do not affect the annual bills for typical customers on each of the tariffs and tariff combinations reported in Chapters 2 and 5.  The summary tables and analysis in this chapter give sufficient comparison and assessment of the fees and charges included on market offers for 2016–17. Finally, we also found no retailers included account establishment fees in published offers; hence, the tables below have no column for these fee types.

4.4.1 Residential flat rate offers Market offers Residential flat rate market offers published on Energy Made Easy as at 30 June 2017 included the following retail fees and charges:  credit and debit card payment fees  payment processing fees—in dollar and percentage amounts—on payments made by cheque, direct debit, or over the counter (at Australia Post)  dishonoured cheque and direct debit payment fees (a 'dishonour payment fee')  late payment fees  early termination fees. The tables below show the retail fees and charges attached to residential flat rate market offers as at 30 June 2017. Table 37 Retail payment processing fees and charges attached to residential market offers, 30 June 2017

Retailer Credit / Visa / Amex / Direct debit Paper bill Over the debit card MasterCard Diners Club fees ($) fees ($) counter (at fees — fees (%) fees (%) Australia general Post) fees application ($) (%)

AGL 0.55 — — — 1.75g 2.00h

Click Energy 0.60 — — — — —

Dodo Power & — — 2.89 1.90f 2.20 — Gas

EnergyAustralia — 0.36 1.50d — 1.69 1.91

Energy Locals 1.00 — — — 2.00 —

Mojo Power — — 2.35e — — —

Origin Energy — 0.37c — — 1.75 2.00i

Powerdirect 0.55 and — — — — — 0.60a

Simply Energy 0.60b — — — — —

Queensland Competition Authority Fees and charges

a 0.55% and 0.60% applied (on different offers) to payments made by debit and credit cards. b Applied to credit card payments only. c The fee may have applied to the Saver, Supply, Maximiser, Solar Boost and Solar Boost Plus offers. The fee did not apply to the Everyday or Connect offers. d Amex only. e Amex only. Mojo Power's offers on Energy Made Easy also included a $2.35 Amex credit card fee; this appears to be a reporting error by the retailer. f Dodo's offer on Energy Made Easy also stated that payments made by Bpay or other methods may also have incurred a processing fee. g The fee may have applied. h The fee may have applied, and was listed as an early termination fee on the Set and Forget offer. i The fee applied to the Maximiser, Supply, Saver, Solar Boost and Solar Boost Plus offers only. Notes: We identify where retailers' noted on Energy Made Easy that certain fees 'may' have applied. Diamond Energy, ERM Power, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Powershop and Red Energy had at least one residential flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any payment processing fees on their offer(s). A dash (—) means the retailer did not include the fee or charge type in any of its residential flat rate market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a retail fee or charge identified, it did not necessarily attach that fee or charge to all of the residential flat rate market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis. Table 38 Retail dishonour payment, late payment and early termination fees and charges attached to residential market offers, 30 June 2017

Retailer Dishonour Dishonour Late payment fees Early termination payment fee - payment fee - ($) fees ($) cheque ($) direct debit ($)

AGL 10.00 3.50 12.73c —

Click Energy — — 12.00 —

Dodo Power & Gas — 9.50a — —

EnergyAustralia — — 12.00 22.00f

Energy Locals — 11.00b 13.00 —

Mojo Power — 2.50 — —

Origin Energy — — 12.00d —

Powerdirect 12.00 5.00 12.73e —

a The fee may have applied to payments that were declined. Dodo's market offer was only available via automatic payment plan from credit card or direct debit. b The fee was listed as an 'other fee' on Energy Made Easy. We have assigned it to the dishonour payment fee – direct debit category on the basis that Energy Locals' website lists direct debit, credit card and Bpay as its payment methods, and the retailer does not accept payment by cheque.133 c The fee may have applied. d The fee may have applied to Maximiser, Supply, Solar Boost and Solar Boost Plus offers only. The fee did not apply to the Saver, Everyday and Connect offers. e The fee may have applied. f Applied to Rate Fix (Home) offer only. The fee did not apply to the Anytime Saver (Home) or Flexi Saver (Home) offers. Notes: We identify where retailers' noted on Energy Made Easy that certain fees 'may' have applied. Diamond Energy, ERM Power, Lumo Energy, Momentum Energy, Next Business Energy, People Energy, QEnergy and Sanctuary Energy did not have a residential flat rate market offer published on Energy Made Easy as at 30 June 2017. Powershop, Red Energy and Simply Energy had at least one residential flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any dishonour payment, late payment or early termination fees on their offer(s). A dash (—) means the retailer did not include the fee type in any of its residential flat rate market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a retail fee or charge identified, it did not necessarily attach that fee or charge to all of the residential flat rate market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis.

133 Energy Locals, 'How can I pay my bill?', https://help.energylocals.com.au/prices-and-billing/how-can-i-pay- my-bill; Energy Locals 2017, response to part 3 of the QCA's information notice (unpublished).

Queensland Competition Authority Fees and charges

QCA assessment Nine of the 11 retailers with residential market offers published on Energy Made Easy as at 30 June 2017 attached retail fees and charges to at least one of their offers. Powershop and Red Energy did not attach retail fees and charges to any of their residential market offers. Origin Energy did not apply the same fee and charge types to each of its residential market offers. The following subsections outline our assessment of each fee type for the nine retailers with retail fees and charges attached to at least one offer.

Payment processing fees As noted in Chapter 2, the Competition and Consumer Act, part IVC may prevent retailers from levying excessive payment processing fees on customers.134 All nine retailers included processing fees on credit card payments on at least one of their offers. The fees ranged from 0.36 per cent on payments made to EnergyAustralia by Visa and MasterCard, to 2.89 per cent on payments made to Dodo Power & Gas by Amex and Diners Card. Four retailers included processing fees on debit card payments on at least one of their offers. The fees ranged from 0.55 per cent by AGL and Powerdirect to 1.00 per cent charged by Energy Locals. Five retailers charged paper bill processing fees, ranging from EnergyAustralia's $1.69 fee to Dodo Power & Gas's $2.20 fee. Three retailers charged over the counter payment fees for payments made at Australia Post, ranging from $1.91 charged by EnergyAustralia, to $2.00 charged by AGL and Origin Energy (on five of its seven offers). However, retailers did not consistently identify the payment methods available, or not available, on their residential flat rate market offers. This made it difficult to compare payment processing fees across offers and retailers.

Dishonour payment fees Fees for dishonouring direct debit payments ranged from $2.50 on Mojo Power's offers, to $11.00 on Energy Locals' offer. AGL and Powerdirect charged $10.00 and $12.00 respectively for dishonour fees on cheque payments.

Late payment fees Six retailers included late payment fees on at least one offer, ranging from $12.00 levied by Click Energy, EnergyAustralia and Origin Energy (in respect of the Maximiser offer), to $13.00 levied by Energy Locals. Of the retailers without a late payment fee, Dodo Power & Gas, Origin Energy (Saver offer only), Red Energy and Simply Energy had pay on time discounts on their offers, thereby providing a separate incentive to customers to pay on time.135 We also found that Click Energy (except its Natural offer) and EnergyAustralia (Flexi Saver – Home offer only) included late payment fees and pay on time discounts on their offers, making the (percentage) difference between bills paid on time and late even wider than would be the case on offers without late payment fees and/or pay on time discounts. AGL (Savers offer only)

134 For more information, see ACCC 2016. 135 The retailers' pay on time discounts are outlined in Chapter 3, section 3.4.1 (discounts subsection).

Queensland Competition Authority Fees and charges

and Powerdirect also included pay on time discounts on offers with late payment fees attached, but the offer information on Energy Made Easy stated that the late payment fee may have applied, making it less clear whether their offers would feature the larger gap between bills paid on time and paid late.

Early termination fees As noted in Chapter 2, an early termination fee must be a reasonable estimate of the retailer's costs resulting from early termination, and the manner of calculating the fee must be detailed in the contract.136 One retailer, EnergyAustralia, charged an early termination fee. This $22.00 fee applied only to the Rate Fix (Home) offer, under which prices were fixed for two years.137

Standing offers The National Energy Retail Law (Queensland) Act 2014 (Qld) (Queensland NERL Act) restricted retailers to including the following three types of fees to standing offer customers in 2016–17:  a fee to provide, upon a customer's request, historical billing data which is more than two years old  a retailer administration fee for a dishonoured payment  a financial institution fee for a dishonoured payment.138 In terms of retail fees and charges, residential flat rate standing offers published on Energy Made Easy as at 30 June 2017 included dishonour payment fees only. The table below shows the dishonour payment fees attached to residential flat rate standing offers as at 30 June 2017. Table 39 Retail fees and charges attached to residential flat rate standing offers, 30 June 2017

Retailer Dishonour payment fee - cheque Dishonour payment fee - direct ($) debit ($)

AGL 10.00 3.50

Diamond Energy — 10.00

Dodo Power & Gas — 9.50c

Energy Locals — 11.00d

Mojo Power — 2.50

Momentum Energy 9.50 —

People Energy 15.00a 15.00e

Powerdirect 12.00 5.00

Sanctuary Energy 15.00b 15.00f

136 National Energy Retail Rules, rule 49A. 137 The features of the Rate Fix – Home offer are outlined in Chapter 3, section 3.4.1 (other incentives and benefits subsection). 138 National Energy Retail Law, section 22A, as per section 15 of the schedule to the Queensland NERL Act; Queensland Government Gazette 2015, page 190. Chapter 9 reports on significant issues that emerged in SEQ regarding the restriction on the types of fees that retailers could charge standing offer customers in 2016–17. The fee types restriction also applies in 2017–18.

Queensland Competition Authority Fees and charges

a Costs would be passed on up to $15. b Costs would be passed on up to $15. c The fee may have applied. d The fee was listed as an 'other fee' on Energy Made Easy. We have assigned it to the dishonour payment fee – direct debit category on the basis that Energy Locals' website lists direct debit, credit card and Bpay as its payment methods, and the retailer does not accept payment by cheque.139 e Costs would be passed on up to $15. f Costs would be passed on up to $15. Notes: We identify where retailers' noted on Energy Made Easy that certain fees 'may' have applied. Click Energy, EnergyAustralia, Lumo Energy, Next Business Energy, Origin Energy, Powershop, QEnergy, Red Energy and Simply Energy had at least one residential flat rate standing offer published on Energy Made Easy as at 30 June 2017, but did not include any retail fees or charges on their offer(s). A dash (—) means the retailer did not charge the dishonour payment fee type. Where a retailer has a retail fee or charge identified, it did not necessarily attach that fee or charge to all of the residential flat rate standing offers it published on Energy Made Easy in 2016–17. Source: Energy Made Easy (except where noted). QCA assessment Nine of the 18 retailers with residential standing offers published on Energy Made Easy as at 30 June 2017 attached dishonour payment fees to at least one of their offers. Fees for dishonoured cheque payments ranged from $9.50 on Momentum Energy's offer to up to $15.00 on People Energy's and Sanctuary Energy's offers. Fees for dishonoured direct debit payments ranged from $2.50 on Mojo Power's offers, to up to $15.00 on People Energy's and Sanctuary Energy's offers. The comparison of retailers' inclusion of retail fees and charges on their standing offers suggests that all retailers were compliant as at 30 June 2017 with the restriction on the types of fees that could be charged on residential standing offers.140

4.4.2 Small business flat rate offers Market offers Small business flat rate market offers published on Energy Made Easy as at 30 June 2017 included the following retailers' fees and charges:  credit and debit card payment fees  payment processing fees—in dollar and percentage amounts—on payments made by cheque, or over the counter (at Australia Post)  dishonoured cheque and direct debit payment fees  late payment fees  early termination fees. The tables below show the retailers' fees and charges attached to small business flat rate market offers as at 30 June 2017.

139 Energy Locals, 'How can I pay my bill'?, https://help.energylocals.com.au/prices-and-billing/how-can-i-pay- my-bill; Energy Locals 2017, response to part 3 of the QCA's information notice (unpublished). 140 Chapter 9 reports on retailers' compliance with the fee types restriction in the course of 2016–17.

Queensland Competition Authority Fees and charges

Table 40 Retail payment processing fees and charges attached to small business market offers, 30 June 2017

Retailer Credit / debit Visa / Amex / Diners Paper bill fees Over the card fees — MasterCard Club fees (%) ($) counter (at general fees (%) Australia Post) application (%) fees ($)

AGL 0.55 — — 1.75f 2.00h

Click Energy 0.60 — — — —

EnergyAustralia — 0.36 1.50d 1.69 1.91

Energy Locals 1.00 — — 2.00 —

ERM Power — 0.50 and 0.55b 1.65 and 1.87e — —

Origin Energy — 0.37c — 1.75g 2.00i

Powerdirect 0.55 — — — —

QEnergy — — — 2.75 —

Simply Energy 0.60a — — — —

a Applied to credit card payments only. b 0.50% applied to Visa payments, 0.55% applied to MasterCard payments. c The fee may have applied. d Amex only. e 1.65% applied to Diners Club payments, 1.87% applied to Amex payments. f The fee may have applied. g The fee applied to BusinessSaver Electricity Usage Discount and Business eSaver off Electricity Usage Discount offers. The fee did not apply to the Supply offer. h The fee may have applied. i The fee applied to BusinessSaver Electricity Usage Discount and Business eSaver off Electricity Usage Discount offers. The fee did not apply to the Supply offer. Notes: Diamond Energy, Dodo Power & Gas, Mojo Power, Momentum Energy, Next Business Energy, People Energy and Sanctuary Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 June 2017. Lumo Energy, Powershop and Red Energy had at least one small business flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any payment processing fees on their offer(s). QEnergy's offers published in July 2016 included the following payment processing fees: credit card fee (1.7%); paper bill processing fee ($2.75) and cheque payment processing fee ($5.00). QEnergy ceased charging these fees, with the exception of the paper bill processing fee, in May 2017.141 A dash (—) means the retailer did not include the fee or charge type in any of its small business flat rate market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a retail fee or charge identified, it did not necessarily attach that fee or charge to all of the small business flat rate market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis.

141 QEnergy 2017, response to part 2 of the QCA's information notice (unpublished).

Queensland Competition Authority Fees and charges

Table 41 Retail dishonour payment, late payment and early termination fees and charges attached to small business market offers, 30 June 2017

Retailer Dishonour Dishonour Late payment fees Early termination payment fee - payment fee - ($) fees ($) cheque ($) direct debit ($)

AGL 10.00 3.50 12.73b —

Click Energy — — 12.00 —

EnergyAustralia — — 12.00 22.00e

Energy Locals — 11.00a 13.00 —

ERM Power 27.50 27.50 — —

Origin Energy — — 12.00c 20.00f

Powerdirect 12.00 5.00 12.73d —

a The fee was listed as an 'other fee' on Energy Made Easy. We have assigned it to the dishonour payment fee – direct debit category on the basis that Energy Locals' website lists direct debit, credit card and Bpay as its payment methods, and the retailer does not accept payment by cheque.142 b The fee may have applied. c The fee may have applied. d The fee may have applied. e Applied to Rate Fix (Business), Everyday Saver (Business) and Basic Saver (Business) offers. The fee did not apply to the Flexi Saver – Business offer. f Applied to BusinessSaver Electricity Usage Discount and Business eSaver off Electricity Usage Discount offers. The fee did not apply to the Supply offer. Notes: Diamond Energy, Dodo Power & Gas, Mojo Power, Momentum Energy, Next Business Energy, People Energy and Sanctuary Energy did not have a small business flat rate market offer published on Energy Made Easy as at 30 June 2017. Lumo Energy, Powershop and Red Energy had at least one small business flat rate market offer published on Energy Made Easy as at 30 June 2017, but did not include any dishonour payment, late payment or early termination fees on their offer(s). QEnergy's offers published in July 2016 included the following fees: dishonoured cheque payment fee ($14.85); late payment fee ($14.85); and early termination fee ($22.00 on Biz Saver Single Rate offer and $82.50 on Freedom Biz offer). QEnergy ceased charging these fees in May 2017.143 A dash (—) means the retailer did not include the fee type in any of its small business flat rate market offers published on Energy Made Easy as at 30 June 2017. Where a retailer has a retail fee or charge identified, it did not necessarily attach that fee or charge to all of the small business flat rate market offers it published on Energy Made Easy in 2016–17. Sources: Energy Made Easy; QCA analysis. QCA assessment Nine of the 12 retailers with small business market offers published on Energy Made Easy as at 30 June 2017 attached retail fees and charges to at least one of their offers. Lumo Energy, Powershop and Red Energy did not attach retail fees and charges to any of their small business market offers. EnergyAustralia and Origin Energy did not apply the same fee and charge types to each of their respective small business market offers. The following subsections outline our assessment of each fee type for the nine retailers with retail fees and charges attached to at least one offer.

Payment processing fees Eight of the nine retailers included processing fees on debit and/or credit card payments on at least one of their offers. QEnergy was the exception; it did not include these fees. The fees ranged from 0.36 per cent on payments made to EnergyAustralia by Visa and MasterCard, to 1.87 per cent on payments made to ERM Power by Amex.

142 Energy Locals, 'How can I pay my bill?', https://help.energylocals.com.au/prices-and-billing/how-can-i-pay- my-bill; Energy Locals 2017, response to part 3 of the QCA's information notice (unpublished). 143 QEnergy 2017, response to part 2 of the QCA's information notice (unpublished).

Queensland Competition Authority Fees and charges

Five retailers charged paper bill processing fees, ranging from EnergyAustralia's $1.69 fee to QEnergy's $2.75 fee. Three retailers charged over the counter payment fees for payments made at Australia Post, ranging from $1.91 charged by EnergyAustralia, to $2.00 charged by AGL and Origin Energy (on two of its three offers). However, retailers did not consistently identify the payment methods available, or not available, on their small business flat rate market offers. This made it difficult to compare payment processing fees across offers and retailers.

Dishonour payment fees ERM Power's $27.50 fee on dishonoured direct debit and cheque payments was the largest fee of this type in the market. AGL had the lowest dishonoured direct debit and cheque payment fees of $3.50 and $10.00 respectively.

Late payment fees Six retailers included late payment fees on at least one offer, ranging from $12.00 levied by Click Energy, EnergyAustralia and Origin Energy, to $13.00 levied by Energy Locals.

Early termination fees Two retailers, EnergyAustralia and Origin Energy, charged an early termination fee. EnergyAustralia charged a $22.00 fee on three of its four offers, and Origin Energy charged a $20.00 fee on two of its three offers. Of the three EnergyAustralia offers that attracted an early termination fee, one included guaranteed and pay on time discounts off usage charges, one included a guaranteed discount off usage charges, and another provided for fixed prices for two years.144 The offer which did not include an early termination fee included a pay on time discount only. The two Origin Energy offers which included an early termination fee also included discounts on usage charges, whereas the offer which did not attract the fee did not include any discounts. We observe that, where early termination fees applied, they generally were attached to offers with relatively more favourable discounts and/or other incentives and benefits, compared to other offers.

Standing offers In terms of retail fees and charges, small business flat rate standing offers published on Energy Made Easy as at 30 June 2017 included dishonour payment fees only. The table below shows the dishonour payment fees attached to small business flat rate standing offers as at 30 June 2017.

144 The discounts on the Basic Saver (Business), Everyday Saver (Business) and Flexi Saver (Business) offers are outlined in Chapter 3, section 3.4.2 (discounts subsection). The features of the Rate Fix (Business) offer outlined in Chapter 3, section 3.4.2 (other incentives and benefits subsection).

Queensland Competition Authority Fees and charges

Table 42 Retail fees and charges attached to small business flat rate standing offers, 30 June 2017

Retailer Dishonour payment fee - cheque Dishonour payment fee - direct ($) debit ($)

AGL 10.00 3.50

Diamond Energy — 10.00

Energy Locals — 11.00a

ERM Power 27.50 27.50

Momentum Energy 9.50 —

Powerdirect 12.00 5.00

4.5 GST on fees For the residential and small business offers above, we note that the reported GST treatment within some fee types was inconsistent or unclear between retailers. For example:  Mojo Power's $2.50 dishonour payment fee for direct debit payments on its residential market offers was GST exempt, whereas Dodo Power & Gas's $9.50 fee included GST.  Most retailers reported late payment fees as being exempt from GST, but Origin Energy reported these fees as including GST for some of its offers.  EnergyAustralia's credit card payment fees on small business offers were GST exclusive, while all other retailers (except Simply Energy who did not report the GST status of its credit card fee) included GST on their credit card payment fees.

145 Energy Locals, 'How can I pay my bill'?, https://help.energylocals.com.au/prices-and-billing/how-can-i-pay- my-bill; Energy Locals 2017, response to part 3 of the QCA's information notice (unpublished). 146 Chapter 9 reports on retailers' compliance with the fee types restriction in the course of 2016–17.

Queensland Competition Authority Fees and charges

 In many instances, the GST status of fees was simply not stated by the retailer.

4.6 Fees that 'may' have applied In terms of fees that retailers identified 'may' have applied on some residential and small business offers, we appreciate that there may be circumstances in which the fees may not apply, but have included them in the analysis on the assumption that customers should consider the potential to be charged these fees when comparing offers.

4.7 Additional fee information on Energy Made Easy Some retailers included information on their offers on Energy Made Easy referring to the potential for retail fees and charges—other than those listed on Energy Made Easy—to be levied on customers. For example:  AGL and Powerdirect stated that additional fees and charges may have applied, and suggested customers refer to the standing offer terms and conditions for standing offers, or the market contract fee schedule for market offers, on their websites (www.agl.com.au and www.powerdirect.com.au respectively).  EnergyAustralia's Rate Fix – Home, Anytime Saver – Home and Flexi Saver – Home offers noted that the fees would apply to "many customers", that "[s]ome exclusions" applied, and the "best way" to avoid the fees published on the offers was to receive bills by email and pay either by direct debit or through a bank account via Bpay.  Lumo Energy's standing and market offers stated that, for the full schedule of fees applicable to the offers, customers should visit a page on its website (http://www.lumoenergy.com.au/help-centre/fee-schedule-qld) or call Lumo Energy on 1300 11 58 66.  Mojo Power's standing and market offers stated that, for information on additional fees and conditions that may have applied, customers should visit its website (www.mojopower.com.au).  Red Energy referred customers to a page on its website (www.redenergy.com.au/additionalservicechargesqld) for more information on its additional fees and charges.  Simply Energy stated that additional fees may have applied on its standing and market offers, and suggested customers call the retailer for more information. We consider all retailers should clearly identify on Energy Made Easy where customers can obtain information on additional retail fees and charges that apply, or may apply, to their offers.

4.8 Conclusion The key points of our comparison and assessment of retail fees and charges for 2016–17 are summarised below.

Queensland Competition Authority Fees and charges

Comparison and assessment (1) Most retailers who published residential and/or small business market offers included retail fees and charges on at least some of their offers. (2) Powershop and Red Energy did not attach retail fees and charges to any of their residential market offers. (3) Lumo Energy, Powershop and Red Energy did not attach retail fees and charges to any of their small business market offers. (4) The types of retail fees included on the market offers were credit and debit card payment fees, payment processing fees on payments made by cheque, direct debit, or over the counter (at Australia Post), dishonoured cheque and direct debit payment fees, late payment fees and early termination fees. (5) For most fee types, the range of the charges was narrow. (6) Retailers appeared to be compliant with the restriction on the types of retail fees they could include on their residential and small business standing offers at the end of the year. (7) Retailers did not consistently identify the payment methods available, or not available, on their offers on Energy Made Easy. This made it difficult to compare payment processing charges across offers and retailers. (8) Some retailers included information on their offers on Energy Made Easy referring to the potential for retail fees and charges—other than those listed on Energy Made Easy—to be levied on customers. We consider all retailers should clearly identify on Energy Made Easy where customers can obtain information on additional retail fees and charges that apply, or may apply, to their offers. (9) For some fee types, the reported GST treatment on residential and small business market offers was inconsistent or unclear between retailers.

Queensland Competition Authority Trends in standing and market offer prices

5 TRENDS IN STANDING AND MARKET OFFER PRICES

This chapter reports on trends in retailers' standing offer and generally available market offer prices available in 2015–16 and 2016–17.

5.1 Minister's Direction Section 2(e) of the Direction requires the market monitoring report to include a comparison and assessment of any trends in relation to retailers' standing offer prices and generally available market offer prices between 2015–16 and 2016–17.

5.2 QCA methodology We used information from Energy Made Easy for standing and market offer prices for 2015–16 to assess any trends in prices. We report on trends using the same tariffs and tariff combinations which we use in Chapter 2 to report on prices (and variations) for 2016–17. That is, we report on:  for residential customers—a flat rate tariff, and a combination of a flat rate tariff and either a controlled load super economy tariff or a controlled load economy tariff  for small business customers— a flat rate tariff and a time-of-use tariff. We also use the same consumption data for trend analysis that we use in Chapter 2.

5.3 QCA monitoring 5.3.1 Residential flat rate offers The table and figure below show the average standing offer, the average market offer, and the averages of retailers' lowest and highest market offers for the four quarters in each of 2015–16 and 2016–17. Table 43 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate offers)

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

September 2015 1,442 1,388 1,329 1,445

December 2015 1,442 1,384 1,345 1,424

March 2016 1,446 1,366 1,342 1,395

June 2016 1,446 1,362 1,333 1,399

September 2016 1,565 1,408 1,365 1,453

December 2016 1,551 1,406 1,370 1,442

March 2017 1,548 1,399 1,364 1,431

June 2017 1,548 1,420 1,381 1,453

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis.

Queensland Competition Authority Trends in standing and market offer prices

Figure 26 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate offers)

$1,600

$1,500

$1,400

$1,300

$1,200 Sept Dec March June Sept Dec March June 2015 2015 2016 2016 2016 2016 2017 2017

Ave standing offer Ave mkt offer Ave low mkt offer Ave high mkt offer

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. QCA assessment Between September 2015 and June 2017, the average residential flat rate standing offer increased by 7.4 per cent, and the average market offer increased by 2.3 per cent. The most significant trend for residential flat rate offers between 2015–16 and 2016–17 was the step increase in bills in the September quarter of 2016–17. The increases in the averages between the June and September 2016 quarters were:  8.3 per cent (from $1,446 to $1,565) for the average standing offer. This was driven mostly by the relatively high standing offers of two new entrants (Mojo Power and Next Business Energy)147  3.4 per cent (from $1,362 to $1,408) for the average market offer  2.4 per cent (from $1,333 to $1,365) for the average lowest market offer  3.9 per cent (from $1,399 to $1,453) for the average highest market offer. Following retail price deregulation on 1 July 2016, the increase in the average standing offer being significantly higher than the increase in the average market offer may have reflected a number of factors, including:  the marketing behaviours of retailers, who tended to discount market offer prices off standing offer prices

147 Excluding the Mojo Power and Next Business Energy standing offers, the increase in the average residential flat rate standing offer between the June and September 2016 quarters was 3.9 per cent (from $1,446 to $1,502).

Queensland Competition Authority Trends in standing and market offer prices

 retailers publishing a standing offer to comply with the National Energy Retail Law148, but setting standing offer prices at a level so as not to attract customers 149  the costs of meeting standing offer terms and conditions, and/or  retailers being prevented from changing their standing offer prices after they were set in 2016–17, unless it was to reduce the price150. The other notable trend for residential flat rate offers was the narrowing of the gap between the average low and average high market offers. In the September 2015 quarter, the gap between the average low market offer ($1,329) and the average high market offer ($1,445) was 8.7 per cent. By the June 2017 quarter, the gap between the low ($1,381) and high ($1,453) average market offer had narrowed to 5.2 per cent.

5.3.2 Residential flat rate with controlled load super economy offers The table and figure below show the average standing offer, the average market offer, and the averages of retailers' lowest and highest market offers for the four quarters in each of 2015–16 and 2016–17. Table 44 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate with controlled load super economy offers)

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

September 2015 1,771 1,670 1,600 1,738

December 2015 1,769 1,661 1,614 1,710

March 2016 1,772 1,639 1,609 1,674

June 2016 1,772 1,640 1,604 1,686

September 2016 1,869 1,724 1,670 1,778

December 2016 1,863 1,737 1,694 1,781

March 2017 1,866 1,733 1,692 1,770

June 2017 1,866 1,761 1,719 1,802

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis.

148 National Energy Retail Law, section 20. 149 In Chapter 2 (Prices and variations to prices), we identify some of the highest standing offers which had no, or very few, customers contracted to in 2016–17. 150 National Energy Retail Law, section 23(9), as per section 16 of the schedule to the Queensland NERL Act.

Queensland Competition Authority Trends in standing and market offer prices

Figure 27 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate with controlled load super economy offers)

$1,900

$1,800

$1,700

$1,600

$1,500 Sept Dec March June Sept Dec March June 2015 2015 2016 2016 2016 2016 2017 2017

Ave standing offer Ave mkt offer Ave low mkt offer Ave high mkt offer

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. QCA assessment Between September 2015 and June 2017, the average standing offer for this tariff combination increased by 5.3 per cent, and the average market offer increased by 5.2 per cent. The most significant trend for residential flat rate with controlled load super economy offers between 2015–16 and 2016–17 was the step increase in bills in the September quarter of 2016– 17. The increases in the averages between the June and September 2016 quarters were:  5.4 per cent (from $1,772 to $1,869) for the average standing offer. This was driven by the relatively high standing offer of a new entrant (Mojo Power) and large increases in the standing offer prices by retailers who were in the market in 2015–16 (particularly Click Energy, Diamond Energy and Urth Energy).151  5.1 per cent (from $1,640 to $1,724) for the average market offer  4.1 per cent (from $1,604 to $1,670) for the average low market offer  5.4 per cent (from $1,686 to $1,778) for the average high market offer. We consider the possible reasons for the increase in the average standing offer being significantly higher than the increase in the average market offer for this tariff combination to be the same as discussed above for the residential flat rate offers.

5.3.3 Residential flat rate with controlled load economy offers The table and figure below show the average standing offer, the average market offer, and the averages of retailers' lowest and highest market offers for the four quarters in each of 2015–16 and 2016–17.

151 Excluding the Mojo Power standing offer, the increase in the average standing offer for this tariff combination between the June and September 2016 quarters was 3.6 per cent (from $1,772 to $1,837).

Queensland Competition Authority Trends in standing and market offer prices

Table 45 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate with controlled load economy offers)

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

September 2015 1,759 1,658 1,590 1,727

December 2015 1,756 1,641 1,582 1,701

March 2016 1,760 1,631 1,601 1,666

June 2016 1,760 1,629 1,594 1,675

September 2016 1,829 1,683 1,632 1,735

December 2016 1,822 1,689 1,648 1,731

March 2017 1,822 1,684 1,645 1,720

June 2017 1,822 1,707 1,666 1,747

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. Figure 28 Average annual bills for a typical residential customer, 2015–16 and 2016–17 (residential flat rate with controlled load economy offers)

$1,900

$1,800

$1,700

$1,600

$1,500 Sept Dec March June Sept Dec March June 2015 2015 2016 2016 2016 2016 2017 2017

Ave standing offer Ave mkt offer Ave low mkt offer Ave high mkt offer

Queensland Competition Authority Trends in standing and market offer prices

 2.4 per cent (from $1,594 to $1,632) for the average low market offer  3.6 per cent (from $1,675 to $1,735) for the average high market offer. We consider the possible reasons for the increase in the average standing offer being significantly higher than the increase in the average market offer for this tariff combination to be the same as for the residential flat rate offers.

5.3.4 Small business flat rate offers The table and figure below show the average standing offer, the average market offer, and the averages of retailers' lowest and highest market offers for the four quarters in each of 2015–16 and 2016–17. Table 46 Average annual bills for a typical small business customer, 2015–16 and 2016–17 (small business flat rate offers)

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

September 2015 2,141 2,034 1,951 2,118

December 2015 2,141 2,021 1,964 2,084

March 2016 2,142 2,022 1,977 2,074

June 2016 2,142 2,033 2,000 2,078

September 2016 2,478 2,219 2,197 2,247

December 2016 2,468 2,228 2,210 2,248

March 2017 2,475 2,233 2,215 2,255

June 2017 2,500 2,271 2,247 2,295

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. Figure 29 Average annual bills for a typical small business customer, 2015–16 and 2016–17 (small business flat rate offers)

$2,600

$2,500

$2,400

$2,300

$2,200

$2,100

$2,000

$1,900 Sept Dec March June Sept Dec March June 2015 2015 2016 2016 2016 2016 2017 2017

Ave standing offer Ave mkt offer Ave low mkt offer Ave high mkt offer

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis.

Queensland Competition Authority Trends in standing and market offer prices

QCA assessment Between September 2015 and June 2017, the average small business flat rate standing offer increased by 16.8 per cent, and the average market offer increased by 11.6 per cent. The most significant trend for small business flat rate offers between 2015–16 and 2016–17 was the step increase in bills in the September quarter of 2016–17. The increases in the averages between the June and September 2016 quarters were:  15.7 per cent (from $2,142 to $2,478) for the average standing offer. This was driven by the relatively high standing offer of a new entrant (Next Business Energy) and large increases in the standing offer prices by retailers who were in the market in 2015–16 (particularly ERM Power and QEnergy)152  9.1 per cent (from $2,033 to $2,219) for the average market offer  9.8 per cent (from $2,000 to $2,197) for the average low market offer  8.2 per cent (from $2,078 to $2,247) for the average high market offer. We consider the possible reasons for the increase in the average standing offer being significantly higher than the increase in the average market offer for small business flat rate offers to be the same as for the residential flat rate (and controlled load combination) offers. The step increase in small business flat rate bills in the first quarter of 2016–17 was also noticeably higher than the step increase in the residential bills. The other notable trend for small business flat rate offers was the narrowing of the gap between the average low and average high market offers. In the September 2015 quarter, the gap between the average low market offer ($1,951) and the average high market offer ($2,118) was 8.5 per cent. By the June 2017 quarter, the gap between the low ($2,247) and high ($2,295) average market offer had narrowed to 2.1 per cent.

5.3.5 Small business time-of-use offers The table and figure below show the average standing offer, the average market offer, and the averages of retailers' lowest and highest market offers for the four quarters in each of 2015–16 and 2016–17. Table 47 Average annual bills for a typical small business customer, 2015–16 and 2016–17 (small business time-of-use offers)

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

September 2015 5,700 5,405 5,173 5,631

December 2015 5,701 5,338 5,175 5,576

March 2016 5,703 5,366 5,269 5,491

June 2016 5,703 5,416 5,347 5,518

September 2016 6,895 6,042 5,940 6,146

December 2016 6,853 6,086 6,010 6,161

152 Excluding the Next Business Energy standing offer, the increase in the average small business flat rate standing offer between the June and September 2016 quarters was 12.8 per cent (from $2,142 to $2,416).

Queensland Competition Authority Trends in standing and market offer prices

Quarter Average standing Average market Average lowest Average highest offer ($) offer ($) market offer ($) market offer ($)

March 2017 6,779 6,094 6,039 6,165

June 2017 6,856 6,243 6,182 6,316

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. Figure 30 Average annual bills for a typical small business customer, 2015–16 and 2016–17 (small business time-of-use offers)

$7,000

$6,600

$6,200

$5,800

$5,400

$5,000 Sept Dec March June Sept Dec March June 2015 2015 2016 2016 2016 2016 2017 2017

Ave standing offer Ave mkt offer Ave low mkt offer Ave high mkt offer

Sources: Energy Made Easy; retailers' responses to parts 1 and 3 of the QCA's information notice; QCA analysis. QCA assessment Between September 2015 and June 2017, the average small business time-of-use standing offer increased by 20.3 per cent, and the average market offer increased by 15.5 per cent. The most significant trend for small business time-of-use offers between 2015–16 and 2016–17 was the step increase in bills in the September quarter of 2016–17. The increases in the averages between the June and September 2016 quarters were:  20.9 per cent (from $5,703 to $6,895) for the average standing offer. This was driven by the relatively high standing offer of a new entrant (Next Business Energy) and large increases in the standing offer prices by retailers who were in the market in 2015–16 (particularly ERM Power and QEnergy)153  11.6 per cent (from $5,416 to $6,042) for the average market offer  11.1 per cent (from $5,347 to $5,940) for the average low market offer  11.4 per cent (from $5,518 to $6,146) for the average high market offer. We consider the possible reasons for the increase in the average standing offer being significantly higher than the increase in the average market offer for small business time-of-use

153 Excluding the Next Business Energy standing offer, the increase in the average small business time-of-use standing offer between the June and September 2016 quarters was 17.2 per cent (from $5,703 to $6,686).

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offers to be the same as for the residential flat rate (and controlled load combination) and small business flat rate, offers. As was the case with the small business flat rate bills, the step increase in small business time- of-use bills in the first quarter of 2016–17 was also noticeably higher than the step increase in the residential bills. The other notable trend for small business time-of-use offers was the narrowing of the gap between the average low and average high market offers. In the September 2015 quarter, the gap between the average low market offer ($5,173) and the average high market offer ($5,631) was 8.9 per cent. By the June 2017 quarter, the gap between the low ($6,182) and high ($6,316) average market offer had narrowed to 2.2 per cent.

5.4 Conclusion The key points of our comparison and assessment of trends in prices over 2015–16 and 2016–17 are summarised below.

Comparison and assessment For each of the most common tariffs and tariff combinations: (1) Standing and market offer bills had a step increase between 2015–16 and 2016–17. (2) The step increase in the average standing offer price was higher than the step increase in the average market offer bill. (3) The differences between the highest market offers and the lowest market offers narrowed during the period.

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6 SWITCHING TO MARKET OFFERS

This chapter compares and assesses the number of customers moving from standing to market offers with their retailer, and provides information on characteristics of those customers, in 2016–17.

6.1 Background Standing offers are basic contracts with regulated terms and conditions which generally provide a greater range of protections for customers compared to market offers.154 Market offers retain minimum terms and conditions, but conditions such as payment options and fees can be varied, and these contracts may include a fixed term or benefit period.155 Standing offer prices are generally higher than market offer prices, reflecting to some extent the difference in terms and conditions between the two types of contract, and the impact of this difference on retailer costs. Despite the generally higher prices, some customers opt to remain on standing offers. This may be because customers value greater customer protections in standing offers. Customers who are not price-sensitive may also prefer the simplicity of standing offers to the (relative) complexity of market offers. In May 2017, the AER reported that about 70 per cent of small electricity customers in SEQ were on market contracts.156 Generally, an increase in customers moving from standing to market offers would indicate an increase in the number of customers actively engaging in the competitive market. However, the data reported in the market monitoring report under this part of the Direction will understate the overall number of standing offer customers switching to market offers in the SEQ market. This is because when a customer on a standing offer transfers to a market offer with a new retailer, the new retailer does not have any record of the type of contract the customer was on with their previous retailer. As such it is not possible for the QCA to capture data on customers who switched from a standing offer with one retailer to a market offer with a different retailer. We consider it will therefore be difficult for stakeholders to draw conclusions about the state of competition in SEQ based on this measure alone, given the inability to capture data on all customers switching to market offers and the preference of an unquantified number of customers to remain on standing offers.

6.2 Minister's Direction Section 2(f) of the Direction requires the market monitoring report to include:  a comparison and assessment of the number of customers who moved from a standing offer to a market offer with a retailer in 2016–17, and  information on the following characteristics of those customers;  their location  their electricity consumption

154 See also Chapter 2, section 2.1.1 for detail. 155 National Energy Retail Rules, rule 14. 156 AER 2017b, section 4.8.1.

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 whether they were participating in a retailer hardship program or received an energy concession  whether they had an electricity debt.

6.3 QCA methodology 6.3.1 Customer location Section 2(f)(i) of the Direction requires the QCA to report on the location of customers who switched from a standing offer to a market offer with their existing retailer during the reporting period. The Direction does not define 'location' or the level of detail which the QCA should include on location in its report. In our scoping paper, we said that the most accurate, and simplest, way for retailers to identify the location of customers switching from standing offers to market offers would be to reference the postcode of the premises being supplied. We suggested that this would likely result in a larger dataset being provided by retailers than could be feasibly presented in the main body of the market monitoring report. In order to present a useful level of detail in the main report while not limiting data available to stakeholders, we intended to present data for the top 10 postcodes in the report, and said that we may provide a full list of figures for all postcodes in an appendix to the market monitoring report. Finally, we said that we would examine the data and provide commentary on any notable geographical patterns present in the data collected from retailers.157 The scoping paper proposed reporting the top 10 switching postcodes on the basis of the number of the total number of switching customers in each postcode.158 We also stated in the scoping paper that we would also report on areas of low switching.159

6.3.2 Customer electricity consumption Section 2(f)(ii) of the Direction requires the QCA to report on the electricity consumption of customers switching from a standing offer to a market offer with their existing retailer during 2016–17. In our scoping paper, we indicated that total consumption data for these customers (including supply from other tariffs, such as controlled load) would need to be obtained from retailers, who we anticipated would be able to provide 2016–17 consumption data for each of their customers who switched from a standing offer to a market offer.160 We suggested that:  consumption data should be presented on an annual basis to provide comparability with the rest of the market monitoring report consumption data  consumption data that did not cover the entire 2016–17 reporting period would be annualised

157 QCA 2016a, section 3.3.1. 158 See QCA 2016a, section 3.3.1 (Table 7). 159 QCA 2016a, section 3.3.1. 160 QCA 2016a, section 3.3.2.

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 we would present consumption data in 500 kWh bands, with charts showing the number of customers in each consumption band. The scoping paper showed our intention to prepare charts showing the number of customers in each consumption band.161

6.3.3 Customers participating in a retailer hardship program or receiving an energy concession Section 2(f)(iii) of the Direction requires the QCA to report on the number of customers switching from standing offers to market offers with their existing retailer who are participating in a retailer hardship program, or are receiving the Queensland Government's electricity rebate (the electricity rebate). Hardship programs are formal assistance programs which aim to provide assistance to residential customers experiencing financial difficulty. SEQ retailers must implement a customer hardship policy which aims to identify residential customers experiencing payment difficulties due to hardship and to assist those customers to better manage their energy bills on an ongoing basis. These policies must be approved by the AER.162 The electricity rebate has historically been available to customers with:  a Pensioner Concession Card issued by either Centrelink or Department of Veterans' Affairs  a Department of Veterans' Affairs Gold Card (and recipient of the War Widow Pension or special rate TPI Pension)  a Queensland Government Seniors Card (seniors card).163 In its response to the QPC's electricity pricing inquiry final report, the Queensland Government extended eligibility for the electricity rebate—which in 2016 provided assistance of $330 per annum—to include Commonwealth Health Care Card holders and asylum seekers from 1 January 2017.164 In our scoping paper, we indicated that:  using information provided by SEQ's electricity retailers, we would report on the number of customers participating in these programs  it was, however, possible for customers to participate in a hardship program while simultaneously receiving the electricity rebate  in order to avoid overstating the overall number of customers on these programs we would also request, and report on, data on these customers in the market monitoring report.165 In order to provide a sufficient level of detail for the market monitoring report, we intended to present overall data for these measures in the main body of the report, and said that we may provide a full listing of data by retailer in an appendix for stakeholders seeking more detail.166

161 See QCA 2016a, section 3.3.2 (Figure 5). 162 See the National Energy Retail Law, section 43 and the AER's customer hardship policies web page, https://www.aer.gov.au/retail-markets/energy-retailers-customer-hardship-policies. 163 More information can be found on the DEWS website, https://www.dews.qld.gov.au/electricity/rebates. 164 Queensland Government 2016, page 14 (response to QPC Recommendation 43). 165 QCA 2016a, section 3.3.3. 166 QCA 2016a, section 3.3.3 (Table 8).

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6.3.4 Customers with electricity debt Section 2(f)(iv) of the Direction requires the QCA to report on the number of customers switching from standing offers to market offers who had an electricity debt. The Direction does not define the term 'electricity debt'. However, the AER's recent retail energy market performance reports define electricity debt as 'an amount owed to a retailer that has been outstanding for 90 days or more'.167 In the interest of consistency with figures published by the AER, as well as minimising the regulatory burden on retailers, we said in our scoping paper that we intended to require retailers to use the same definition when reporting numbers of hardship customers under section 2(f)(iv) of the Direction.168

6.4 Proposed data requirements In order to report data as required by section 2(f) of the Direction, our scoping paper indicated that we would request the following information from retailers:  The number of customers who switched from a standing offer to a market offer during 2016–17.  The location (by postcode) of customers who switched.  The electricity consumption of customers who switched, and the number of days over which the electricity was consumed.  The number of customers who switched who were participating in a retailer hardship program, or were receiving the electricity rebate, and the number of customers who were participating in a hardship program and were receiving the electricity rebate.  The number of customers who switched who, at any time during 2016–17, had an electricity debt which was outstanding for 90 days or more.169

6.5 Submissions 6.5.1 Definition of a customer Submission Origin Energy requested clarification on how the QCA planned to define 'customer' for the purpose of market monitoring. Origin Energy said that the QCA had previously required data to be provided on a NMI level, but all other reporting for the AER and the Victorian Essential Services Commission (ESC) was done at an account level. Origin Energy suggested that the QCA defines a customer by account level rather than by NMIs; the benefit of this is that accounts are linked to each customer's debt, concession and rebates, and data can be matched accordingly. Origin Energy considered that this would make data extraction far more efficient and ensure that the QCA's reporting requirements are aligned with other jurisdictions.170

167 AER 2015b, section 2.3; AER 2016, section 2.3. 168 QCA 2016, section 3.3.4. 169 QCA 2016, section 3.4. 170 Origin Energy 2016, pages 1–2.

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QCA position The QCA agrees with Origin Energy's suggestion that customers be defined at the account level. In February, the QCA confirmed with all retailers operating in SEQ that customers would be defined at the account level.

6.5.2 Customer location Submission QCOSS noted that the QCA proposed to report the top 10 postcodes for switching, but argued that:  there are significant differences in the number of premises in each postcode area  reporting the top 10 areas would bias the results by the postcodes with the largest number of premises.171 QCOSS recommended that the QCA's analysis by postcode should be on the basis of comparison of the number of customers switching in the postcode area as a proportion of the total number of residential and small business customers in the postcode area. QCOSS suggested that the number of residential and small business customers in each postcode area should be obtainable from Energex.172

QCA position Energex publishes the number of business and domestic customers by postcode on the 'data to share' page of its website.173 However, this data is at the connection (NMI), not customer account, level; also, Energex's business connection numbers include small and large business customers.174 Therefore, given that the QCA defines residential and small business customers at the account level, Energex's connection data could not be used to express the numbers of customers switching from standing to market offers as a proportion of total customers by postcode. However, we acknowledge the merits of reporting on the number of customers in a postcode switching as a proportion the total customers in each postcode. Through the information notices, we required retailers to state the total number of customers in each postcode.

6.5.3 Customer consumption Submissions EnergyAustralia noted that the concepts of 'billing data' and 'consumption data' appeared to be used interchangeably in the QCA's scoping paper. EnergyAustralia submitted that, while these concepts were related, they have different meanings and would impact on the QCA's analysis if retailers did not provide consistent data. EnergyAustralia stated that it would not be possible to provide actual consumption and costs for 2016–17; instead, data provided would be customer

171 QCOSS 2016, section 3.1. 172 QCOSS 2016, section 3.1 (Recommendation 16). 173 Energex website, data to share page, https://www.energex.com.au/about-us/our-commitment/to-our- customers/connecting-with-you/data-to-share. 174 Energex 2017, unpublished advice.

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consumption and costs that are billed within that period. EnergyAustralia sought guidance from the QCA on its expectations regarding this data.175 Origin Energy and EnergyAustralia sought clarification from the QCA on whether 'electricity consumption' referred to the time period in which the customer was on a standing offer, market offer or the total consumption while the customer was contracted to the retailer during the financial year.176

QCA position The QCA accepts the points raised by stakeholders and, in part 2 of the QCA's information notice, required billed consumption data for the whole timeframe that the customer was contracted with the retailer during 2016–17.177 The information notice required retailers to provide the number of switching residential and small business customers grouped into consumption bands of 500kWh increments. Retailers were also required to state the number of days to which the consumption data applied to allow for annualisation of the data. For consistency with the price, trend, discounts and fees monitoring in previous chapters, data was required for switching customers on the following tariffs and tariff combinations:  residential flat rate  residential flat rate with controlled load super economy  residential flat rate with controlled load economy  small business flat rate  small business time-of-use.

6.5.4 Reporting on electricity debt (and hardship program and concession customers) Submission In light of its view that the switching information in the market monitoring report would only be a subset of standing offer customers switching to market offers, AGL considered the QCA's proposed information request in the scoping paper178 to be "excessive".179 AGL stated that it should be able to provide information on the number of customers who switched from a standing offer to market offer during 2016–17, and their location, electricity consumption and current participation in a retailer hardship program or receipt of an energy concession. However, AGL said it was "more problematic" to provide information on the number of customers who switched from a standing offer to a market offer, and who, at any time during 2016–17, had an electricity debt which was outstanding for 90 days or more. AGL stated that determining the number of customers who have an electricity debt outstanding for 90 days or more at any single point in time is a simple process, but that analysing whether a customer had any such debt at any [particular] time in 2016–17 was more complex.180

175 EnergyAustralia 2016, page 2. 176 Origin Energy 2016, page 2; EnergyAustralia 2016, page 2. 177 See Chapter 10 for more detail on the QCA's information notice. 178 QCA 2016a, section 3.4. 179 AGL 2016, pages 1–2. 180 AGL 2016, page 2.

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AGL encouraged the QCA to identify the specific reason for collecting specific information on debt, and amend the information request to satisfy the intent while making the extraction of data much simpler for retailers.181

QCA position Our approach is consistent with section 2(f)(iv) of the Direction, which requires us to report on the number of customers who moved from a standing offer to a market offer with their retailer in 2016–17, and their characteristics such as whether they had an electricity debt. We also clarified the 90 day time period—as described in the scoping paper—to be 90 calendar days, as per the AER definition.182 Further, to provide more meaningful information for stakeholders, we considered that retailers should provide information to the QCA about whether a customer switching from a standing to market offer had an electricity debt for 90 calendar days or more at the time of switching. We informed retailers of these changes as part of the draft switching, hardship and rebate part of the information notice we provided to them in February 2017. To provide consistency with reporting on switching customers with electricity debt, the notice also stated that switching customers who were participating in a retailer hardship program, and/or receiving the electricity rebate, should be reported on the at the time of switching basis.

6.6 QCA monitoring Retailers were required to provide 2016–17 data for the location of their switching and non- switching customers, switching customers' consumption, number of hardship and rebate switching customers and customers with a debt at the time of switching. EnergyAustralia did not submit a response to this section of the information notice.183 The table below summarises the switching data for residential and small business customers. Table 48 Customer switching summary, 2016–17

Number of switching Total number of Proportion of customers customers customers switching (%)

Residential 25,348 1,415,173 1.8%

Small business 2,081 108,819 1.9%

Total 27,429 1,523,992 1.8%

Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). The overall switching rate was approximately 1.8 per cent of 1.52 million customers. However, as noted in section 6.1, the AER has stated that about 70 per cent of customers in SEQ are on market contracts.184 Based on this proportion of customers on market contracts, the total number of customers switching from standing offers represents around 6 per cent of the number of customers on standing offers.

181 AGL 2016, page 2. 182 QCA 2016a, section 3.3.4. 183 EnergyAustralia provided a response in (early) September but later withdrew it. 184 AER 2017b, section 4.8.1.

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6.6.1 Customer location The 10 postcodes with the highest number of customers switching as a proportion of total customers in the postcode are presented below. A full list of postcodes and number of switching customers are presented in Appendix F. Table 49 Top 10 SEQ postcodes for switching

Postcode Postcode location(s) Local government Proportion of area switching customers (%)

4342 Lockrose, Lynford, Crowley Vale, Forest Hill, Glen Lockyer Valley, 3.64% Cairn, Glenore Grove Somerset

4309 Moogerah, Teviotville, Morwincha, Obum, Mount Scenic Rim 3.61% Edwards, Fassifern, Aratula, Kents Lagoon, Kalbar, Fassifern Valley, Milora, Kulgun, Tarome, Clumber, Charlwood, Frazerview, Munbilla

4350 East Toowoomba, Charlton, Darling Heights, Blue Toowoomba 3.57% Mountain Heights, Centenary Heights, Athol, Cotswold Hills, Cranley, Clifford Gardens, Drayton, Gowrie Mountain, Harlaxton, Finnie, Glenvale, Kearneys Spring, Harristown, Mount Kynoch, Middle Ridge

4568 Pinbarren, Pomona, Federal Noosa 3.48%

4155 Chandler Brisbane 3.38%

4347 Veradilla, Mount Whitestone, Ma Ma Creek, Lockyer Valley 3.30% Grantham, Winwill

4307 Mutdapilly, Harrisville, Coleyville, Wilson Plains, Ipswich, Scenic Rim 3.27% Warrill View, Silverdale, Radford

4346 Marburg Ipswich, Somerset 3.12%

4184 Perulpa Island, Russell Island, Karragarra Island, Redland 3.07% Lamb Island, Macleay Island, Peel Island, Coochiemudlo Island

4554 Ilkley, Eudlo Sunshine Coast 3.00%

Note: Location data provided by retailers includes small customers on all tariffs and tariff combinations. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); Australia Post website, http://auspost.com.au/postcode/; Electoral Commission Queensland, locality and postcodes list, https://www.ecq.qld.gov.au/electoral-boundaries/find-my-electorate. The heat map below illustrates the distribution of switching customers in the SEQ region.

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Figure 31 Proportion of switching customers by postcode in SEQ

Note: Retailers included a number of postcodes that are designated post office box locations (4001, 4002, 4003 and 4004). Customer data for these postcodes has been merged with postcode 4000 for mapping purposes only. Source: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. QCA assessment The higher proportion of switching customers generally appear to be in postcodes in the west of SEQ, away from the coastline. We note that it is difficult to draw conclusions based on locational data over a one-year period. A higher or lower rate does not necessarily indicate a propensity for switching in a particular area overall. For example, low switching regions may have a higher proportion of customers who switched to market contracts in previous years. Of the switching customers in SEQ, 99 per cent were reported by Origin Energy and AGL (68 and 31 per cent respectively). Other retailers report insignificant numbers of switching customers due to their relatively lower number of customers on standing offers. It appears that central Brisbane and more populated areas of the Gold Coast and Sunshine Coast had a lower proportion of switching customers. This may be due to customers in these areas having already switched to, and remaining on, market offers since deregulation, or retailers focussing their marketing efforts more in the western areas during 2016–17.

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6.6.2 Customer electricity consumption The graph below shows the number of residential customers, by consumption band, who switched from standing to market offers in 2016–17. Figure 32 Residential switching customers' consumption, 2016–17

Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). The graph below shows the number of small business flat rate customers, by consumption band, who switched from standing to market offers in 2016–17. Figure 33 Small business flat rate switching customers' consumption, 2016–17

Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). The graph below shows the number of small business time-of-use customers, by consumption band, who switched from standing to market offers in 2016–17.

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Figure 34 Small business time-of-use switching customers' consumption, 2016–17

Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). QCA assessment The consumption distribution of switching residential customers indicates a broad range of usage among those customers. Of most interest is the number of switching customers who consumed 9,000 or more kWh, representing 23 per cent of the total switching residential customers. Based on Energex consumption information from 2013–14, around 9 per cent of customers use more than 9,000 kWh per year. The median usage for residential customers in SEQ in 2015–16 ranged from 4,000 kWh (flat rate only customers) to 6,000 kWh (residential flat rate with controlled load super economy customers).185 This indicates that residential customers with extremely high usage compared to the typical usage level more actively switched from standing offers to market offers in 2016–17. Similar to residential customers, while small business customers across all consumption levels switched to market offers in 2016–17, a relatively large proportion of high usage customers (20 per cent and 25 per cent respectively for flat rate and time-of-use) switched to market offers. In making these observations, it should be noted that the methodology of annualising and reallocating the consumption to an annual consumption band may impact the accuracy of the consumption data; however, it is not considered that it would materially change this outcome. It is not unexpected that high consumption small business and residential customers were more likely to have switched in 2016–17 as it is these customers who would have saved the most by being on market offers (the bulk of which have discounts applied only to usage) compared to a standing offer. However, customers across a broad range of consumption levels switched during the year, indicating that savings were being made regardless of usage levels.

185 Energex consumption data (unpublished). See Chapter 2, section 2.3.1 for more detail.

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6.6.3 Customer participation in a retailer hardship program and/or receiving an electricity rebate We note that AGL stated that it was unable to provide the customer numbers in these categories at the time of switching, so has provided the numbers based on whether the switching customer was in one of these categories at any point during 2016–17.186 Therefore, the numbers may be slightly over- or under-stated based on the precise data definition. The table below outlines the number of switching customers who were in a hardship program, received the electricity rebate, or both, and the proportion each contributes to the total number of residential switching customers. Table 50 Switching customers in a hardship program and/or receiving the electricity rebate

Customers in a hardship Customers receiving the Customers in a hardship program electricity rebate program and receiving the electricity rebate

Number 1,233 9,959 734

Proportion of total 4.9% 39.3% 2.9% switching customers (%)

Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). In line with switching overall, these numbers are driven by Origin Energy and AGL who account for 99.7 per cent of the above customer numbers.

QCA assessment The number of switching customers participating in a hardship program or receiving the electricity rebate, or both, represented almost half of the residential switching customers reported by retailers. At 4.9 per cent, the proportion of switching hardship customers significantly outweighed the total proportion of hardship customers in Queensland of 0.97%, reported by the AER as at 30 June 2016.187 Further, the proportion of switching electricity rebate customers in SEQ (39.3 per cent) was considerably higher than the total proportion of customers receiving the electricity rebate in Queensland of 26 per cent.188

6.6.4 Customers with an electricity debt Few retailers reported any switching customers having a debt for 90 days or more at the time of switching. We note that AGL was unable to provide data based on the debt at the time of switching, resulting in its numbers being based on customers who switched in 2016–17 and had an outstanding debt of 90 days as of the end of August 2017. The table below shows the number of customers with an outstanding electricity debt.

186 AGL 2017, response to part 2 of the QCA's information notice (unpublished). 187 AER 2016, section 2.5.1 (Table 2.6). 188 AER 2016, section 2.7 (Table 2.16).

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Table 51 Residential customers with an outstanding electricity debt

Retailer Number of customers who had an electricity debt outstanding for 90 or more (calendar) days

AGL 214

Click Energy 0

Diamond Energy 0

Dodo Power & Gas 1

EnergyAustralia Did not provide data

Energy Locals 0

ERM Power 0

Lumo Energy 0

Mojo Power 0

Momentum Energy 0

Next Business Energy 0

Origin Energy 1,758

People Energy 0

Powerdirect 0

Powershop 0

QEnergy 0

Red Energy 0

Sanctuary Energy 0

Simply Energy 0

Total 1,973

Note: AGL's numbers based on customers who switched in 2016–17 and had an outstanding debt of 90 days as of the end of August 2017. All other retailers who provided data provided it on the 'at the time of switching' basis. Source: Retailers' responses to part 2 of the QCA's information notice (unpublished). The switching customers with a debt comprised approximately 7.2 per cent of the total switching customers.

QCA assessment In isolation it is difficult to interpret this measure; however, the size of the proportion indicates that customers with electricity debt may have taken steps to attempt to limit the growth of that debt by taking up market offers and achieving savings on their bills.

6.7 Conclusion The key points of our comparison and assessment of switching customers for 2016–17 are summarised below.

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Comparison and assessment (1) The proportion of switching customers in 2016–17 were dispersed mainly across the west of the SEQ region. This may be due to the customers in other areas of SEQ having already switched to and remaining on market offers since deregulation, or retailers focussing their marketing efforts more in the western areas during 2016–17. (2) High consumption residential and small business customers were more likely to have switched in 2016–17. However, customers across all consumption levels have switched, indicating that savings can be made regardless of consumption levels. (3) The number of switching customers participating in a hardship program or receiving the electricity rebate, or both, represented almost half of the residential switching customers reported by retailers. (4) Customers with electricity debt may have taken steps to attempt to limit the growth of that debt by taking up market offers and achieving savings on their bills.

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7 HARDSHIP AND REBATE CUSTOMERS

This chapter compares and assesses customers participating in a retailer hardship program or receiving the electricity rebate in 2016–17.

7.1 Background As stated in Chapter 6, standing offers are basic contracts with regulated terms and conditions which generally provide a greater range of protections for customers compared to market offers.189 Standing offers may be suited to customers experiencing financial hardship or customers receiving concessions. However, where customers meet certain conditions, such as paying their bills on time, prices under market offers can result in lower customer bills. Due to the differences in prices, terms, and conditions—between the multitude of market offers being offered by retailers, and standing offers—it is not clear which type of contract is best suited to customers experiencing financial hardship or being on a concession. That is, contract suitability will likely depend on the customer's individual circumstances.

7.2 Minister's direction Section 2(g) of the Direction requires the market monitoring report to include a comparison and assessment of customers that were participating in a retailer hardship program or receiving an energy concession in 2016–17. The comparison and assessment is to cover (i) the number of customers on standing and market offers, and (ii) the standing and market offer prices they paid.

7.3 QCA methodology We interpret 'energy concession' in section 2(g) of the Direction to have the same meaning as it does in section 2(f)(iii) of the Direction; that is, customers receiving an energy concession are those receiving the electricity rebate.

7.3.1 Number of customers on standing offers and market offers Section 2(g)(i) of the Direction requires the QCA to report on the number of customers on standing and market offers that were participating in a retailer hardship program or receiving an energy concession in 2016–17. In the scoping paper, we indicated that we would report on of the number of residential customers participating in a hardship program, as well as the number of customers receiving the electricity rebate, and those participating in both programs on standing offers and market offers during 2016–17. We also indicated that this data would be obtained directly from retailers.190

189 See also Chapter 2, section 2.1.1 for detail. 190 See QCA 2016a, section 4.3.1 (Table 9).

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7.3.2 Standing offer prices and market offer prices customers paid Section 2(g)(ii) of the Direction requires the QCA to report on the standing and market offer prices paid by customers who participated in a retailer hardship program or received an energy concession in 2016–17. In order to fulfil this requirement of the Direction, we indicated in the scoping paper that we would have to obtain data from retailers on the standing and market offer prices hardship and rebate customers paid them in 2016–17. We also noted that presentation of the prices hardship and rebate customers paid was potentially problematic for a number of reasons:  Retailers may have hardship and rebate customers on a range of different contracts, with some retailers offering more than one standing offer.  Some customers will have multiple tariffs.  Customers on some market offers will effectively pay a different price depending on whether or not they fulfil certain conditions, such as paying their bill on time; therefore, the price they effectively pay may vary from bill to bill.  Prices under market offers may vary during 2016–17, so there may not be a single price for each hardship and/or rebate customer for the entire reporting period.  Presenting prices will not provide information on how many customers are on each price.191 In the interests of comparability with typical SEQ customers, we said it would be useful to present prices for hardship and rebate customers as an annual bill based on median consumption levels. We added that we would compare these outcomes with outcomes for typical SEQ customers, in any or all of text, table or graphical forms, to best describe the results of the comparison.192 The scoping paper also said that retailers should be able to provide standing and market offer prices, and the number of customers who are participating in their hardship program or are receiving the electricity rebate, on each offer. So that we could present prices as an annual bill for 'typical' hardship and concession customers, we said we would also request, for these customers, the proportion of bills that received conditional discounts and the total discount value. Any conditional discounts would be applied in line with these proportions. We also provided a sample chart showing the number of customers on a hardship program and their annual bill size (in bands).193

7.4 QCA data requirements To enable us to make our assessment, we stated in the scoping paper:  We would need anonymised quarterly billing data from retailers showing complete information on each of their customers who are participating in a hardship program and/or receiving the electricity rebate. This would include information on customers supplied for part of each quarter.  Data would be requested in electronic format through a formal information notice under section 89C of the Electricity Act.

191 QCA 2016a, section 4.3.2. 192 QCA 2016a, section 4.3.2. 193 See QCA 2016a, section 4.3.2 (Figure 6).

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7.5 Submissions 7.5.1 Methodology and data collection for hardship / rebate customers Submissions AGL and EnergyAustralia submitted that providing the QCA with anonymised billing data was unnecessary to meet the requirements of section 2(g)(ii) of the Direction, and would represent a material compliance burden on retailers.194 AGL indicated that, to comply with the QCA's proposed data request, it would need to provide the QCA with quarterly retail bills for 110,000 customers for 2016–17.195 EnergyAustralia suggested that providing the number of customers on hardship programs, and the price plan they are on, would be sufficient for reporting purposes.196

QCA position We revised our approach to assessing the standing and market offer prices paid by hardship and concession customers. Retailers were required to provide 2016–17 offer data for the consumption and daily charge, discounted charges and the proportion of customers receiving conditional discounts, from which the equivalent annual bills were calculated for hardship and concession customers using typical consumption levels. We required the following data (for 2016–17) from electricity retailers operating in SEQ to enable the QCA to make its assessment. Table 52 Hardship and concession customer data request, 2016–17 (flat rate residential tariff)

Customers in a Customers Customers in a hardship program receiving the hardship program only electricity rebate and receiving the only electricity rebate

Standing offer 1 (Offer ID #)

Number of customers X X X

Proportion (%) of customer bills receiving X X X discounts

Total value of discounts across all X X X customers ($)

Daily charge (c/day) X X X

Consumption charge (c/kWh) X X X

Controlled load charge(s) (c/kWh) X X X

Market offer 1 (Offer ID #)

Number of customers X X X

Proportion (%) of customer bills receiving X X X all conditional discounts

194 AGL 2016, page 2; EnergyAustralia 2016, page 1. 195 AGL 2016, page 2. 196 EnergyAustralia 2016, page 1.

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Customers in a Customers Customers in a hardship program receiving the hardship program only electricity rebate and receiving the only electricity rebate

Total value of conditional discounts across X X X all customers ($)

Undiscounted charges (includes guaranteed discounts)

Daily charge (c/day) X X X

Consumption charge (c/kWh) X X X

Controlled load charge(s) (c/kWh) X X X

Discounted charges (includes conditional discounts)

Daily charge (c/day) X X X

Consumption charge (c/kWh) X X X

Controlled load charge(s) (c/kWh) X X X

Notes: This table is for illustrative purpose only. This analysis assumes that prices under market offers remain unchanged in 2016–17. Retailers were required to provide pricing information for each of their standing and market offers, with hardship and concession customers on them, for the most common residential tariffs in 2016–17. The only retailer in the first two quarters of 2016–17 to offer discounts (showing on Energy Made Easy) on standing offers was Diamond Energy, who offered pay on time and direct debit discounts on flat rate and time-of-use offers. The daily charge, consumption charge, and controlled load charge rows were repeated for the discounted charges subsection for the market offer in case these charges differed when conditional discounts were applied. All charges, and the value of discounts were to be reported exclusive of GST. The total value of discounts figure was included to allow the QCA to provide general commentary on the level of discounts provided to hardship and rebate customers in the market monitoring report. Some customers may have been in more than one hardship and/or rebate category during 2016–17, or may not have been in a particular category for the whole year. The revised approach meant that the QCA did not require anonymised quarterly billing data from retailers showing complete information on each of their customers who are participating in a hardship program and/or receiving the electricity rebate. Information on customers supplied for part of 2016–17 was still included in the QCA information notice.

7.6 QCA monitoring We note the following with respect to retailer responses to the hardship and rebate customers section of the information notice:  Momentum Energy, Next Business Energy and Powershop did not have any hardship or electricity rebate customers.197  EnergyAustralia did not provide a response to this section of the QCA's information notice.198  Simply Energy provided a significantly late response to this section of the QCA's information notice, which was unable to be included in the report due to time constraints.

197 Momentum Energy 2017, Next Business Energy 2017 and Powershop 2017, responses to part 2 of the QCA's information notice (unpublished). 198 EnergyAustralia provided a response in (early) September but later withdrew it.

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 AGL and Powerdirect submitted a combined response and we report this data in the name of AGL.199

7.6.1 Number of hardship and rebate customers on standing offers and market offers The table below summarises the number of hardship, electricity rebate and both hardship and electricity rebate customers on standing offers and market offers. Table 53 Customers in hardship programs and receiving the electricity rebate

Number of customers Number of customers Proportion of on standing offers on market offers customers on market offers (%)

Customers in a hardship program 548 6,431 92% only

Customers receiving the 101,218 376,888 79% electricity rebate only

Customers in a hardship program 590 10,902 95% and receiving the electricity rebate

Notes: Click Energy did not state whether its offers were market or standing offers. Cross-checking with information from Energy Made Easy, we allocated the offer "Tariff 11 Standing" to standing offers and all others to market offers. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished). The majority of hardship and electricity rebate customers were on market offers in 2016–17. The proportion of hardship and rebate customers on market offers for each of the three categories of these customers is higher than the proportion of customers on market offers in whole SEQ market (70 per cent).200

QCA assessment The high proportion of hardship and rebate customers on market offers may reflect:  efforts made by retailers to assist hardship customers, which may include helping them identify the best prices for their circumstances, and/or  customers in these categories being strongly engaged in the electricity market in 2016–17.

7.6.2 Standing offer prices and market offer prices customers paid The table below summarises the weighted average annual bills for each category of customers based on the corresponding typical consumption level. It has been calculated by multiplying the typical bill calculation for each offer by the number of customers on each offer by category (hardship, electricity rebate and both), then dividing the total sum of the bill amounts by the number of customers in each category. Note that all bill calculations for electricity rebate customers do not include the rebate, to allow comparisons to be made with the actual underlying prices being paid.

199 AGL 2017, response to part 2 of the QCA's information notice (unpublished). 200 AER 2017b, section 4.8.1.

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Table 54 Weighted average annual bill by residential tariff / tariff combination and offer type, 2016–17

Standing Market offer Difference Market offer Difference offer ($) incl. ($) incl. ($) (A) guaranteed (A) – (B) guaranteed and (A) – (C) discounts ($) conditional (B) discounts ($) (C)

Hardship customers

Flat rate 1,504 1,459 45 1,417 87

Flat rate with controlled load super 1,907 1,800 107 1,727 180 economy

Flat rate with controlled load 1,804 1,760 44 1,693 111 economy

Electricity rebate customers

Flat rate 1,490 1,459 30 1,395 95

Flat rate with controlled load super 1,883 1,782 101 1,707 176 economy

Flat rate with controlled load 1,791 1,756 35 1,676 116 economy

Hardship and rebate customers

Flat rate 1,489 1,428 62 1,401 89

Flat rate with controlled load super 1,916 1,748 168 1,716 199 economy

Flat rate with controlled load 1,789 1,714 75 1,679 110 economy

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. Consistent with the standing offer and market offer comparisons based on typical customers in Chapter 2, hardship and electricity rebate customers on market offers were paying less than those on standing offers. To compare annual bills for hardship and rebate customers with offers generally available in the rest of the SEQ market at a more granular level, the next sections report residential bill outcomes by retailer, as well as by aggregating bills into bands as indicated in the scoping paper.201

201 QCA 2016a, section 4.3.2, or section 7.3.2 in this report.

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Residential flat rate offers The table and graph below summarise the weighted average bills (GST inclusive) of a customer with typical usage on a residential flat rate tariff, across all three categories of hardship, electricity rebate and both hardship and electricity rebate customers, by retailer. Table 55 Weighted average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate offers)

Retailer Weighted average Weighted average Weighted average Proportion of standing offer bill market offer bill – market offer bill – customers ($) guaranteed including all receiving all discounts only ($) guaranteed and guaranteed and conditional conditional discounts ($) discounts (%)

AGL 1,486 1,447 1,386 85

Click Energy 1,556 1,663 1,673 76

Diamond Energy 1,429 n/a n/a n/a

Dodo Power & Gas n/a 1,517 1,381 96

Energy Locals n/a 1,538 n/a n/a

Lumo Energy 1,509 1,485 1,359 43

Mojo Power n/a 1,184 n/a n/a

Origin Energy 1,491 1,456 1,395 24

People Energy n/a 1,452 n/a n/a

QEnergy 1,559 n/a n/a n/a

Red Energy 1,458 1,455 1,305 84

Sanctuary Energy n/a 1,446 n/a n/a

Notes: n/a—The retailer did not have hardship or electricity rebate customers on that type of offer or, in the case of the proportion of customers receiving all guaranteed and conditional discounts, on offers that included conditional discounts. Click Energy did not provide its conditionally discounted rates; therefore, the average market offer bill for Click Energy customers is not directly comparable to other retailers or its standing offer bill. Origin Energy's result does not include the Predictable Plan202 as the rates customers pay vary depending on usage over the year. Diamond Energy offers direct debit and pay on time discounts to standing offer customers, which have been incorporated into the hardship and rebate customer bill calculations based on the customer numbers provided. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. Chapter 2 presents a comparison of retailers' standing offer and market prices that were generally available in the market in 2016–17, by using each retailer's average prices to calculate bills based on the typical usage level. A comparison with the weighted averages presented above provides an indication of whether hardship and rebate customers paid similar prices to those available in the market. Note that it is not a direct comparison with the actual bills paid by customers in the wider market. Comparing specifically to the market offers for residential flat rate customers available in the June quarter (section 2.4.1) we note the following:

202 See Chapter 8, section 8.4.2 for detail of Origin Energy's Predictable Plan.

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 The average standing offer bill did not differ materially for hardship and electricity rebate customers on standing offers.  The weighted average market offer bill including all discounts for hardship and electricity rebate customers ranged from $39 lower than the market offer average (2.9 per cent, Red Energy) to $32 higher than the market offer average (2.4 per cent, Dodo Power & Gas).203 Figure 35 Weighted average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. Residential flat rate with controlled load super economy offers The table and graph below summarise the weighted average bills of a typical customer on a combined residential flat rate with controlled load super economy tariff, across all three categories of hardship, electricity rebate and both hardship and electricity rebate customers, by retailer. The methodology is the same as the methodology described in the residential flat rate section. Table 56 Weighted average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate with controlled load super economy offers)

AGL 1,827 1,764 1,701 75

Click Energy n/a 2,131 2,135 73

203 Click Energy has been excluded from this analysis due to the limitation described in the notes to Table 55.

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Diamond Energy 1,781 n/a n/a n/a

Dodo Power & Gas n/a 1,825 1,649 97

Energy Locals n/a 1,987 n/a n/a

Lumo Energy 1,684 1,795 1,655 40

Mojo Power n/a 1,488 n/a n/a

Origin Energy 1,829 1,780 1,699 19

People Energy n/a 1,738 n/a n/a

QEnergy 1,885 n/a n/a n/a

Red Energy 1,792 1,786 1,592 92

Sanctuary Energy n/a 1,731 n/a n/a

Notes: n/a—The retailer did not have hardship or electricity rebate customers on that type of offer or, in the case of the proportion of customers receiving all guaranteed and conditional discounts, on offers that included conditional discounts. Click Energy did not provide its conditionally discounted rates; therefore, the average market offer bill for Click Energy customers is not directly comparable to other retailers or its standing offer bill. Origin Energy's result does not include the Predictable Plan204 as the rates customers pay vary depending on usage over the year. Diamond Energy offers direct debit and pay on time discounts to standing offer customers, which have been incorporated into the hardship and rebate customer bill calculations based on the customer numbers provided. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. As noted in the residential flat rate section above, we have compared these averages to those presented in Chapter 2. Comparing specifically to the market offers for residential flat rate with controlled load super economy customers available in the June quarter (section 2.4.2), we note the following:  The average standing offer bill did not differ materially for hardship and electricity rebate customers on standing offers.  The weighted average market offer bill including all discounts for hardship and electricity rebate customers ranged from $90 lower than the market average (5.4 per cent, Red Energy) to $35 higher than the market average (2.1 per cent, AGL).205

204 See Chapter 8, section 8.4.2 for detail of Origin Energy's Predictable Plan. 205 Click Energy has been excluded from this analysis due to the limitation described in the notes to Table 56.

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Figure 36 Weighted average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate with controlled load super economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. Residential flat rate with controlled load economy offers The table and graph below summarise the standing offer and market offer average bills of a typical customer on a combined residential flat rate with controlled load economy tariff, across all three categories of hardship, electricity rebate and both hardship and electricity rebate customers, by retailer. The methodology is the same as the methodology described in the residential flat rate section. Table 57 Weighted average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate with controlled load economy offers)

Retailer Average standing Weighted average Weighted average Proportion of offer bill ($) market offer bill – market offer bill – customers guaranteed including all receiving all discounts only ($) guaranteed and discounts (%) conditional discounts ($)

AGL 1,783 1,725 1,663 85

Click Energy n/a 2,038 2,053 75

Diamond Energy 1,739 n/a n/a n/a

Dodo Power & Gas 1,734 1,811 1,637 95

Energy Locals n/a 1,895 n/a n/a

Lumo Energy 1,732 1,733 1,551 60

Mojo Power n/a 1,408 n/a n/a

Origin Energy 1,795 1,753 1,669 25

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People Energy n/a 1,728 n/a n/a

QEnergy 1,857 n/a n/a 0

Red Energy 1,752 1,749 1,581 89

Sanctuary Energy n/a 1,722 n/a 0

Notes: n/a —The retailer did not have hardship or electricity rebate customers on that type of offer or, in the case of the proportion of customers receiving all guaranteed and conditional discounts, on offers that included conditional discounts. Click Energy did not provide its conditionally discounted rates; therefore, the average market offer bill for Click Energy customers is not directly comparable to other retailers or its standing offer bill. Origin Energy's result does not include the Predictable Plan206 as the rates customers pay vary depending on usage over the year. Diamond Energy offers direct debit and pay on time discounts to standing offer customers, which have been incorporated into the hardship and rebate customer bill calculations based on the customer numbers provided. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. As noted in the residential flat rate section above, we have compared these averages to those presented in Chapter 2. Comparing specifically to the market offers for residential flat rate with controlled load economy customers available in the June quarter (section 2.4.3) we note the following:  The average standing offer bill did not differ materially for hardship and electricity rebate customers on standing offers.  The weighted average market offer bill including all discounts for hardship and electricity rebate customers ranged from $51 lower than the market average (3 per cent, Origin Energy) to $56 higher than the market average (3.5 per cent, AGL).207

206 See Chapter 8, section 8.4.2 for detail of Origin Energy's Predictable Plan. 207 Click Energy has been excluded from this analysis due to the limitation described in the notes to Table 57.

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Figure 37 Average annual bills for hardship and electricity rebate customers on retailers' standing and market offers, 2016–17 (residential flat rate with controlled load economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. QCA assessment Customers on hardship programs and the electricity rebate generally paid bills that were similar to the generally available offers published on Energy Made Easy, based on the standing or market offer each customer has selected with each retailer. It should be noted that this does not take account of any fees that may have been incurred for late payment, or payment processing fees.

7.6.3 Distribution of customer bills The graphs below show the distribution of customer bills based on typical usage levels for standing and market offers, by residential tariff / tariff combination, for each of the customer categories.

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Hardship customers Figure 38 Equivalent annual bills for customers on hardship programs, 2016–17 (residential flat rate offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

Figure 39 Equivalent annual bills for customers on hardship programs, 2016–17 (residential flat rate with controlled load super economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

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Figure 40 Equivalent annual bills, by tariff / tariff combination, for customers on hardship programs, 2016–17 (residential flat rate with controlled load economy offers)

900 800 700 600 500 400 300

Numbercustomers of 200 100 0

Annual bill $

Standing offer Market offer all discounts Market offer conditional discounts

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. Electricity rebate customers Figure 41 Equivalent annual bills for customers receiving the electricity rebate, 2016–17 (residential flat rate offers)

50,000 45,000 40,000 35,000 30,000 25,000 20,000 15,000

Numbercustomers of 10,000 5,000 0

Annual bill $

Standing offer Market offer all discounts Market offer conditional discounts

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

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Figure 42 Equivalent annual bills for customers receiving the electricity rebate, 2016–17 (residential flat rate with controlled load super economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

Figure 43 Equivalent annual bills for customers receiving the electricity rebate, 2016–17 (residential flat rate with controlled load economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

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Hardship and electricity rebate customers Figure 44 Equivalent annual bills for customers on hardship programs and receiving the electricity rebate, 2016–17 (residential flat rate offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

Figure 45 Equivalent annual bills for customers on hardship programs and receiving the electricity rebate, 2016–17 (residential flat rate with controlled load super economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis.

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Figure 46 Equivalent annual bills for customers on hardship programs and receiving the electricity rebate, 2016–17 (residential flat rate with controlled load economy offers)

Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); QCA analysis. QCA assessment The distribution of bills appears to demonstrate that customer bills were clustered around the averages, with only a small number of bills being significantly above or below the average. While the proportion of hardship and rebate customers on market offers was relatively high, those that remained on standing offers were paying significantly more than they could be paying, either on a standing offer with another retailer or a market offer.

7.6.4 Total value of discounts The table below summarises the total value of discounts received by hardship and electricity rebate customers in 2016–17. Table 58 Total and average discount value across hardship and electricity rebate market offer customers, 2016–17

Hardship customers ($) Electricity rebate Hardship and rebate customers ($) customers ($)

Total value of discounts 61,349 5,238,306 92,234

Total value of electricity 0 64,817,621 1,831,170 rebates

Total value of discounts 61,349 70,055,927 1,923,404 and rebates

Average discount 21.42 27.55 17.18

Average discount plus 21.42 357.55 347.18 rebate

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Notes: Value of discounts was not provided by all retailers. The average is based only on those retailers where a discount value was reported and the numbers of the hardship, rebate and both hardship and rebate customers on their corresponding market offers. Sources: Retailers' responses to part 2 of the QCA's information notice (unpublished); Queensland Government 2016 (see also the Queensland Government's Budget and Strategy Outlook 2016–17 Appendix A: Concessions statement); QCA analysis. Excluding the rebate where applicable, the table indicates a lower level of savings than indicated by the bill data for the wider market. Reasons for this may be that these categories of customers have lower usage than the typical customer, hardship customers being less likely to receive conditional discounts, or that savings are higher in the omitted retailers.

QCA assessment The data presented above indicates that hardship and electricity rebate customers generally took advantage of market offers and received discounts which were available in the wider market. However, based on the typical consumption used to calculate annual bills, it appears that there are some may have been able to achieve a lower bill, based on the offers available.

7.7 Conclusion The key points of our comparison and assessment of hardship and concession customers for 2016–17 are summarised below.

Comparison and assessment (1) A high proportion of hardship and electricity rebate customers were on market contracts. (2) On average, customers on hardship programs and the electricity rebate generally paid bills that were similar to the rest of the market, based on the standing or market offer each customer has selected with each retailer. (3) While many typical hardship and electricity rebate customers paid annual bills within a similar range to other typical customers, there were offers available that could have resulted in these customers paying lower bills.

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8 NEW RETAIL TARIFF STRUCTURES AND PLANS

This chapter comments on types of retail tariff structures and retail electricity plans in 2016–17.

8.1 Background Before retail prices were deregulated in SEQ's electricity market, the QPC's electricity pricing inquiry found that, while the benefits of increased competition in the SEQ retail electricity market are likely to be realised gradually, deregulation was expected to drive retailers to offer more innovative and tailored products and services that match customers' needs and preferences.208 In particular, the QPC noted:  Price deregulation could increase options and choices for customers in the longer term; this may include better electricity plans, reliability and service.  Price deregulation could give businesses more flexibility to formulate their own strategies and processes, without government interference or regulatory restrictions.  Competitive pressure should result in prices that trend to the efficient cost of supplying the service.  Research by the International Energy Agency suggested that removing price regulation resulted in greater product differentiation and innovation, reflecting new entry and resulting in more tailored choices for customers.  Retailers in deregulated jurisdictions are diversifying their product offerings and are increasingly competing through innovative services such as energy audits and appliance swaps, advice about energy efficiency initiatives, energy cap plans, providing better information about energy usage profiles, and providing 'free' electricity or gas on certain days of the week.209 When the Minister publicly announced, on 1 July 2016, that SEQ's retail electricity market would be deregulated, he stated that "electricity customers will soon have access to a wider range of innovative electricity products and deals". The Minister also said that households would be "able to access products and packages which are more tailored to meet their individual needs and the way they use and consume energy".210 The Grattan Institute reported in March 2017 that since market deregulation there has been no widespread take-up of innovative tariffs across NEM jurisdictions, including Queensland, nor was it clear that services had improved dramatically. The institute added that there was "not much scope for innovation in retail electricity provision" as the good cannot change; what can change is how it is priced and the level of service received by the customer.211 In its May 2017 report on the state of the NEM, the AER commented that despite the range of offers in the market, most offers retain a similar two-part price structure of a daily supply charge plus a consumption-based usage charge.212 Similarly, in its 2017 retail energy

208 QPC 2016b, chapter 8 findings. 209 QPC 2016a, section 8.3.2; QPC 2016b, section 8.3.2. 210 Bailey 2016b. 211 Grattan Institute 2017, section 3.0. 212 AER 2017b, section 4.8.4.

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competition review report, the AEMC said that "[d]espite some new pricing plans, there is still limited innovation in the retail tariff structures on offer" in the NEM.213 The ACCC's retail electricity pricing inquiry preliminary report of September 2017 noted that "there has been little in the way of innovation in underlying price structures" across electricity offers, and that "[o]ne reason for this could be the underlying network tariff structures".214

8.2 Minister's Direction Section 3 of the Direction requires the market monitoring report to include comment on whether new types of retail tariff structures and retail electricity plans have emerged since deregulation on 1 July 2016.

8.3 QCA methodology We collected and analysed retail tariff structure and electricity plan data from Energy Made Easy to report on the emergence of new tariff structures and plans. In terms of information available on Energy Made Easy, we noted in the scoping paper215:  Retailers are responsible for the accuracy of data and information they provide to the website.216  We were not aware of any independent quality assurance of data provided by retailers to Energy Made Easy. Therefore, we suggested that we would invite retailers, through the information notice process, to provide specific information on any new tariff structures and retail electricity plans to us for potential inclusion in the market monitoring report.217 We invited retailers to provide the information in their responses to the switching, hardship and rebate customers part of the QCA's information notice.218

8.4 QCA monitoring Retailers did not provide any information in their responses to the switching, hardship and rebate customers part of the QCA's information notice which we include in this report. Using Energy Made Easy and retailers' websites, we identified a small number of new tariff structures and plans emerging in SEQ in 2016–17. These are summarised in the table below.

213 AEMC 2017d, section 4.2.2. 214 ACCC 2017, section 4.2. 215 QCA 2016a, section 5.3. 216 AER 2015a, page 20. 217 QCA 2016a, section 5.3. 218 See Chapter 10 for more information on the QCA's information notice.

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Table 59 New retail tariff structures and plans, 2016–17

Retailer Plan name/type Tariff structure

Mojo Power Subscription based plans Subscription fee plus fixed daily and variable usage charges

Origin Energy Predictable Plan Annual fixed price based on forecast usage. Price is reviewed annually based on billed usage.

Powershop Powerpacks Two-part tariffs; customers can select from a range of discounts on the usage charge depending on their circumstances.

Sources: Energy Made Easy; Mojo Power website, https://www.mojopower.com.au/energypass-benefits/; Origin Energy website, Predictable Plan page, https://www.originenergy.com.au/for-home/campaign/origin- predictable-plan.html; Powershop website, Powerpacks page, http://www.powershop.com.au/toolkit/. More detail on the new retail electricity tariff structures and plans is below.

8.4.1 Mojo Power—Subscription plans Mojo Power introduced 'EnergyPass' market offers which, in exchange for paying a subscription fee, allowed residential customers to access the retailer's wholesale rates.219 In each of the four quarters of 2016–17, Mojo Power's offers published on Energy Made Easy included annual subscription prices of $280 (GST inclusive) for the annual Basic EnergyPass options, and $420 (GST inclusive) for the monthly Basic EnergyPass option. Mojo Power's website said that EnergyPass payments were payable in advance and are non-refundable.220 The fixed charge for Mojo Power's subscription-based offers was cheaper than the retailer's standing offers, and the variable charges were also cheaper than the standing offers across flat rate and controlled load offers.221 However, the standing offers did not include the subscription charge which, if added to the fixed charge, makes the overall fixed charges of the offers more comparable. The table below illustrates the differences between fixed and variable charges of Mojo Power's standing and market flat rate offers for the June quarter of 2016–17. Table 60 Mojo Power residential market and standing offer examples, 30 June 2017

Offer name Offer Offer ID Subscription Fixed Variable type charge ($) charge charge (cents/day) (cents/kWh)

Energy With Benefits Market MOJ332608MR $280 / year 59.14 22.37 (Annual EnergyPass) (69.69 (128.83)^ cents/day)*

Energy With Benefits Market MOJ332605MR $35 / month 0.5914 22.37 (Monthly EnergyPass) (104.54 (163.68)^ cents/day)*

Energy Without Benefits Standing MOJ223145SR — 159.14 28.34

Notes: * Subscription charge converted into an equivalent GST excl. fixed daily charge. ^ Fixed charge including the (converted) subscription charge. The AER requires fixed and variable charges on Energy Made Easy to be GST excl.; Mojo Power's subscription charges are GST incl. In April 2017, Mojo Power published new market offers on Energy Made Easy, with the variable charge increasing from 20.24 cents per kWh to 22.37 cents per kWh. Source: Energy Made Easy.

219 Mojo Power website, https://www.mojopower.com.au/energypass-benefits/. 220 Mojo Power website, https://www.mojopower.com.au/energypass-benefits/. 221 QCA analysis of published Mojo Power offers on Energy Made Easy, quarters 1 and 2.

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As shown in Chapter 2, Mojo Power's standing offer bills for a typical customer were above other retailers' standing offer bills in 2016–17. By contrast, Mojo Power's average market offer was more competitive compared to the average market offer (excluding Mojo Power) at higher than typical consumption levels.222 This supports Mojo Power's argument in its submission on the scoping paper that its market offers are generally more compelling for higher energy users.223

8.4.2 Origin Energy—Predictable Plan Origin Energy's Predictable Plan is a fixed price energy plan that is based on:  a forecast of energy usage over a 12 month period  information about the cost of energy for the 12 month period. Origin Energy offers customers who change or renew their plan a new price based on updated billed usage. This provides an incentive to customers to use energy efficiently as the price offered by Origin Energy for a new plan may increase if billed usage is greater than forecast. If a customer uses more energy than was estimated when the fixed price was calculated, Origin Energy will not increase its charge, unless the usage is excessive or unreasonable. If a customer uses less electricity (or natural gas) than predicted, the charge will be the same, but the new fixed price will be based on the lower usage if the customer takes up a new Predictable Plan.224

8.4.3 Powershop—Powerpacks Powershop offers a range of plans—described as 'Powerpacks'—to suit different types of customers and their energy usage. According to Powershop's website:225  The retailer did not have electricity 'plans', but packaged its electricity for sale through the Powerpacks.  Customers could use the Power Organiser online to show how long their Powerpack purchases were expected to last, based on recent usage.  Four Powerpacks were available to customers— top-up packs, online saver packs, spot specials and future packs. These are described below, based on information from Powershop's website.

Top-up pack These products represent a customer's guaranteed discount which Powershop will automatically purchase as a customer's default Powerpack at account review time, if the customer has not signed in and has purchased a different pack.

Online saver pack The online saver provides a customer with the best possible discount that is available every day.

222 Stakeholders can calculate annual bills using the dataset published on the QCA website, as per the instructions in Appendix E (Calculating annual bills using our published dataset subsection). 223 Mojo Power 2016, page 2. 224 Origin Energy website, Predictable Plan Frequently Asked Questions page, https://www.originenergy.com.au/for-home/electricity-and-gas/plans/predictable-plan/faq.html. 225 Powershop website, Questions Answered page, http://www.powershop.com.au/questions-answered/.

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Spot specials These are released every week or so and provide a larger discount than the online saver, but are only available for a limited amount of time. When these are available, customers will be notified through Facebook, Twitter, and via a push notification on their phone from the Powershop app.

Future pack Future packs secure a discount for a period in the future, so a customer can stock up for the months ahead.

8.5 QCA commentary The box below summarises the QCA's commentary on whether new types of retail tariff structures and retail electricity plans have emerged since deregulation on 1 July 2016.

Comment (1) Some new types of retail tariff structures and electricity plans emerged in 2016–17.

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9 STANDING OFFERS FEE TYPES RESTRICTION

This chapter reports on significant issues that emerged in SEQ regarding the restriction on the types of fees that retailers could charge standing offer customers in 2016–17.

9.1 Background The National Energy Customer Framework (NECF) is a set of national laws, rules and regulations governing the sale and supply of electricity and gas to consumers. It was developed via cooperative arrangements between Australia's federal, state and territory governments and aims to reduce regulatory 'red tape' for the electricity industry, drive greater efficiencies and foster increased competition in the retail market.226 Participants to the NECF apply the framework as a law of their jurisdiction. The NECF was introduced to Queensland on 1 July 2015 via the Queensland NERL Act.227 When Queensland adopted the NECF, it did so with a number of Queensland-specific additions, known as 'derogations'. The QCA is responsible for one derogation in respect of price deregulation—the restriction on the types of fees that can be included in standing offers for the first two years after deregulation.

Standing offer prices for retailers The Queensland NERL Act amends the National Energy Retail Law to include an additional Queensland-specific provision (section 22A) about standing offer prices for particular electricity retailers.228 Subsections (1) and (2) of section 22A provide that, if notified prices apply under section 90(4) of the Electricity Act, the retailer's standing offer prices for customer retail services must be the notified prices. Accordingly, prior to price deregulation on 1 July 2016, the standing offer price for customer retail services in SEQ was the notified price.229 Subsections (3) and (4) of section 22A provide for transitional arrangements to support price deregulation and the adoption of market monitoring in SEQ. These subsections ensure that no new types of fees and charges are applied to their accounts of those customers in SEQ on standing offers for the first two years after price regulation was removed.230 As of 1 July 2016, notified prices no longer applied in SEQ.231 As a result, retailers have been restricted, under section 22A of the National Energy Retail Law, to charge the following three types of fees to standing offer customers in 2016–17:

226 AEMC, Guide to application of the NECF, http://www.aemc.gov.au/Energy-Rules/Retail-energy-rules/Guide- to-application-of-the-NECF. 227 DEWS, website, https://www.dews.qld.gov.au/electricity/regulation/initiatives/necf; Queensland NERL Act, section 4(a); AEMC, Guide to the application of the NECF, http://www.aemc.gov.au/Energy-Rules/Retail- energy-rules/Guide-to-application-of-the-NECF. 228 National Energy Retail Law, section 22A, as per section 15 of the schedule to the Queensland NERL Act. 229 National Energy Retail Law, section 22A(1)–(2), as per section 15 of the schedule to the Queensland NERL Act; Queensland NERL Bill explanatory notes, pages 30–31. 230 National Energy Retail Law, section 22A(3)–(4), as per section 15 of the schedule to the Queensland NERL Act; Queensland NERL Bill explanatory notes, page 31. 231 ECPLA Act, part 2.

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 a fee to provide, upon a customer's request, historical billing data which is more than two years old  a retailer administration fee for a dishonoured payment  a financial institution fee for a dishonoured payment.232 Further, as noted in Chapter 2, retailers were not allowed to vary their standing offer prices in 2016–17, unless the variation was to reduce the price.233

9.2 Minister's Direction Section 4 of the Direction requires the market monitoring report to include comment on any significant issues that emerged in 2016–17 as a result of the derogation in section 22A of the National Energy Retail Law.

9.3 QCA methodology In our scoping paper, we indicated that we would report contraventions by identifying the potential financial impact on customers of non-compliant standing offers.234 We used findings from our compliance program235 to identify significant issues that emerged in relation to the fee types restriction. Specifically, we used Energy Made Easy to review the fee types included in retailers' standing offers, and identify retailers with standing offers that appeared to be in breach of section 22A. Throughout 2016–17, we also reviewed monthly systemic complaint data from the Energy and Water Ombudsman Queensland236, and from issues raised directly by customers, for the purpose of monitoring compliance with the fee types restriction. However, we did not find any significant issues via these processes.

9.4 QCA monitoring The results of the QCA's reviews of retailers' compliance with the fee types restriction are set out below.

9.4.1 Retailers' initial published fees In our review of retailers' initial 2016–17 standing offers, we found:  Many retailers' standing offers included a payment processing fee; that is, a fee as a percentage of the purchase price if the customer pays by either credit card, direct debit or cheque.

232 Queensland Government Gazette 2015, page 190. The maximum values of the fees that applied in 2015–16 were $30 for historical billing data, $15 for a retailer's administration fee for a dishonoured payment, and no more than the fee incurred by the retailer for a financial institution fee for a dishonoured payment. 233 National Energy Retail Law, section 23(9), as per section 16 of the schedule to the Queensland NERL Act. The AER regulates this section of the NERL. 234 QCA 2016a, section 6.2 (Table 10). 235 Details of the QCA's approach to compliance, including its enforcement guidelines (QCA 2015a), can be accessed on the 'Code Breaches' page of the QCA's website, http://www.qca.org.au/Electricity/Reviews/Code-Breaches. 236 For information on EWOQ's approach to managing systemic issues in SEQ's retail electricity market, see EWOQ 2017, systemic issues and electricity chapters.

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 Some retailers' standing offers included a late payment fee and/or an account establishment fee.  Some retailers' standing offers included other extra fees, such as a fee for issuing a paper bill or making over-the-counter payments at Australia Post. The table below shows, for all retailers, whether a retailer included prohibited fees (by fee type) in their initial 2016–17 standing offers. Table 61 Retailers' initial standing offer fee types, August 2016 (except where noted)

Retailer Payment Late payment fee Account Other processing fee establishment fee

AGL Sales —  — —

Click Energy   — —

Diamond Energy    —

Dodo Power — — — —

EnergyAustralia  — — 

Energy Localsa   — 

ERM Power Retail  — — —

Lumo Energy — — — —

Mojo Powerb  — — —

Momentum Energy — — — —

Next Business Energyc — — — —

Origin Energy Retail — — — —

People Energya — — — —

Powerdirect  — — —

Powershopd — — — —

QEnergy   — 

Red Energya — — — —

Sanctuary Energy — — — 

Simply Energy  — — —

Urth Energy   — 

a Energy Locals', People Energy's and Red Energy's standing offers were published on Energy Made Easy in December 2016. b Mojo Power's standing offers were published on Energy Made Easy in September 2016. c Next Business Energy's initial offers are those it published on Energy Made Easy in September 2016, before it had any residential or small business customers in SEQ. d Powershop's standing offers were published on Energy Made Easy in January 2017. Note: A tick () indicates the retailer included the fee type on at least one standing offer. A dash (—) indicates the retailer did not include the fee type on any standing offer. Source: Energy Made Easy. 9.4.2 QCA compliance enforcement The QCA's enforcement guidelines set out the four formal enforcement actions the QCA may take to address a breach of the fee types restriction:

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 Accept a voluntary undertaking from the retailer to rectify any contravention and to prevent it from reoccurring.  Pursue a court enforceable undertaking.  Pursue civil proceedings.  Seek revocation of a retailer's authorisation.237 As section 22A of the National Energy Retail Law is not a civil penalty provision, the QCA could not issue an infringement notice to any retailer(s), giving the retailer(s) the option of paying the infringement penalty and obtaining immunity from action by the QCA regarding the alleged breach.238 It is important to note that the results of the QCA's initial research shown in the above table were not conclusive. That is, the QCA could not conclude definitively that any retailers were actually charging prohibited fee types to their standing offer customers. The research showed only that some prohibited fee types were included on some or all standing offers of 12 retailers. For this reason, the QCA's first step in enforcing compliance with the fee types restriction was to write to retailers, in the first quarter of 2016–17, to indicate that the QCA had identified a number of potential breaches of the restriction, and request retailers review their compliance with the restriction and advise the QCA of any actions they would take. The QCA similarly wrote to retailers in January 2017 who entered the SEQ market in November and December 2016.

9.4.3 QCA's and retailers' actions The QCA wrote to all 12 retailers whose initial standing offers included prohibited fee types. Of the 12 retailers, three reimbursed customers to whom they charged prohibited fee types and nine did not actually charge these fees. The QCA did not pursue enforcement action against any retailer for non-compliance with the fee types restriction in 2016–17.

9.5 Retailers' awareness of the fee types restriction The outcomes of the QCA's review of retailers' initial compliance with the fee types restriction— where 12 retailers were found to have published standing offers including prohibited fee types—suggest a lack of awareness of the fee types restriction.

9.5.1 Minister's announcement When the Minister publicly announced, on 1 July 2016, that SEQ's retail electricity market would be deregulated, he stated that "mechanisms have also been put in place to ensure particularly vulnerable customers are protected in the deregulated electricity market".239 These mechanisms are included in the Queensland NERL Act, and its associated Regulation, and include the fee types restriction.

237 QCA 2015, section 3.2. 238 See QCA 2015, section 3.2. 239 Bailey 2016b.

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9.5.2 AEMC's guide to the NECF The AEMC has published a guide to the application of the NECF on its website.240 The guide includes a spreadsheet setting out the state and territory modifications to each provision of the National Energy Retail Law and National Energy Retail Rules. The spreadsheet clearly shows that the Queensland NERL Act adds an additional Queensland-specific provision (section 22A) about standing offer prices for particular retailers.

9.5.3 QCA communication The QCA website has a NECF page that includes information on the derogations to the NECF that have been made by the Queensland Government.241 The NECF page contains a link to the derogations page, which in turn links to a list of derogations—including the fee types restriction—that the QCA regulates.242 Also, in July 2015, the QCA wrote to a number of electricity businesses that were operating in Queensland to advise them of the QCA's functions under the NECF. The letter contained a table showing the derogations regulated by the QCA, which includes section 22A of the NERL. The letter also emphasised that the onus was on retailers to be aware of, and fulfil, their obligations under the NECF. The QCA also wrote to retailers regarding their obligations under the NECF as they entered the SEQ market in 2016–17.

9.5.4 QCA analysis We consider that sufficient information was available for all retailers to have known about, and ensured their compliance with, the fee types restriction in 2016–17.

9.6 Significant issues We consider that the relatively widespread non-compliance by retailers in relation to the fee types restriction can be considered a significant issue, even though all of the issues were resolved at an administrative level. As noted in Chapter 4, as at 30 June 2017, all retailers had complying offers published on Energy Made Easy for the tariffs and tariff combinations included in this report.243 The box below shows the significant issues that emerged regarding the fee types restriction in section 22A of the NERL in 2016–17.

240 AEMC, Guide to application of the NECF, http://www.aemc.gov.au/Energy-Rules/Retail-energy-rules/Guide- to-application-of-the-NECF. 241 QCA, NECF, http://www.qca.org.au/Electricity/Consumer/Derogations. 242 QCA, Derogations, http://www.qca.org.au/Electricity/Consumer/Derogations/Final- Report/Derogations#finalpos. 243 See Chapter 4, sections 4.4.1 and 4.4.2 (standing offers subsections).

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Significant issues (1) Twelve retailers published standing offers in 2016–17 which included prohibited fee types. All 12 retailers published new, complying offers following communication from the QCA. (2) Of the 12 retailers, three reimbursed customers to whom they charged prohibited fee types and nine did not actually charge these fees. (3) The QCA did not pursue enforcement action against any retailer for non-compliance with the fee types restriction in 2016–17.

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10 QCA INFORMATION NOTICE

This chapter outlines the QCA's approach to issuing information notices to retailers for the purpose of monitoring the SEQ retail electricity market in 2016–17.

10.1 Electricity Act Section 89C(1) of the Electricity Act allows the QCA to obtain information from retailers for the purpose of monitoring the SEQ retail electricity market. Section 89C(2) provides that the QCA may, by written notice given to a retailer, require the retailer to give QCA the relevant information that the QCA requires to comply with the Direction. Section 89C(3) obliges retailers to comply with a QCA information notice for market monitoring within the reasonable period stated in the notice. This obligation applies unless, in the circumstances, the retailer could not reasonably have been expected to have, or to be able to obtain, the relevant information. The maximum penalty for a retailer's non-compliance with an information notice is 100 penalty units.244 However, if the retailer is a body corporate, the court may impose a maximum fine of up to 500 penalty units.245

10.2 Contents of information notice The scoping paper stated:  The QCA would endeavour to set out data and methodology requirements that relied as much as possible on publicly available information.  Where publicly available information was not available to meet the requirements of the Direction, the QCA would seek to minimise the level of information it requested through the information notices.246 We anticipated that this approach would minimise the regulatory burden of market monitoring on all retailers. We also noted that the retailers operating in SEQ varied significantly in terms of their size; therefore, the cost of meeting information requests may affect smaller retailers relatively more than larger ones.247

10.3 Initial timeframes for information notice In the scoping paper, we considered two months to be a reasonable time for retailers to obtain and give the information to the QCA. We also held the view that the two-month timeframe should end a reasonable number of weeks after the end of the June quarter of 2016–17 to allow retailers sufficient time to finalise the 2016–17 information and data they would supply to us.248

244 The Penalties and Sentences Act, section 5, and the Penalties and Sentences Regulation, section 3, set the value of a penalty unit as $121.90 between 9 December 2016 and 30 June 2017, and as $126.15 from 1 July 2017. 245 Penalties and Sentences Act, sections 181B and 191B; Acts Interpretation Act, section 41. 246 QCA 2016a, section 7.2. 247 QCA 2016a, section 7.2. 248 QCA 2016a, section 7.3.

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Therefore, we proposed to issue written notices to retailers in mid-May 2017, requiring retailers to give information to us by mid-July 2017. We expected this would also allow us reasonable time to analyse and, where necessary, clarify data with retailers, and provide the report to the Minister by 31 October 2017.249 The scope of the information notice discussed in the scoping paper related principally to switching, hardship and concession customers elements of the Direction. The scoping paper also indicated that retailers would be invited to comment on new tariff structures and retail electricity plans through the information notice.250

10.4 Submissions 10.4.1 Consultation on switching, hardship and concession customers information notice EnergyAustralia submitted that:  the QCA should consult with retailers to confirm the details of the data request as soon as possible following consultation on the scoping paper  advanced notice of the information that will be required will assist it in preparing its data submission.251 QCA position The QCA agreed with EnergyAustralia that consultation on information notices would assist retailers to respond to notices. This was particularly the case with the switching, hardship and concession customers part of the information notice. The QCA consulted with retailers on these requirements in February and March 2017 (see section 10.6.1 below).

10.4.2 Timeframe for switching, hardship and concession customers information notice AGL and ERM Power agreed with the QCA that two months was a reasonable time for retailers to obtain and provide the information to the QCA. However, both retailers noted that most of the data is financial year data which would not actually exist until 30 June 2017.252 Further to its submission that the QCA should consult with retailers to confirm the details of the data request, EnergyAustralia submitted that the stated notice period of two months would only be sufficient if it had prior knowledge of the information that is requested.253 AGL acknowledged the QCA's time limitations under the Direction, and stated that allowing retailers until mid-August 2017 to submit the data was achievable.254 The AEC and Origin Energy considered that the mid-May to mid-July 2017 timeframe for the QCA's data requests was "challenging" (AEC) / "not achievable" (Origin Energy) as it would fall soon after the end of the financial year, which is a busy time for regulatory reporting. The organisations noted that the AER and ESC set a deadline of 31 August each year255 for data collections to allow for data to be extracted, collated, verified and approved256.

249 QCA 2016a, section 7.3. 250 QCA 2016a, sections 5.4 and 7.2. 251 EnergyAustralia 2016, page 3. 252 AGL 2016, page 2; ERM Power 2016, page 3. 253 EnergyAustralia 2016, page 3. 254 AGL 2016, page 2. 255 See AER 2011, section 2.2.2 and ESC 2016, section 1.5. 256 AEC 2016, page 1; Origin Energy 2016, page 2.

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Accordingly, the AEC suggested 31 August 2017 as a more appropriate timeframe, given other demands are placed on retailers at that time of the year.257 Origin Energy argued that:  it was not feasible or reasonable for the QCA to require information that calls for management sign-off before it can be released to a third party, within two weeks of a financial year  the closer the time period is to 1 July for retailers to provide data, the less complete the consumption data will be, given consumption data is based on meter reads and billed data which only occurs every three months in Queensland. Origin Energy advised that it will take up to the end of September to capture all consumption data up to 30 June 2017.258 EnergyAustralia requested that additional time be provided for data—for example, consumption and customer transfers—to be collated as complete data will not be available in mid-July 2017. EnergyAustralia indicated that, at a minimum, it would require until the end of July to provide this data and consider the deadline should be extended to accommodate this.259 EnergyAustralia also stated that:  network prices in Queensland change on 1 July each year and that a considerable number of retailer analytical resources are fully engaged during the lead up to this event  an additional data request during this period represents a more significant challenge than it would at other times of the year.260 EnergyAustralia acknowledged that the QCA was unable to delay collecting data as it was required to finalise its report by 31 October; however, it indicated it would appreciate efforts to minimise the administrative burden on retailers at this time.261 QCA position The Minister extended the due date for the market monitoring report from 31 October 2017 to 30 November 2017. The extension allowed the QCA to change the due date for retailers to respond to information notices on their switching, hardship and concession customers to 31 August 2017.

10.5 Energy Made Easy parts of the information notice 10.5.1 2015–16, September 2016 and December 2016 offers In March, we issued an information notice to the 19 retailers who were active in the SEQ market requiring them to clarify and confirm some of the information they provided in their published offers on Energy Made Easy. The notice related to offers published in the four quarters of 2015– 16, and the first two quarters of 2016–17. The notice was in Microsoft Excel form, and was part 1 of the QCA's information notice for 2016–17. Specifically, the notice covered information on controlled load tariffs, flat rate tariffs, metering fees, and GST on fees and solar feed-in tariffs.

257 AEC 2016, page 1. 258 Origin Energy 2016, page 2. 259 EnergyAustralia 2016, page 2. 260 EnergyAustralia 2016, page 3. 261 EnergyAustralia 2016, page 3.

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Controlled load tariffs We observed that, on Energy Made Easy, some retailers had named the controlled load tariffs on their offers as 'controlled load', 'controlled load 1' or 'controlled load 2', while other retailers referred to 'super economy' or 'economy' controlled load tariffs. There were also some retailers who named both of the controlled load tariffs on their offers as 'controlled load' without distinguishing between super economy and economy tariffs. The information notice required retailers to identify the controlled load tariffs on their offers as 'super economy' or' economy', so as to allow us to compare their offers.262

Flat rate tariffs Some retailers used flat rate tariff names, such as 'Peak' or 'Anytime' on their offers, which did not distinguish between residential and non-residential tariffs. As the Direction requires the QCA to separately identify the tariffs available to residential and small business customers, the information notice asked retailers to clarify this matter.

Metering charges In Chapter 2 we note that retailers may include metering charges in their fixed charges.263 Energy Made Easy does not, however, require retailers to specify whether a metering charge is included in their offers' fixed charge. We observed that most retailers did not specify on Energy Made Easy whether their fixed charges included metering charges, nor did they identify metering charges as a separate fee type. For completeness and consistency, the information notice required all retailers to specify whether their fixed charge included a metering service charge as a direct pass-through to customers.

GST on fees and solar feed-in tariffs Energy Made Easy provides retailers the discretion to specify if the fees and solar feed-in tariffs on their offers include or exclude GST. Although some retailers specified the GST that applied, others did not. For completeness and consistency, the information notice required retailers to specify whether a GST component was included in relevant fee types and feed-in tariffs.

10.5.2 March and June 2017 offers In mid-July, we issued part 3 of the notice, requiring the same information as part 1, but for new offers published in the March and June quarters (as at 31 March and 30 June 2017 respectively). Part 3 notices were sent to the 14 retailers who had new offers published in the SEQ market in the March and/or June quarters (as at 31 March and 30 June 2017). The notice did not require retailers to provide information on offers that were published as at 30 September and 31 December 2016 which were still available in the SEQ market.

10.5.3 Retailers' responses All 19 retailers provided responses to part 1 of the notice, of which 12 were received by the due date of 5 May 2017. All 14 retailers provided responses to part 3 of the notice, of which nine were received by the due date of 31 August 2017.

262 We also observed that the Energy Made Easy website does not allow users to identify which controlled load tariff, or tariffs, they wish to search for when they search for available offers in SEQ. 263 See section 2.3.3.

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The responses to parts 1 and 3 allowed us to clarify and correct a number of elements of retailers' offer details, thereby improving the reliability and accuracy of the data we used to compare and assess prices. In particular, retailers' identification of controlled load tariffs as 'super economy' and 'economy' assisted our classification of their offers into the correct tariff combinations. Many retailers also provided useful information on the application of GST to retail fees and solar feed-in tariffs.

10.6 Switching, hardship and rebate customers part of the information notice 10.6.1 Background In February, we issued a draft information notice to the 19 retailers who were active in the SEQ market regarding their switching, hardship and rebate customers. The draft notice was in Microsoft Excel and contained seven worksheets:  Switching (location)  Switching (consumption)  Switching (hardship and concession participation)  Switching (debt)  Hardship and rebate (residential flat rate tariff)  Hardship and rebate (residential flat rate and controlled load super economy)  Hardship and rebate (residential flat rate and controlled load economy). The draft notice informed retailers of the changes to the QCA's position on the:  definition of a customer, customer consumption and customer location, as explained in Chapter 6, and  methodology and data collection for hardship / rebate customers, as explained in Chapter 7. We requested comments from retailers by mid-March and received comments from 12 retailers. The QCA issued the notice to retailers in late May. The notice required the same information to be provided by retailers as set out in the draft notice, but additional instructions were added to answer questions raised by retailers in their feedback. As outlined in section 6.5.4, the notice also stated that switching customers who were participating in a retailer hardship program, and/or receiving the electricity rebate, should be reported on the at the time of switching basis. Further, the notice invited retailers to provide specific information on any new tariff structures and retail electricity plans to the QCA for potential inclusion in the market monitoring report. The switching, hardship and rebate customers notice was part 2 of the QCA's information notice for 2016–17.

10.6.2 Retailers' responses All retailers provided (complete or partial) responses to part 2; eight complete responses were received by the due date of 31 August 2017. In (late) September 2017, EnergyAustralia withdrew its response to part 2 of the information notice, after it identified inconsistencies in its submission which it said it could not satisfactorily

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treat.264 In October, we wrote to EnergyAustralia seeking formal advice and details of its withdrawn response; our letter also confirmed that the QCA was considering enforcement options in respect of EnergyAustralia's apparent failure to comply with the notice. EnergyAustralia responded to the QCA's letter in November; the QCA will decide whether or not to pursue a contravention by EnergyAustralia of section 89C of the Electricity Act as soon as is practicable. The responses to part 2 of the information notice were used to report on switching, hardship and rebate customers as detailed in Chapters 6 and 7.

264 EnergyAustralia 2017, response to part 2 of the QCA's information notice (unpublished).

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GLOSSARY

ACCC Australian Competition and Consumer Commission

ACL Australian Consumer Law

Acts Interpretation Act Acts Interpretation Act 1954 (Qld)

AEC Australian Energy Council

AEMC Australian Energy Market Commission

AER Australian Energy Regulator

AGL AGL Sales Pty Ltd

Amex American Express

Click Energy Click Energy Pty Ltd

Competition and Consumer Act Competition and Consumer Act 2010 (Cth)

Diamond Power Diamond Power Pty Ltd

DEWS Department of Energy and Water Supply (Queensland)

Dodo Power & Gas Dodo Power & Gas (M2 Energy Pty Ltd)

ECPLA Act Electricity Competition and Protection Legislation Amendment Act 2014 (Qld)

ECPLA Act Proclamation Electricity Competition and Protection Legislation Amendment Act 2014 (Qld) Proclamation (SL 2015 No. 32)

ECPLA Bill explanatory notes Electricity Competition and Protection Legislation Amendment Bill 2014 (Qld) explanatory notes

ECPLA (Postponement) Regulation Electricity Competition and Protection Legislation Amendment (Postponement) Regulation 2015 (Qld) (SL 2015 No. 33)

Electricity Act Electricity Act 1994 (Qld)

Electricity Industry Act (Victoria) Electricity Industry Act 2000 (Vic)

Electricity Regulation Electricity Regulation 2006 (Qld)

Electricity Regulations (SA) Electricity (General) Regulations 2012 (SA)

EnergyAustralia EnergyAustralia Pty Ltd

Energy Locals Energy Locals Pty Ltd

ERM Power ERM Power Limited

ESC Essential Services Commission (Victoria)

ESCOSA Essential Services Commission of South Australia

EWOQ Energy and Water Ombudsman Queensland excl. Exclusive

(the) government Queensland Government

GST Goods and Services Tax incl. inclusive

IPART Independent Pricing and Regulatory Tribunal (NSW)

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kWh kilowatt hours

Lumo Energy Lumo Energy (Qld) Pty Ltd

Minister Minister for Energy, Biofuels and Water Supply (Queensland)

Mojo Power Mojo Power Pty Ltd

Momentum Energy Momentum Energy Pty Ltd n/a Not Applicable

National Energy Retail Law or NERL National Energy Retail Law (schedule to the National Energy Retail Law (South Australia) Act 2011 (SA))

National Energy Retail Regulations National Energy Retail Regulations (under the National Energy Retail Law and section 12 of the National Energy Retail Law (South Australia) Act 2011 (SA))

National Energy Retail Rules or NERR National Energy Retail Rules, version 7

NECF National Energy Customer Framework

NEM National Electricity Market

Next Business Energy or NBE Next Business Energy Pty Ltd

NMI National Metering Identifier

No. Number

NSW New South Wales

Origin Energy Origin Energy Retail Pty Ltd

Penalties and Sentences Act Penalties and Sentences Act 1992 (Qld)

Penalties and Sentences Regulation Penalties and Sentences Regulation 2015 (Qld)

People Energy People Energy Pty Ltd

Powerdirect Powerdirect Pty Ltd

Powershop Powershop Pty Ltd

QCA Queensland Competition Authority

QCA Act Queensland Competition Authority Act 1997 (Qld)

QCOSS Queensland Council of Social Service

QEnergy QEnergy Limited

Qld Queensland

QPC Queensland Productivity Commission

Queensland NERL Act National Energy Retail Law (Queensland) Act 2014 (Qld)

Queensland NERL Bill explanatory National Energy Retail Law (Queensland) Bill 2014 (Qld) explanatory notes notes

Queensland NERL Regulation National Energy Retail Law (Queensland) Regulation 2014 (Qld)

Red Energy Red Energy Pty Ltd

SA South Australia

Sanctuary Energy Sanctuary Energy Pty Ltd

Simply Energy Simply Energy Pty Ltd

SL Subordinate Legislation

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Queensland Competition Authority Glossary

TOU time-of-use

Urth Energy Urth Energy Pty Ltd

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Queensland Competition Authority Appendix A: Minister's letter (July 2016)

APPENDIX A: MINISTER'S LETTER (JULY 2016)

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Queensland Competition Authority Appendix B: Minister's letter and direction notice (Feb 2017)

APPENDIX B: MINISTER'S LETTER AND DIRECTION NOTICE (FEB 2017)

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Queensland Competition Authority Appendix B: Minister's letter and direction notice (Feb 2017)

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Queensland Competition Authority Appendix B: Minister's letter and direction notice (Feb 2017)

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Queensland Competition Authority Appendix C: Submissions

APPENDIX C: SUBMISSIONS

Submissions on the scoping paper The organisations below made submissions on the scoping paper to the QCA. The text in brackets indicates how the submissions are abbreviated in the report. Organisation AGL Sales Pty Ltd (AGL 2016) Australian Energy Council (AEC 2016) EnergyAustralia (EnergyAustralia 2016) ERM Power Pty Ltd (ERM Power 2016) Mojo Power Pty Ltd (Mojo Power 2016) Origin Energy Pty Ltd (Origin Energy 2016) Queensland Consumers' Association (Queensland Consumers' Association 2016) Queensland Council of Social Service (QCOSS 2016)

All submissions are available on the QCA website.

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APPENDIX D: RESPONSES TO ADDITIONAL ISSUES RAISED IN SUBMISSIONS

In this appendix we provide responses to the issues raised in submissions on the scoping paper that are not otherwise addressed in the body of this report.

Legislative framework Submissions QCOSS submitted that the QCA's approach to monitoring SEQ's retail electricity market was too narrow. Specifically, QCOSS argued that the scoping paper did not mention or give due regard to the legislative intent of market monitoring as set out in:  the Minister's letter accompanying the Direction265  the explanatory notes to the ECPLA Bill  the draft and final reports of the QPC's electricity pricing inquiry and the government's response to the final report.266 QCOSS noted that the scoping paper said that the market monitoring report would not draw conclusions about the effectiveness of competition in the SEQ retail electricity market, and that this approach was said to be consistent with the government's policy intent outlined in the Direction and the explanatory notes to the ECPLA Bill.267 QCOSS submitted that the government's policy intent was outlined in the Minister's letter rather than in the Direction itself.268 QCOSS also suggested the market monitoring report should provide sufficient input to enable the government to achieve its objectives as set out in the explanatory notes to the ECPLA Bill.269 QCOSS quoted the explanatory notes where they stated that "[t]he establishment of an effective market monitoring and reporting framework will allow government to monitor the operation of the SEQ retail electricity market in order to ensure customers have the opportunity to benefit from increased competition".270 QCOSS argued that, to achieve the purpose of market monitoring, the QCA "must gather enough information to allow the government to ensure that customers are actually benefiting from increased competition".271 QCOSS suggested that benefits may include lower prices and increased service levels, and that benefitting from competition implied "much more than just experiencing increased competition".272

265 Note that QCOSS's submission related to the Minister's letter and Direction issued in July 2016, not the Minister's covering letter and updated Direction issued in February 2017. The Minister's July 2016 letter is at Appendix A. 266 QCOSS 2016, section 1.2. 267 QCA 2016a, section 1.1. 268 QCOSS 2016, section 1.2.1. 269 QCOSS 2016, section 1.2.2. 270 ECPLA Bill explanatory notes, page 2. 271 QCOSS 2016, section 1.2.2. 272 QCOSS 2016, section 1.2.2.

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QCOSS argued that the scoping paper did not address the expectations for market monitoring that were expressed in the QPC's electricity pricing inquiry final report.273 QCOSS considered that the "comprehensive purpose of market monitoring and reporting" was set out in the QPC's draft report.274 QCOSS identified one of the QPC's final report findings regarding deregulation in SEQ, which states that "effective market monitoring is important to the success of price deregulation in SEQ, to ensure the market is operating in a way that is consistent with effective competition and delivers real benefits to customers".275 QCOSS also referenced the QPC's recommendation 27:

The currently proposed market monitoring arrangements for price deregulation in SEQ are largely adequate. However, the Queensland Government should ensure: (a) the efficiency and effectiveness of standing offers form part of the monitoring arrangements; and (b) the impacts of deregulation on vulnerable and low income customers are monitored, particularly in relation to consumer understanding of contract terms and benefits...276 QCOSS added that the government had accepted this recommendation in full.277 Against this background, QCOSS recommended that the QCA:  in determining its approach to market monitoring, clearly set out how its approach enables the government to evaluate the impacts of price deregulation on SEQ customers, and meets the range of expectations for market monitoring that QCOSS considered to be set out in the Minister's letter, the explanatory notes to the ECPLA Bill and the QPC's final report  in its scoping and reporting, endeavour to address the broad sense of what market monitoring is intended to achieve for SEQ electricity customers, and not just undertake specific fact-finding to satisfy the exact wording of the Direction, without recourse to what QCOSS considered to be market monitoring's wider purpose.278 The Queensland Consumers' Association indicated its support for QCOSS's submission, particularly QCOSS's recommendations on the need for the market monitoring to go beyond just reporting on offers available, etcetera, and for it to provide new information about, and insights into, the outcomes actually being achieved, by various types of consumers.279 QCA position The Direction represents the government's implementation of its market monitoring policy. We do not consider the policy position articulated in the Minister's letter to differ from the explanatory notes; hence, we have not formed a view on QCOSS's position that the government's policy intent is outlined in the Minister's letter. We acknowledge the QPC's final report found that "effective market monitoring is important to the success of price deregulation in SEQ, to ensure the market is operating in a way that is consistent with effective competition and delivers real benefits to customers". However, the QPC also found that "[r]eports from the QCA, AEMC and AER should provide sufficiently independent information to allow the

273 QCOSS 2016, section 1.2.3. 274 QCOSS referenced section 8.6.1 of the QPC draft report (QPC 2016a); the reference should have been to section 8.5.1. 275 QPC 2016b, chapter 8 findings. 276 QCOSS 2016, section 1.2.3 [the QPC recommendation refers to contract terms and benefits, not terms and conditions as quoted by QCOSS]; QPC 2016b, section 8.6.3 (Recommendation 27). 277 QCOSS 2016, section 1.2.3; Queensland Government 2016, page 10. 278 QCOSS 2016, section 1.2.3 (Recommendation 1). 279 Queensland Consumers' Association 2016, page 1.

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Queensland Government to make an informed judgement regarding the effectiveness of competition in SEQ".280 QCOSS's submission does not acknowledge this QPC finding. The Minister directed the QCA to provide the government with information that will allow it to achieve its policy objectives. We expect that the market monitoring report will be one of the information sources used by the government to assess the efficacy of deregulation. We also consider that the market monitoring report will provide sufficient input to enable the government to achieve its objectives as set out in the explanatory notes to the ECPLA Bill. We are of the view that our position is consistent with the statement made by the (then) Minister for Energy and Water Supply—when introducing the ECPLA Bill in the Queensland Parliament—that the QCA's market monitoring role would "complement" the AER and AEMC market functions.281 Accordingly, we consider that we are meeting the requirements of the Direction, and reject QCOSS's argument that we are not meeting the requirements of the legislative framework for market monitoring. The Direction does not require the QCA to explain how its approach will enable the government to evaluate the impacts of price deregulation on SEQ customers. We anticipate that the government will apply its own criteria for assessing the efficacy of deregulation, and that our market monitoring report will support its decision-making process. We also note that the Electricity Act includes a provision—separate to the market monitoring provision—that allows the Minister (responsible for the Electricity Act) to direct an entity (such as the QCA) to:  conduct a review into the effectiveness of competition in SEQ  give advice about whether to reintroduce price regulation in SEQ.282 Further, we do not agree with QCOSS that our approach can accurately be described as just specific fact- finding to satisfy the exact wording of the Direction, without recourse to its wider purpose. Our role is to provide information that is requested in the Direction, which is provided in the context of the government's market monitoring framework. As stated, we consider the report will complement other reports, which, together, will inform the government on the outcomes of price deregulation in SEQ. Finally, we consider there to be merit in aligning, as far as practicable, our methodologies and approaches to retail electricity monitoring conducted by the AEMC, IPART, the ESC and ESCOSA.

Electricity supply costs Submission QCOSS noted that the scoping paper stated that the QCA would not report on costs to supply electricity in SEQ.283 QCOSS submitted that, to meet the objectives of market monitoring and to determine if consumers are benefitting from retail price deregulation, QCA consideration of the costs to supply electricity was required, as those costs would have determined the tariffs that would have applied had standing offer price regulation not been removed. QCOSS did acknowledge that the QCA would be likely anyway to analyse the costs of supply in SEQ in its work on regional retail prices that apply outside SEQ.284 QCOSS also referred to the QPC's final report which stated that, at a minimum, the QCA's market comparison report should provide a comparative analysis of a range of price-related indicators, including

280 QPC 2016b, chapter 8 findings. 281 McArdle 2014. 282 Electricity Act, section 89D. 283 QCA 2016a, section 1.1. 284 QCOSS 2016, section 2.3.

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analysis of changes in underlying supply costs.285 Accordingly, QCOSS recommended that, as the government accepted the QPC's recommendations in full, the QCA should report on costs to supply electricity to meet the objectives of market monitoring and the QPC's recommendation.286 QCA position The QPC's final report did state that the QCA's market monitoring should include analysis of changes in underlying supply costs.287 However, the government considered the QPC's final report and provided the QCA with a Direction that does not require the QCA to report on supply costs. We consider that if or when the government wishes us to analyse supply costs as part of, or separately to, market monitoring, it will explicitly direct us to do so.

Prices and variations to prices Timing of data collection Submission QCOSS recommended that the QCA collect offer information daily or at least on a random basis, rather than quarterly, to ensure that the way market monitoring is undertaken does not affect retailer behaviour such that the retailers' offers look 'better' at the time that the monitoring process is observing them than they do at other times.288 QCA position It is possible that retailers could have published 'better' (i.e. cheaper or lower) priced offers on or close to the last day of the quarter than were available at other times in the quarter. However, it is not necessary to view daily or randomly selected offers, to monitor this type of retailer behaviour. A more practical approach in monitoring retailers' behaviour of this type is to:  periodically review each retailer's expired market offers to look for patterns of 'more expensive' offers being published and expired within quarters  review the publication dates of market offers downloaded on the last day of each quarter to look for any patterns of 'better' offers being published close to or on the last day of each quarter. In January, April and July 2017, we reviewed the published and expired offer data for 2016–17 obtained from Energy Made Easy, and found no evidence of the behaviour QCOSS was concerned about. In Chapter 2 we note that small business flat rate and time-of-use standing offer customers would have saved on electricity bills in each quarter during the year by switching to EnergyAustralia's lowest generally available market offer.289 Although some of EnergyAustralia's lowest market offers were available only for a short time, the fixed and variable charges on these offers were the same as other offers which EnergyAustralia had published on Energy Made Easy during 2016–17. The differences were the result of sign-up incentives which we identify in Chapter 2 and detail in Chapter 3. Only market offers were reviewed, because (a) retailers were prevented from changing their standing offer prices more than once in 2016–17, unless it was to reduce the price290; and (b) many standing offers

285 QCOSS 2016, section 2.3; QPC 2016b, section 8.5. 286 QCOSS 2016, section 2.3 (Recommendation 10). 287 QPC 2016b, section 8.5.4 (Table 15). 288 QCOSS 2016, section 2.1.1 (Recommendation 3). 289 Chapter 2, sections 2.4.4 and 2.4.5 (QCA assessment subsections). 290 National Energy Retail Law, section 23(9), as per section 16 of the schedule to the Queensland NERL Act.

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were expired by retailers in the first quarter of 2016–17 to achieve compliance with the fee types restriction (see Chapter 9). We also note that stakeholders can analyse retail offers daily or at random, by downloading offer information from Energy Made Easy at any time, if they want to check for the type of retailer behaviour QCOSS was concerned about.

Typical SEQ customer Submissions QCOSS recommended that, at minimum, the QCA report on the outcomes for customers with low, medium and high usage, on single or time-of-use tariffs, with or without controlled load tariffs, and with or without solar generation.291 ERM Power suggested that the QCA be cautious in presenting commentary around 'savings' between retailers' most expensive and cheapest market offers based on 'typical bill amounts' that ignore the variability of usage. ERM Power added that:  usage in the small business sector is often unable to align to the concept of 'typical use'  projections of savings may be distorted by atypical usage and seasonality  discounts converted to an average dollar value may be overstated and may not reflect the triggers to discount conditions.292 Mojo Power was concerned that the proposed analysis of retail offer prices shown in the scoping paper293 may not adequately represent its pricing behaviour in the Queensland retail electricity market. Mojo Power explained that:  its market offers generally contain a higher fixed component than its competitors, with much lower usage charges, making its offers generally more compelling for higher energy users  customers that save the most by switching to Mojo Power are therefore generally not 'typical customers' who would be used as the basis for comparison  the impact of the QCA using a typical annual consumption figure of 3,860 kWh for the residential flat rate tariff, as indicated in the scoping paper294, would accentuate the impact, as the consumption figure was much lower than the 5,175 kWh used by the AEMC in its 2015 report on retail electricity price trends.295, 296 QCA position We maintain our position that presenting prices as an annual bill for a customer with a median consumption level (typical SEQ customer), using consumption information from Energex, is appropriate for market monitoring. The median customer is the middle customer, in terms of consumption, out of all customers on a particular tariff. As such, approximately half of all customers will use less electricity than the typical customer, and half will use more. Further, stakeholders and retailers can use the dataset we

291 QCOSS 2016, section 2.2 (Recommendation 9). 292 ERM Power 2016, page 2. 293 QCA 2016a, section 2.3. 294 QCA 2016a, section 2.3.1. 295 The AEMC used a consumption figure of 5,173 kWh—not 5,175 kWh—for its 'representative [Queensland] consumer' in its 2015 and 2016 retail electricity price trends reports: AEMC 2015, section 3.1; AEMC 2016, section 4.1. 296 Mojo Power 2016, page 2.

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have published to calculate annual bill outcomes for different consumption levels across various tariffs and tariff combinations. The AEMC's consumption benchmark of 5,173 kWh includes 1,552 kWh attributed to the controlled load tariff.297 This, therefore, makes it broadly comparable to the figures we use in this report, being:  6,000 kWh for the residential flat rate with controlled load super economy tariff combination, of which 1,900 is for the controlled load super economy tariff  5,400 kWh for the residential flat rate with controlled load economy tariff combination, of which 1,800 is for the controlled load economy tariff.298

Lowest, highest and average market offer prices Submissions EnergyAustralia and ERM Power advised the QCA to exercise caution in comparing offers based on lowest, highest and average prices.299 EnergyAustralia noted that such comparisons would not capture the value of additional services (such as fixed price plans), while ERM Power submitted that the QCA's analysis would not reflect the qualitative nature of the service provision.300 EnergyAustralia also commented that lowest and highest offer analysis are only relevant for comparing standing offers and should not be relevant for market offers. EnergyAustralia recommended that the QCA seek information on retailers' most common market offer, in line with IPART's analysis301, to meet the requirements of the Direction.302 QCA position We maintain our view on the relevance of reporting on the lowest, highest and average market offer prices for each retailer in 2016–17. We agree that the value of additional non-price features and service offerings of market offers cannot be captured accurately by price-based analysis. As noted by EnergyAustralia, this is because the value of these benefits are not easily valued or quantified; for example, some customers may value a free energy audit more than others. On this basis, we consider that any attempt to quantify any non-price benefits may lead to misleading conclusions about prices and may potentially lead to customer confusion. This approach is also consistent with the 'standing and market offer annual bill pricing approach' adopted for reporting in other states and by consumer groups such as the St Vincent de Paul Society.303 Chapter 3 includes a summary (based on information from Energy Made Easy) of the types of benefits and incentives attached to market offers for residential and small business flat rate tariffs, for each retailer as at 30 June 2017. We acknowledge EnergyAustralia's general argument that details of retailers' most common market offer would provide useful information for stakeholders and customers. However, reporting on the most common offer is outside the scope of the Direction. Section 2(a) of the Direction requires the QCA to compare the lowest, highest and average market offer prices for each retailer, where relevant. The

297 AEMC 2015, section 3.1. 298 See Chapter 2, section 2.3.1 for more detail on the most common tariffs and tariff combinations. 299 EnergyAustralia 2016, page 3; ERM Power 2016, page 2. 300 EnergyAustralia 2016, page 3; ERM Power 2016, page 2. 301 See IPART 2016, chapter 6. 302 EnergyAustralia 2016, page 3. 303 See QCA 2016a, sections 2.2 and 2.3.1.

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Direction does not require the QCA to consider reporting on retailers' most common market offer, nor does it give the QCA discretion to consider any other matters it considers to be relevant.304

Averaging of market offer prices Submission QCOSS noted the scoping paper305 said that the simplest and most practical approach to calculate average market offer prices for each retailer would be to apply a simple (unweighted) average of the annual bill estimates of each retailer's portfolio of relevant offers. QCOSS submitted that:  a retailer wanting to appear cheaper on average could create many similar offers at the low end of its pricing range in order to move an unweighted average  these offers could all be essentially the same, but with slight variations in name so would not represent any additional benefit for consumers (and would in fact increase complexity for no additional benefit)  if the QCA was only looking at offers on the last day of each quarter, these offers would only need to be put on Energy Made Easy for the one day to be included. In order to be meaningful, some kind of weighting of the significance of offers was required  unweighted averaging, on its own, would be "useless" to meet the purposes envisaged for market monitoring, and would not meet the government's policy intent in monitoring the market.306 QCOSS recommended that the QCA apply weighting to make the reporting of average offers more meaningful, and report other measures as set out in the draft and final reports of the QPC's electricity pricing inquiry.307 QCA position We maintain our view that we should not weight market offers, for the reasons set out in the scoping paper308 and Chapter 2 of this report. Further, as stated above, we reviewed the published and expired offer data for 2016–17 obtained from Energy Made Easy, and found no evidence of retailers publishing 'better' priced offers on or close to the last day of the quarter than were available during the quarter.

Features of market offers Submissions QCOSS submitted that:  not all market offers have the same features  some features may be more desirable to some customers than others  it was therefore important that the QCA not just average or weight different types of offers, but also discuss the features of each offer.309

304 In contrast, the Electricity Act, section 90(5)(b), allows the QCA to have regard to any other matter it considers relevant to determine standing offer prices in the Ergon distribution area. 305 QCA 2016a, section 2.3.1. 306 QCOSS 2016, section 2.1.3. 307 QCOSS 2016, section 2.1.3 (Recommendation 6); QPC 2016, section 8.5.4 (Table 15). 308 QCA 2016a, section 2.3.1. 309 QCOSS 2016, section 2.1.4.

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QCOSS recommended that the market monitoring report take into account differences between tariffs, such as terms and conditions, and not just headline price differences.310 QCA position Customers can benefit from the different terms and conditions included in market offers. Chapter 3 includes a summary (based on information from Energy Made Easy) of the features attached to the residential and small business flat rate market offers for each retailer as at 30 June 2017.

Variations to market offer prices Submission QCOSS submitted that Energy Made Easy only provides information on offers available to new customers, and does not include consideration of how offers are varied to existing customers. QCOSS therefore suggested that the QCA's assessment of variations should include a:  quantitative assessment of how the market offer to a customer varies after a customer has signed up with a retailer  qualitative assessment of the process of variation. This should include consideration of the notice period of variations that customers receive, and how intelligible and actionable the variation information is.311 QCOSS suggested the data collection for these issues could be undertaken through information requests to retailers, supplemented with customer market research.312 QCOSS argued that a "key problem" with the QCA's approach to monitoring and reporting on variations (set out in the scoping paper313) was that it would focus on what retailers are offering, rather than what customers are experiencing or the outcomes being realised for customers. For example, QCOSS thought the QCA should report on:  whether prices remain the same for the duration of the contract, or whether prices change soon after customers take up a market offer  the trends in changes in tariffs for existing customers  how the trends in pricing of tariffs on Energy Made Easy that are on offer to customers moving to a new retailer, or to a new tariff, compare with the trends in pricing of tariffs to customers that stay on the same tariff with the same retailer.314 Accordingly, QCOSS recommended that the QCA:  modify its approach to monitor the impacts on customers who have taken up a market offer  emphasise investigating and reporting on what customers are experiencing since price deregulation, rather than solely focusing on what retailers are offering.315 QCA position The Direction is clear in requiring the QCA to use Energy Made Easy to report on generally available market offer prices, not the particular experience of individual customers.

310 QCOSS 2016, section 2.1.4 (Recommendation 7). 311 QCOSS 2016, section 2.1.2 (Recommendation 4). 312 QCOSS 2016, section 2.1.2. 313 QCA 2016a, section 2.3.1. 314 QCOSS 2016, section 2.1.2. 315 QCOSS 2016, section 2.1.2 (Recommendation 5).

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Generally available market offer information on Energy Made Easy—particularly in the contract expiry details field—does contain some information on how customers can be notified of changes to, and expiry of, their offers. This information can be accessed by stakeholders at any time. Further, we note that the AER is responsible for monitoring and enforcing compliance with the rules governing price change notifications as part of the NECF.316

Publishing datasets Submissions EnergyAustralia and Origin Energy recommended that the QCA not publish standing offer and market offer pricing datasets along with the final report. EnergyAustralia submitted that publishing datasets could result in publication of conclusions based on poor analysis.317 Origin Energy submitted that providing full datasets would represent an unnecessary effort for the QCA, given that the QCA's report will contain the most useful information for customers.318 On the other hand, QCOSS supported full downloadable datasets, with 'user friendly interfaces', being provided on the QCA website.319 QCA position We maintain our position of supplementing the market monitoring final report with a dataset for each standing and generally available market offer, for each of the most common residential and small business tariffs and tariff combinations, for the four quarters of 2016–17, available as a separate downloadable spreadsheet (on our website) for stakeholders seeking more detail. We consider that publishing datasets for each standing and market offer:  provides increased transparency on our analysis  provides stakeholders, retailers and consumers with the opportunity to analyse standing and market offer pricing information and review information on the features attached to retailers' standing and market offers. In turn, this may result in improved stakeholder/customer understanding of the SEQ retail market (and therefore improved consumer confidence) and assist with decision-making. Users of the datasets will ultimately be responsible for any analysis undertaken or conclusions drawn or published, where such analysis or conclusions are based on their own analysis of the Energy Made Easy data published by the QCA.

Discounts, savings and benefits Submission QCOSS submitted that, besides the monitoring and reporting set out in the scoping paper, the QCA also needed to monitor and report on the length of time for which discounts, savings and other benefits are available to customers, as these can impact significantly on the value of the discount, saving or benefit to the customer. QCOSS noted that:  often these are only available for an initial period of (say) six months, one year or two years

316 See the NERL, section 23A, as per section 17 of the schedule to the Queensland NERL Act and AER 2014. 317 EnergyAustralia 2016, page 3. 318 Origin Energy 2016, page 1. 319 QCOSS 2016, chapter 2 (Recommendation 2).

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 in other cases, the customer will always enjoy that discount level as long as he/she stays with the retailer320 QCOSS recommended that the QCA include in the report:  The base rates off which discounts are being promoted (especially where these differ from the standing offer prices.  Length of time for which discounts and savings and other benefits are available to the customer.  How customers are informed/reminded before the benefit ceases.  The circumstances under which a customer may lose a discount and the impact of that [loss] on the price paid.  The extent to which direct debit discounts are extended to payments made direct to retailers by Centrelink (via Centrepay).321 QCA position We acknowledge the importance of retailers' administration of discounts, savings and benefits to customer outcomes in the market. We also note that Dr Alan Finkel stated in his June 2017 report of the review into the future security of the NEM:

Comparing offers from different retailers is … complicated by differences in how prices are structured and marketed. For example, prices may include several different components, and may be marketed as a discount of ‘x’ per cent without it being clear to the consumer what base the discount is from. Marketing by retailers should be much clearer and state the standard price from which any discounts apply.322 In similar terms, the August 2017 independent review into Victoria's electricity and gas retail markets reported:

Discounts can be difficult to understand and may mislead consumers. It is often not clear what the discount is from (the total bill or just on the variable charge/cost of the energy used) and what the actual price is that the consumer will pay. Consumers seem unaware that a discount rate does not mean 'the best price'. What is being presented by retailers as 'a simple decision for consumers to make' is in fact, a complex decision.

… Should the customer want to know the actual price to determine if the discount will provide better value, they need to open the price fact sheet, know their energy consumption amount, know the fixed supply charge, know whether to apply the discount to the variable charge (cost of energy used) or the total bill, and then calculate the likely price outcomes.

Discounts linked to pay on time, or on-line billing disadvantage low-income and vulnerable customers, despite the fact that energy is an essential service. 323 Most recently, the ACCC's retail electricity pricing inquiry preliminary report stated:

Even if a 'discount' does not meet the threshold to be considered misleading or deceptive under the ACL, it could still be very confusing for consumers. This is particularly the case when there is no consistent form of presentation or application of discounts. For example, discounts advertised by major retailers vary in a number of important ways, some are:

- applied to the whole bill, while others apply only to usage charges

320 QCOSS 2016, section 2.4. 321 QCOSS 2016, section 2.4 (Recommendation 11). 322 Finkel 2017, section 6.2. 323 Thwaites, Faulkner and Mulder 2017, industry practices and regulation chapter.

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- based on the retailers' standing offer tariffs, while others are based on the retailers' 'basic' market offers - guaranteed, while others are conditional on the consumer paying on time or by direct debit

- apply for the term of the contract, while others are time limited and finish before the contract itself expires.324 As stated in section 3.4.3, based on our analysis of generally available market offers for this review, we consider that:  Discounts were clearly stated in terms of what they were based on—usually the variable usage charge.325  The different usage charges of retailers could make it difficult, and/or time-consuming, for customers to determine the value to them of various discount options.  Customers would also need to consider their current and future consumption levels, discount benefit periods, their willingness and ability to meet conditions attached to discounts, any incentives, the fees attached to offers, and whether discounts apply to charges before or after solar feed-in tariffs are applied, to decide which discount would offer them the best value in terms of bills. We did not identify any offers where a discount applied for less than the 12-month reporting period. In this report, we deal with the base market offer prices off which discounts were promoted. However, additional information about discounts, savings and benefits is in our dataset, and much of the information QCOSS sought was publicly available on Energy Made Easy.

Fees and charges Fee types Submission QCOSS recommended changes to three aspects of the QCA's monitoring of fees:  Fees not included on Energy Made Easy  Distribution non-network charges that vary between retailers  Metering charges.

Fees not included on Energy Made Easy QCOSS recommended that the market monitoring report cover all types of fees and charges, regardless of whether or not they are included on Energy Made Easy.326 QCOSS made particular reference to Mojo Power's membership fees for its subscription-based plans, emphasising that the QCA should ensure that this type of fee is included in its analysis.327

Distribution non-network charges that vary between retailers QCOSS recommended that the market monitoring report cover all types of fees and charges that vary between retailers; for example, distribution non-network charges, including any add-on, mark-up or adjustments to distribution business charges.328 QCOSS provided (publicly available) evidence that

324 ACCC 2017, section 4.3.2. 325 See Chapter 3, sections 3.4.1 and 3.4.2 (QCA assessment subsections) 326 QCOSS 2016, section 2.5 (Recommendation 12). 327 QCOSS 2016, section 2.1.5 (Recommendation 8). See Chapter 8, section 8.4.1 for details of Mojo Power's subscription-based plans. 328 QCOSS 2016, section 2.5 (Recommendation 12).

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showed significant differences in the quantum of reconnection and disconnection fees between two retailers:  AGL's reconnection fee of $10.75 including GST329  Mojo Power's reconnection fee of up to $108.87 including GST.330 QCOSS added that Mojo Power also charges a disconnection fee (of up to $108.87 including GST), which was not mentioned in the corresponding AGL fact sheet.331

Metering charges QCOSS considered that the scoping paper was inconsistent in describing how metering charges would apply to a customer. In particular, QCOSS requested that a clear distinction be made on whether metering charges are included in the fixed charge or treated as a cost that will be passed through from retailers to customers.332 QCOSS recommended that the QCA be consistent in reporting metering charges across retailers, and offers.333 QCOSS also recommended that the market monitoring report include:  a full disclosure of all circumstances where customers may face metering charges for installation, replacement or removal of a meter to support different tariffs  the number of meters that are being replaced for reasons other than normal wear-and-tear replacements, which retailers are undertaking those replacements, and which tariffs are affected  any other factor that is relevant to whether or not a customer's meter will be replaced because of their choice of retailer or tariff.334 QCA position Fees not included on Energy Made Easy For consistency with reporting on other sections of the Direction—particularly sections 2(a)–(c) and (e)— we are reporting only on (retail) fees that are included in retailers' offers on Energy Made Easy. As Mojo Power's membership fees are included on Energy Made Easy335, we include these fees in our analysis.

Distribution non-network charges that vary between retailers We do not dispute QCOSS's argument that retailers do not all charge the same amounts for distribution non-network charges. In Chapter 2 we summarise the reconnection and disconnection fees included on retailers' residential and small business flat rate market offers, published on Energy made Easy as at 30 June 2017. We also conclude that all retailers should clearly identify on Energy Made Easy where customers can obtain information on additional distribution non-network charges that apply, or may apply, to their offers.

329 QCOSS's submission included a link to the 'AGL Set and Forget – Queensland residential electricity market offer – AGL200325MR'. 330 QCOSS's submission included a link to Mojo Power's 'We're the forward thinking power people' document which included offer fact sheets showing the reconnection and disconnection fees. 331 QCOSS 2016, section 2.5. 332 QCA 2016a, section 2.3.3. 333 QCOSS 2016, section 2.6 (Recommendation 13). 334 QCOSS 2016, section 2.6 (Recommendation 14). 335 Mojo Power's membership fees were either $280 or $420 per annum (GST incl.) in 2016–17. See Chapter 8, section 8.4.1 for detail.

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Metering charges As detailed in Chapter 2, we found, through our information notice process, that most retailers included metering charges in their fixed charges. We made no adjustments to retailers' charges published on Energy Made Easy to account for the inclusion or otherwise of metering charges in fixed charges. We also conclude that all retailers should clearly identify on Energy Made Easy their metering charges, or state that they do not levy metering charges if that is the case, in their offers. We consider it would be outside the scope of the Direction reporting on full disclosure of all circumstances where customers may face metering charges for installation, replacement or removal of a meter to support different tariffs, and the reasons for customers' meter replacements.

Application of fees Submission QCOSS recommended that the market monitoring report include charges and fees reported per bill as well as annually, to provide a clear picture of cost where charges depend on how frequently bills are presented.336 QCA position Retailers' 2016–17 offers on Energy Made Easy expressed fees and charges as a fixed rate or a percentage of a bill. We have included compulsory retailer fees relating to the sale of electricity to customers (e.g. membership fee) in our analysis of standing and market offer bills for a typical SEQ customer. As non-compulsory fees and charges were excluded from our calculations of annual bills, the frequency of these types of fees and charges in customer bills is not reflected in our bill analysis. However, retailers' price fact sheets on Energy Made Easy include information on the types of fees and charges; QCOSS, like all stakeholders, can use this information to conduct its own analysis.

Switching to market offers Customer switches and movements Submissions EnergyAustralia submitted that the simplest means to monitor switching to market offers is to track the total number of standing offer customers over time. EnergyAustralia added that this information was provided to the QCA prior to the commencement of the NECF.337 Mojo Power suggested the QCA consider not requiring retailers to provide data for customers that are only switching away from temporary deemed contract arrangements, as it may lead to the inclusion of switching data that does not provide any insight into retail market competition following the removal of price regulation. As an example, Mojo Power explained that it rarely places customers (such as move-in customers) on its standing offer. If this does occur, Mojo Power explained that it immediately seeks to contact these customers and move them onto its market offers, as they are better priced for most consumers.338

336 QCOSS 2016, section 2.5 (Recommendation 12). 337 EnergyAustralia 2016, page 2. For information on the data, see the market customer statistics page of the QCA's website, http://www.qca.org.au/Electricity/Reviews/Market-reports-and-statistics/Market-Customer- Statistics/Final-Report/Market-Customer-Statistics#finalpos. 338 Mojo Power 2016, page 1.

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QCOSS quoted the scoping paper, where the QCA stated it would be difficult for stakeholders to draw conclusions about the state of competition in SEQ under the proposed methodology due to the inability to capture data on all customers switching to market offers, and the preference of an unquantified number of customers to remain on standing offers.339 QCOSS criticised the QCA for "still intending just to undertake" a comparison and assessment of customer switching behaviour despite it recognising that it will be a "flawed measure that will not allow conclusions to be drawn about the state of competition".340 QCA position Capturing data on all customers switching from standing to market offers based on switching information provided by retailers would be a challenging and resource-intensive exercise. This is because when a customer on a standing offer transfers to a market offer with a different retailer, the new retailer does not have any record of the type of contract the customer was on with their previous retailer. Therefore, to track this group of customers, we would have been required to undertake a detailed and complex analysis of extensive information obtained from retailers for each of their customers, on each of the most common tariffs and tariff combinations, who switched to a market contract in 2016–17. This would have been likely to impose a material regulatory burden on retailers, the costs of which would likely have been passed on to customers in terms of higher electricity prices. As stated in the scoping paper, the QCA's market monitoring report does not include assessments about the effectiveness of competition in the SEQ retail electricity market.341 As the switching data reported by the QCA is only be a subset of customer switching behaviour, stakeholders may wish to refer to the AEMC's annual retail electricity competition reports and the range of information on retail electricity supply published by the AER for analysis of the state of retail electricity competition in Queensland. We disagree with Mojo Power's suggestion of excluding temporary deemed contract arrangement customers who switch from a standing offer to a market offer in its analysis. As standing offers are generally more expensive than market offers, we are unsure whether it would be in every retailer's interest to move customers to a lower priced market offer. Further, some customers may choose to remain on a standing offer, particularly those who are less engaged in the market and/or are not price sensitive, or who value additional customer protections provided under a standing offer. Based on these reasons, we are of the view that customers on temporary deemed contracts who switch from a standing offer to a market offer should remain in scope. We explored EnergyAustralia's suggestion to track the number of customers switching from standing offers to market offers over time, but found that it would not enable us to fulfil the requirements of section 2(f) of the Direction because the customer switching information provided by retailers to us prior to the commencement of the NECF342 was, and the Australian Energy Market Operator's (AEMO) retail transfer statistical data343 is, collected and reported at a connection (NMI) level, rather than at a customer account level. QCOSS has misinterpreted our statements regarding the difficulty of drawing conclusions about the state of competition in the SEQ market based on the switching measure alone. We cautioned that, by itself, the information would not allow stakeholders to draw conclusions about the state of competition in SEQ. We consider that our approach is consistent with the Direction, and therefore is appropriate.

339 QCA 2016a, section 3.1; QCOSS 2016, section 3.0. 340 QCOSS 2016, section 3.0. 341 QCA 2016a, section 1.1. 342 Electricity Industry Code (repealed), clause 8.5.2. 343 AEMO website, retail transfer statistical data page, http://aemo.com.au/Electricity/National-Electricity- Market-NEM/Data/Metering/Retail-Transfer-Statistical-Data.

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Understanding customer behaviour Submission QCOSS quoted the background to the switching section of the scoping paper:

Standing offer prices are generally higher than market offer prices, reflecting to some extent the difference in terms and conditions between the two types of contract, and their impact on retailer costs. Despite the generally higher prices, some customers opt to remain on standing offers. This may be because customers value greater customer protections in standing offers. Customers who are not price- sensitive may also prefer the simplicity of standing offers to the (relative) complexity of market offers.344 QCOSS stated that the QCA should conduct research to test the QCA's assumptions on customer behaviour, to discover the real reasons why consumers make the choices that they do make in regard to standing offers and market offers. Such research from a consumer perspective, QCOSS argued, would provide valuable input to enable the government to evaluate the impacts of deregulation on SEQ customers.345 QCOSS recommended that the QCA undertake market research of customers' experiences, preferences and concerns to ascertain the movement of customers:  from standing offers to market offers and vice versa  between market offers with the same retailer  between market offers from different retailers  the outcomes being achieved by those customers.346 To obtain a comprehensive picture of the impacts of price deregulation on customer switching between standing and market offers, Mojo Power suggested the QCA should consider collecting this data through a survey of customers, rather than collecting only part of this data from retailers.347 QCA position The text in the scoping paper was descriptive and provided for context, indicating some logical reasons why some customers may prefer standing offers to market offers. We were not making assumptions about consumer behaviour. The Direction does not require the reasons for their behaviour to be comprehensively identified.

Customer location Submissions The AEC and ERM Power questioned the merits of the QCA's proposal to use postcode-based data to report on small business customers switching. Both stakeholders were of the view that the approach would probably show results skewed by areas of commercial zoning. They therefore recommended that small business customers be excluded from the analysis.348 QCOSS's submission, which has led us to report on the number of switching customers in a postcode as a proportion the total customers in that postcode, is dealt with in Chapter 6.

344 QCA 2016a, section 3.1; QCOSS 2016, section 3.0. 345 QCOSS 2016, section 3.0. 346 QCOSS 2016, section 3.0 (Recommendation 15). 347 Mojo Power 2016, page 1. 348 AEC 2016, page 1; ERM Power 2016, page 3.

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QCA position Small business customers are clearly in the scope of section 2(f)(i) of the Direction—residential customer switches and small business customer switches are dealt with in Chapter 6.

Hardship and concession customers Defining energy concession customers Submissions AGL accepted the QCA's interpretation of 'energy concession' being those customers receiving the government's electricity rebate349, and confirmed that it could effectively report the number of customers on standing and market offers that were participating in a retailer hardship program or receiving an energy concession in 2016–17. However, regarding providing information on the electricity prices paid by hardship and concession customers, AGL believed this definition was "inappropriate". AGL explained that the electricity rebate is available to many different concessional card holders, including customers with a seniors card. AGL said that seniors card holders:  make up over 30 per cent of AGL's electricity customers, and AGL would expect this percentage to be similar across other retailers  do not markedly differ from AGL's total residential customer base in any characteristics such as consumption, location or debt  are not aligned with customers in hardship or those holding other types of concessional cards.350 AGL suggested that—if the policy intent of obtaining this retail pricing information is to ascertain whether customers in hardship or financial difficulties are participating in the electricity market and the impact this is having on their electricity bills—the QCA should narrow its data request to hardship customers and restricted concession customers. AGL suggested that more relevant information could be obtained if the QCA limited the pricing data request to hardship (e.g. less than 3,000 AGL customers).351 Similar to AGL, the AEC submitted that:  the QCA should limit the data collection to just hardship customers  focusing only on hardship data would allow for a more targeted approach for policy decisions.352 Conversely, QCOSS was of the view that defining concessions card holders as those in receipt of the electricity rebate in Queensland was problematic, as the electricity rebate currently excludes health care card (HCC) holders. QCOSS noted that the government announced—on 30 November 2016 in its response to the QPC final report—changes to include HCC holders and asylum seekers in the eligibility for the electricity rebate; however this would not be implemented until 1 April 2017.353 QCOSS submitted that this meant that only investigating the impacts for customers in receipt of the electricity rebate will exclude a significant number of low income and vulnerable customers who are not eligible to receive the rebate. QCOSS considered that, as a result, it was important for the QCA to include an additional category or use a wider definition of 'concessions' to include not only those on the

349 QCA 2016a, section 3.3.4. 350 AGL 2016, page 2. 351 AGL 2016, page 2. 352 AEC 2016, page 2. 353 QCOSS 2016, section 4.1. The government's response to the QPC final report (Recommendation 43) said that eligibility for the rebate will extend to HCC holders and asylum seekers, and be backdated to 1 January 2017. See Queensland Government 2016, page 14.

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electricity rebate but also any customers who received or applied for a Home Energy Emergency Assistance Scheme (HEEAS) payment in 2016–17. QCOSS supported its position by saying that would better meet the intent of the Direction which is to better understand how those who are on low incomes or struggling financially are faring in the market.354 Accordingly, QCOSS recommended that the QCA look at the following customer groups (both separately and combined) in order to monitor and report on concession customers:  customers receiving the electricity rebate  customers who have received or applied for a HEEAS payment during the year.355 QCA position We agree that removing energy rebate recipients would have materially reduced the regulatory burden on retailers, as noted in AGL's and the AEC's submissions. However, the Direction is clear that concession customers—as defined under the Direction as those receiving the government's electricity rebate—are to be included in the market monitoring report. In response to QCOSS's submission that customers who have received or applied for a HEEAS payment during the year should be included in monitoring of concession customers, we consider that these customers are outside the scope of the Direction.

Defining hardship customers Submissions QCOSS considered that the definition of hardship in the Direction is too narrow. QCOSS submitted that, to understand the impacts of deregulation for customers experiencing hardship, the QCA's monitoring and reporting should look not just at customers on retailers' hardship programs, but also customers accessing payment plan arrangements (which retailers also now report on separately to the AER356). QCOSS noted that many customers on payment plans are actually in financial hardship, but have not entered the hardship program or have experienced barriers accessing the hardship program. QCOSS added that, in its 2014–15 annual report on the performance of the retail energy market, the AER stated, to assist in interpreting payment plan customer data "[r]etailers must only report on arrangements with at least three instalments, and where the customer is paying off arrears (of any overdue amount). Customers using flexible payment arrangements for convenience or budgeting purposes are excluded for the purposes of payment plan reporting".357 Based on this description, QCOSS considered that customers on payment plans are experiencing payment difficulty and should therefore be included within the scope of 'hardship' customers for this aspect of the QCA's monitoring. Accordingly, QCOSS recommended that the QCA look at the following customer groups (both separately and combined) in order to monitor and report on hardship customers:  customers in hardship programs  customers on payment plans.358

354 QCOSS 2016, section 4.1. 355 QCOSS 2016, section 4.1 (Recommendation 18). 356 See AER 2015b, section 2.4 and AER 2016, section 2.4. 357 QCOSS 2016, section 4.1; AER 2015, section 2.4. 358 QCOSS 2016, section 4.1 (Recommendation 18).

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QCA position We consider that the Direction is clear in requiring us to report on customers who are participating in retailer hardship programs, and/or are receiving the electricity rebate. The other types of customer groups identified by QCOSS are therefore out of the scope for the market monitoring report.

Quality and accessibility of hardship programs Submission QCOSS considered that improvements are required to the QCA's approach to meet the requirements of the Direction, and what it referred to as other "documented purposes" of market monitoring, to adequately determine the impacts of deregulation for low income and vulnerable customers.359 QCOSS noted that the QPC's electricity pricing inquiry final report stated that "monitoring the impacts of deregulation on vulnerable customers will be particularly important to ensure they are able to effectively participate in the market and are adequately supported".360 Further, QCOSS noted that the government accepted the QPC's recommendation361 that the government "ensure the impacts of deregulation on vulnerable and low income customers are monitored, particularly in relation to:  consumer understanding of contract terms and benefits, including percentage discounts off standing offers  late payment penalties  the quality and accessibility of retailers' hardship programs".362 QCOSS also considered that in order to determine the impacts of deregulation on this customer group, the QCA's monitoring and reporting must consider the actual prices paid by low income and vulnerable customers. QCOSS argued that this must include:  which customers are on standing offers versus market offers  the type of tariffs that the customers are on  the type of conditions that are attached to the offers and whether the customers are meeting those conditions  the prices that the customers are actually paying.363 QCOSS noted that this level of analysis is particularly important given the dominance of pay-on-time discounts in the market, and the fact that these offers are often unsuitable to low income or hardship customers who may not always be able to pay their bills on time.364 Based on the above, QCOSS recommended that the QCA's monitoring and reporting approach in regards to hardship and concession customers be broadened to include gathering evidence on the aspects recommended by the QPC (and accepted by the government). QCOSS noted that this would require market research of customers to be undertaken to determine the impacts of deregulation and customer understanding of terms and conditions.365

359 QCOSS 2016, section 4.0. 360 QCOSS 2016, section 4.0; QPC 2016b, chapter 8 findings. 361 QCOSS 2016, section 4.0; Queensland Government 2016, page 10. 362 QPC 2016b, section 8.6 (Recommendation 27). 363 QCOSS 2016, section 4.0. 364 QCOSS 2016, section 4.0. 365 QCOSS 2016, section 4.0 (Recommendation 17).

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QCA position Section 2(g) of the Direction is specific in requiring the QCA to report on the number of customers on standing and market offers in 2016–17 who were participating in a retailer hardship program or receiving an energy concession, and the standing offer and market offer prices they paid. Reporting on the quality and accessibility of retailers' hardship programs, and their relationship with low income / vulnerable customers, as well as low income / vulnerable customers' understanding of the terms and conditions of their offers, as suggested by QCOSS, is out of the scope for the market monitoring report.

Retailers with more than one standing offer Submission QCOSS requested that the QCA clarify the statement in the scoping paper that some retailers offer more than one standing offer.366 QCA position Our observation of standing and market offers on Energy Made Easy in 2016–17 is that some retailers offered more than one standing offer per tariff type.

New types of retail tariff structures and plans Submissions ERM Power suggested the QCA will be able to seek sufficient information from Energy Made Easy to identify product offerings and meet the requirement of section 3 of the Direction.367 Mojo Power stated that:  its subscription based offer is a significant innovation in retailing energy  the EnergyPass subscription allows customers to access Mojo Power's wholesale rates, being its expected costs to serve its customers  unlike other retailers, it does not profit based on how much energy its customers use; it profits on the number of subscriptions it sells.368 QCOSS submitted that the QCA should use the information notice process, as well as Energy Made Easy and the retailers' websites to collect, analyse and report on the emergence of new structures and plans in its report. QCOSS added that the extraction of Energy Made Easy data should be ongoing, and not just on the last day of each quarter.369 QCOSS recommended that the QCA have regard to new types of retail tariff structures, such as demand- based tariffs, subscription-based products and services, and capped plans that set out in advance how much a customer will pay rather than being based on actual usage.370 QCA position We consider that Energy Made Easy and retailers' websites provided sufficient information on the retail tariff structures and plans for us to report on this aspect of the market. By inviting, rather than requiring,

366 QCA 2016a, section 4.3.2; QCOSS 2016, section 4.0. 367 ERM Power 2016, page 3. 368 Mojo Power 2016, pages 2–3. 369 QCOSS 2016, section 5.0. 370 QCOSS 2016, section 5.0 (Recommendation 19).

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retailers to provide any information on tariff structures and plans, we reached a reasonable balance between allowing retailers to promote new structures and plans and adding to the compliance burden.

Standing offer fee types restriction Submissions QCOSS submitted that the QCA's proposed methodology may meet the requirements of the Direction; however, it would not meet the other documented purposes of market monitoring as set out in the [explanatory notes to the] ECPLA Bill and the QPC's electricity pricing inquiry final report.371 QCOSS noted that the fee types restriction in the NERL (section 22A) is the only derogation that the QCA proposed to monitor and report on for 2016–17. QCOSS considered that there are other relevant derogations, such as the requirement for individualised advanced notice of price increases, which it believed the QCA should also monitor and report on in terms of customer outcomes.372 QCOSS recommended that the QCA monitor and report on the customer impacts of all relevant derogations implemented in Queensland, including whether those derogations are being met and how information that relates to those derogations is being published accurately in the retailers' price fact sheets.373 QCA position The Direction requires the QCA to comment on any significant issues that emerged in 2016–17 in SEQ regarding the Queensland-specific derogations to the NECF concerning price deregulation for which the QCA is responsible. For the purpose of market monitoring, we interpreted this to mean derogations relating to price deregulation, which is the fee types restriction in subsections (3) and (4) of section 22A of the NERL. Further, the 'notice of price increases' derogation to which QCOSS refers is regulated by the AER.

QCA information notice Streamlining requirements (switching, hardship and concession customers) Submissions EnergyAustralia submitted that:  the QCA information notice request would coincide with a range of other regulatory reporting obligations  much of the data being requested by the QCA is currently provided to the AER as part of retailer reporting obligations  effort by the QCA to streamline overlapping data requirements with the AER, by establishing a data sharing Memorandum of Understanding, will minimise the ongoing burden to retailers.374 ERM Power appreciated the QCA's recognition of the importance of giving due consideration to the compliance costs of meeting data requests for the review. ERM Power indicated that compliance costs

371 QCOSS 2016, section 6.0. 372 QCOSS 2016, section 6.0. 373 QCOSS 2016, section 6.0 (Recommendation 20). 374 EnergyAustralia 2016, page 3.

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were likely to be passed through to customers in terms of higher electricity prices, and that this should not be understated for those retailers that have a small retail base to spread these costs over.375 To minimise the regulatory burden, particularly on smaller and new entrant retailers, Mojo Power urged the QCA to explore all options to obtain data from existing sources. Mojo Power stated this data could be publicly available, or could be obtained through mutual arrangements with other regulatory bodies.376 QCA position The data reported by retailers to the AER as part of their reporting obligations has not been sufficiently detailed to enable us to meet the requirements of the switching, and hardship and concession customers sections of the Direction. We have, however, accepted retailers' submissions to reduce the reporting burden for hardship and concession customers (see Chapter 7 for detail).

Timeframe for switching, hardship and concession customers information notice Submission QCOSS considered that two months was a reasonable timeframe for the QCA to give retailers to give the QCA the relevant information the QCA will require to comply with the switching, and hardship and concession customers elements of the Direction. However, QCOSS:  noted that 31 October 2017 would be well over a year after standing offer price deregulation had been implemented  would have hoped and expected the final report to be provided to the Minister and published on the QCA's website well before 31 October 2017, rather than on 31 October 2017  was very concerned that the QCA did not seem to be planning for finalisation and publication of the report well before 31 October 2017  was concerned if retailers delay getting information to the QCA, the QCA may seek extension of the date for finalisation and publication of the market monitoring report beyond 31 October 2017  recommended that the QCA obtain prior commitment from the retailers to provide timely and accurate and complete responses to the information notices in time to allow the QCA to finalise and publish its report well before 31 October 2017.377 QCA position We accept QCOSS's point that 31 October 2017 was well over a year after deregulation had commenced. We consider that, to review published standing and market offers for the full financial year, a report could not be produced before 30 June 2017. Also, it would be unrealistic to have expected retailers to provide us with information for the year to 30 June 2017, sufficiently before 30 June 2017 in order to publish the report well before 31 October 2017. Further, none of the AER, IPART and the ESC publish their respective price/market monitoring reports before the end of the financial year to which they relate. Also, there was no requirement for us to publish the report early. We also consider that, at the time of publication, many customers in SEQ will be contracted to offers on the terms and conditions that we have compared and assessed in this report. In this regard, the report provides timely and meaningful information to stakeholders, including customers.

375 ERM Power 2016, page 3. 376 Mojo Power 2016, page 1. 377 QCOSS 2016, section 7.0 (Recommendation 21).

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We do not consider that we have the legal power under section 89C of the Electricity Act to obtain prior commitment from the retailers to provide "timely and accurate" responses to our information notices. However, we did engage extensively with retailers during the course of the review to make it easier for them to provide their responses to information notices. Finally, as explained in Chapters 1 and 10, the Minister subsequently extended the deadline for publication of the market monitoring report from 31 October 2017 to 30 November 2017.

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APPENDIX E: KEY ASSUMPTIONS IN PRICE ANALYSIS

Point-in-time approach 2015–16 We use offers that were available on the last day of each quarter of 2015–16 in our analysis. This means that any offers which may have been available during a quarter(s), but which were not available as at the last day of a quarter(s), were not included in our analysis. Our approach also (implicitly) assumes that the customer entered into a contract based upon the terms, conditions and retail offer prices that applied on the last day of each quarter.

2016–17 Only those offers that were available on the last day of each quarter—with an effective date of equal to or greater than 1 July 2016—are included in our analysis. This means that any offers which may have been available during a quarter(s), but which were not published as at the last day of a quarter(s), are not included in our analysis. Our approach also (implicitly) assumes that the customer entered into a contract based upon the terms, conditions and retail offer prices that applied on the last day of each quarter. In the June quarter however, we include offers for Next Business Energy, Powershop and QEnergy which were expired by these retailers on 30 June 2017. Each of these three retailers had offers published on Energy Made Easy during the quarter but had no offers published as at 30 June. If we had not included the expired offers, the three retailers would not have been included in the June quarter reporting, which we consider would not have met the purpose of the Direction in terms of reporting on retailers' prices in the market in the June quarter.

Number of days in a year We use 365.25 days in a financial year, consistent with the figure used in calculating annual bills in the QCA's 2016–17 electricity pricing determination.378

Annual bills—standing offers We exclude the value of:  additional features offered by retailers which incur an additional charge (e.g. GreenPower)379  retailers' fees and charges which do not apply to all customers  solar feed-in tariffs.  Diamond Energy's 3 per cent pay on time, and 3 per cent direct debit, discounts off the bill.380 Where retailers offered more than one standing offer per tariff or tariff group, we report the lowest standing offer on the basis that, generally, higher price standing offers were for solar customers. Diamond Energy advised us that it offers discounts to standing offer customers to ensure its offers are competitive and attractive to as many customers as possible in Queensland.381 We note that, in South

378 QCA 2016b, Appendix J; Queensland Government Gazette 2016, page 119. 379 Retailers' GreenPower options are reported in Chapter 3, sections 3.4.1 and 3.4.2 (GreenPower subsections). 380 Diamond Energy's discounts are reported in Chapter 3, sections 3.4.1 and 3.4.2 (discounts subsections).

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Australia, Diamond Energy had standing and market offers for residential and small business customers in 2016–17, and the average and lowest market offers were cheaper than the standing offers.382 The table below shows Diamond Energy's annual bills, before and after conditional discounts, for its standing offers for the tariffs and tariff combinations included in this report. Table 62 Annual bills for a typical Diamond Energy standing offer customer, before and after conditional discounts, 30 June 2017

Tariff / tariff combination Offer name (ID) Before conditional After conditional Saving ($) discounts ($) discounts ($)

Residential flat rate Diamond Power 1,575 1,480 94 (DIA221767SR)

Residential flat rate with Diamond Power 1,931 1,815 116 controlled load super economy (DIA221769SR)

Residential flat rate with Diamond Power 1,877 1,764 113 controlled load economy (DIA221769SR)

Small business flat rate Diamond Power 2,430 2,284 146 (DIA221770SS)

Small business time-of-use DE Small Business Time of 6,519 6,128 391 Use (DIA221775SS)

Notes: Diamond Energy did not change its standing offer prices during 2016–17. Sources: Energy Made Easy; Diamond Energy's responses to parts 1–3 of the QCA's information notice (unpublished); QCA analysis.

Annual bills—market offers We account for:  quantifiable one-off sign-up bonuses (reduction to bills)  guaranteed and conditional discounts (reduction to bills)  membership fees (addition to Mojo Power bills only). We exclude the value of:  additional features offered by retailers which incur an additional charge (e.g. GreenPower)  retailers' fees and charges which do not apply to all customers  solar feed-in tariffs. Some retailers' higher priced market offers may be for solar customers only. As retailers did not apply a common approach to identifying solar-only offers in offers published on Energy Made Easy in 2016–17, we did not remove any market offers from our analysis.

Annual bill—average market offer prices We use a simple (unweighted) average of each retailer's portfolio of market offers (annual bills) as at the last day of each quarter.

381 Diamond Energy 2017, response to part 2 of the QCA's information notice (unpublished). 382 ESCOSA 2017, Annexures C and D.

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GST All typical customer bills include GST unless otherwise specified.

Residential offers available to small business customers Lumo Energy Lumo Energy published four residential flat rate market offers (LUM191875MS, LUM191878MS, LUM191881MS, and LUM191884MS) on Energy Made Easy in 2016–17, which were available to small business customers.383 We retain the four offers in the residential tariff reporting. We note that the fixed charges (97.99 cents per day) on these offers were lower than the fixed charges (129.29 and 136.29 cents per day) on Lumo Energy's small business flat rate market offers.

QEnergy 2015–16 QEnergy published three residential flat rate standing offers (QEN75926SR, QEN75928SR and QEN73900SR) on Energy Made Easy in 2015–16, which were available to residential and small business customers.384 On the basis that the offers were published for residential customers and, with the exception of the variable charge on one of the offers (QEN75928SR), the fixed charges (116.398 cents per day) and variable charges (22.238 cents per kWh) on them were significantly lower than QEnergy's fixed charges (140.226 cents per day) and variable charges (22.481 and 24.516 cents per kWh) on its small business flat rate standing offers, we retain the three offers in the residential tariff reporting. 2016–17 QEnergy published four residential flat rate standing offers (QEN204786SR, QEN204789SR, QEN336038SR and QEN336041SR) on Energy Made Easy in 2016–17, which were available to residential and small business customers.385 We retain the four offers in the residential tariff reporting. We note that fixed charges (127.539 cents per day) and variable charges (23.795 cents per kWh) on these offers were lower than QEnergy's fixed charges (153.959 and 166.507 cents per day) and variable charges (28.058 and 30.345 cents per kWh) on its small business flat rate standing (and market) offers.

Small business offers available to residential customers QEnergy QEnergy also published nine small business flat rate market offers (QEN280002MS, QEN280005MS, QEN280008MS, QEN336044SS, QEN336047SS, QEN337967MS, QEN337970MS, QEN337973MS and QEN337976MS) on Energy Made Easy in 2016–17, which were available to residential and small business customers.386 We retain the nine offers in the small business tariff reporting. We note that fixed charges (153.959 and 166.507 cents per day) and variable charges (28.058 and 30.345 cents per kWh) on these offers were higher than QEnergy's fixed charges (127.539 cents per day) and variable charges (23.795 cents per kWh) on its residential flat rate standing offers.

383 Lumo Energy 2017, response to part 1 of the QCA's information notice (unpublished). 384 QEnergy 2017, response to part 1 of the QCA's information notice (unpublished). 385 QEnergy 2017, response to part 1 of the QCA's information notice (unpublished). 386 QEnergy 2017, response to part 3 of the QCA's information notice (unpublished).

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Queensland Competition Authority Appendix E: Key assumptions in price analysis

Calculating annual bills using our published dataset The table below shows how stakeholders can calculate annual bills using the dataset published on the QCA website.

Calculating an annual bill

Fixed costs + Cost of electricity + Membership fees – One-off sign up + GST (retailer daily imported bonuses, fixed charges (retailer usage guaranteed and x 365.25) charge x annual conditional consumption level) discounts

184

Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

APPENDIX F: SWITCHING CUSTOMERS (LOCATION) FULL POSTCODE DATA

Residential customers The table below shows all the location data provided by retailers for switching residential customers in 2016–17. Table 63 Switching residential customers, all postcodes, 2016–17

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4000 66 7,491 0.88% 4001 0 1 0.00% 4003 0 0 0.00% 4005 101 10,789 0.94% 4006 100 9,110 1.10% 4007 128 7,874 1.63% 4008 7 134 5.22% 4009 0 10 0.00% 4010 19 1,701 1.12% 4011 130 8,311 1.56% 4012 145 11,679 1.24% 4013 31 2,432 1.27% 4014 100 4,828 2.07% 4016 0 1 0.00% 4017 256 14,650 1.75% 4018 98 5,471 1.79% 4019 188 9,847 1.91% 4020 214 10,992 1.95% 4021 70 3,993 1.75% 4022 45 2,577 1.75% 4030 100 9,085 1.10% 4031 99 7,064 1.40% 4032 112 8,055 1.39% 4034 382 18,687 2.04% 4035 226 8,764 2.58% 4036 45 2,440 1.84% 4037 41 2,448 1.67% 4051 189 13,389 1.41% 4053 323 19,534 1.65%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4054 108 5,594 1.93% 4055 153 7,079 2.16% 4059 83 6,648 1.25% 4060 81 5,600 1.45% 4061 112 5,994 1.87% 4064 82 7,029 1.17% 4065 59 3,975 1.48% 4066 131 9,661 1.36% 4067 70 5,111 1.37% 4068 153 11,845 1.29% 4069 255 11,826 2.16% 4070 89 3,946 2.26% 4073 74 3,073 2.41% 4074 187 8,653 2.16% 4075 177 10,465 1.69% 4076 33 1,863 1.77% 4077 199 11,854 1.68% 4078 135 8,796 1.53% 4101 149 12,101 1.23% 4102 76 4,058 1.87% 4103 97 7,573 1.28% 4104 56 3,300 1.70% 4105 86 6,716 1.28% 4106 12 735 1.63% 4107 35 2,558 1.37% 4108 41 2,350 1.74% 4109 260 13,502 1.93% 4110 79 4,460 1.77% 4111 8 396 2.02% 4112 60 2,571 2.33% 4113 191 10,680 1.79% 4114 214 12,446 1.72% 4115 119 6,367 1.87% 4116 140 8,434 1.66% 4117 8 544 1.47% 4118 191 10,652 1.79% 4119 38 2,287 1.66% 4120 82 5,328 1.54%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4121 174 10,609 1.64% 4122 288 17,976 1.60% 4123 147 7,216 2.04% 4124 159 6,518 2.44% 4125 58 2,347 2.47% 4127 153 9,841 1.55% 4128 105 5,894 1.78% 4129 34 2,303 1.48% 4130 66 2,959 2.23% 4131 69 4,021 1.72% 4132 145 8,726 1.66% 4133 143 6,766 2.11% 4151 136 9,078 1.50% 4152 306 19,056 1.61% 4153 25 1,566 1.60% 4154 71 3,536 2.01% 4155 17 455 3.74% 4156 28 1,051 2.66% 4157 140 7,536 1.86% 4158 41 1,641 2.50% 4159 91 5,255 1.73% 4160 162 7,233 2.24% 4161 99 6,207 1.59% 4163 154 7,191 2.14% 4164 95 5,756 1.65% 4165 233 14,040 1.66% 4167 0 1 0.00% 4169 111 7,691 1.44% 4170 189 12,251 1.54% 4171 102 8,237 1.24% 4172 30 1,956 1.53% 4173 59 3,354 1.76% 4174 16 977 1.64% 4175 0 1 0.00% 4178 191 11,257 1.70% 4179 142 8,068 1.76% 4183 43 1,994 2.16% 4184 158 5,156 3.06%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4205 39 2,316 1.68% 4207 464 23,394 1.98% 4208 145 7,582 1.91% 4209 374 23,657 1.58% 4210 163 6,907 2.36% 4211 411 22,211 1.85% 4212 244 12,255 1.99% 4213 241 9,975 2.42% 4214 277 13,504 2.05% 4215 448 25,449 1.76% 4216 298 16,207 1.84% 4217 401 21,207 1.89% 4218 327 16,886 1.94% 4219 0 2 0.00% 4220 256 14,262 1.79% 4221 216 12,425 1.74% 4223 137 5,898 2.29% 4224 67 3,295 2.03% 4225 95 4,927 1.93% 4226 234 13,903 1.68% 4227 163 8,552 1.91% 4228 52 1,808 2.88% 4229 0 1 0.00% 4270 35 1,340 2.61% 4271 6 505 1.19% 4272 63 2,967 2.12% 4275 27 1,264 2.14% 4280 143 5,626 2.54% 4285 172 7,986 2.15% 4287 7 320 2.19% 4300 399 21,925 1.82% 4301 171 11,432 1.50% 4303 28 1,557 1.80% 4304 141 8,024 1.76% 4305 430 27,734 1.55% 4306 333 13,099 2.54% 4307 16 563 2.84% 4309 37 1,336 2.77%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4310 53 2,595 2.04% 4311 96 4,052 2.37% 4312 38 1,381 2.75% 4313 23 1,177 1.95% 4340 54 2,367 2.28% 4341 178 6,012 2.96% 4342 29 1,038 2.79% 4343 129 4,745 2.72% 4344 25 998 2.51% 4346 14 411 3.41% 4347 19 486 3.91% 4350 1 28 3.57% 4352 39 1,444 2.70% 4359 0 18 0.00% 4370 0 8 0.00% 4380 0 5 0.00% 4385 0 1 0.00% 4387 0 1 0.00% 4390 0 4 0.00% 4401 0 4 0.00% 4405 0 0 0.00% 4413 0 0 0.00% 4422 0 1 0.00% 4500 313 15,366 2.04% 4501 51 2,548 2.00% 4502 56 3,204 1.75% 4503 286 18,481 1.55% 4504 111 6,217 1.79% 4505 183 7,301 2.51% 4506 165 8,472 1.95% 4507 205 9,695 2.11% 4508 145 7,432 1.95% 4509 158 12,011 1.33% 4510 370 20,191 1.83% 4511 97 3,707 2.62% 4512 28 1,081 2.59% 4514 63 2,485 2.54% 4515 35 1,696 2.06%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4516 33 1,216 2.71% 4517 6 259 2.32% 4518 47 1,876 2.51% 4519 67 3,346 2.00% 4520 114 4,331 2.63% 4521 42 1,711 2.45% 4550 38 1,569 2.42% 4551 520 26,833 1.94% 4552 94 4,064 2.31% 4553 43 2,030 2.12% 4554 17 636 2.67% 4555 52 2,446 2.13% 4556 332 17,585 1.89% 4557 136 8,880 1.53% 4558 187 10,274 1.82% 4559 46 2,087 2.20% 4560 289 13,518 2.14% 4561 79 2,677 2.95% 4562 78 3,209 2.43% 4563 71 3,575 1.99% 4564 79 5,108 1.55% 4565 122 6,527 1.87% 4566 112 5,734 1.95% 4567 167 8,337 2.00% 4568 53 1,439 3.68% 4569 13 703 1.85% 4570 386 16,561 2.33% 4571 8 361 2.22% 4572 39 2,188 1.78% 4573 255 13,393 1.90% 4574 11 592 1.86% 4575 195 10,553 1.85% 4580 48 2,987 1.61% 9000 0 2 0.00% 2409 0 1 0.00% Source: Retailers' responses to part 2 of the QCA's information notice (unpublished).

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Small business customers The table below shows all the location data provided by retailers for switching small business customers in 2016–17. Table 64 Switching small business customers, all postcodes, 2016–17

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4000 38 1,457 2.61% 4005 15 592 2.53% 4006 52 2,221 2.34% 4007 10 475 2.11% 4008 3 211 1.42% 4009 11 483 2.28% 4010 15 442 3.39% 4011 10 552 1.81% 4012 7 469 1.49% 4013 6 378 1.59% 4014 18 882 2.04% 4017 13 656 1.98% 4018 0 66 0.00% 4019 12 950 1.26% 4020 8 693 1.15% 4021 6 311 1.93% 4022 0 115 0.00% 4026 0 1 0.00% 4029 0 0 0.00% 4030 20 507 3.94% 4031 6 294 2.04% 4032 1 451 0.22% 4034 22 1,343 1.64% 4035 4 243 1.65% 4036 0 74 0.00% 4037 0 51 0.00% 4051 16 802 2.00% 4053 16 1,057 1.51% 4054 1 283 0.35% 4055 6 179 3.35% 4059 4 326 1.23% 4060 5 304 1.64% 4061 6 136 4.41% 4064 21 943 2.23%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4065 3 152 1.97% 4066 14 468 2.99% 4067 1 130 0.77% 4068 8 459 1.74% 4069 15 357 4.20% 4070 0 62 0.00% 4073 2 321 0.62% 4074 8 742 1.08% 4075 12 583 2.06% 4076 11 709 1.55% 4077 11 517 2.13% 4078 0 103 0.00% 4101 26 1,290 2.02% 4102 14 758 1.85% 4103 4 326 1.23% 4104 2 163 1.23% 4105 12 649 1.85% 4106 8 636 1.26% 4107 10 431 2.32% 4108 24 1,116 2.15% 4109 10 642 1.56% 4110 30 1,036 2.90% 4111 0 5 0.00% 4112 0 60 0.00% 4113 5 396 1.26% 4114 12 906 1.32% 4115 2 131 1.53% 4116 4 172 2.33% 4117 0 72 0.00% 4118 14 671 2.09% 4119 12 737 1.63% 4120 11 531 2.07% 4121 7 355 1.97% 4122 20 1,062 1.88% 4123 8 207 3.86% 4124 2 160 1.25% 4125 1 111 0.90% 4127 19 1,564 1.21%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4128 9 274 3.28% 4129 15 664 2.26% 4130 1 72 1.39% 4131 14 448 3.13% 4132 6 225 2.67% 4133 5 242 2.07% 4144 0 1 0.00% 4151 5 529 0.95% 4152 14 506 2.77% 4153 0 34 0.00% 4154 0 117 0.00% 4155 1 77 1.30% 4156 0 49 0.00% 4157 36 1,308 2.75% 4158 0 91 0.00% 4159 4 192 2.08% 4160 5 319 1.57% 4161 0 87 0.00% 4163 9 825 1.09% 4164 1 122 0.82% 4165 9 459 1.96% 4167 0 0 0.00% 4169 15 580 2.59% 4170 27 759 3.56% 4171 7 478 1.46% 4172 15 550 2.73% 4173 5 394 1.27% 4174 5 296 1.69% 4178 9 770 1.17% 4179 7 255 2.75% 4181 0 1 0.00% 4183 2 201 1.00% 4184 5 149 3.36% 4200 0 1 0.00% 4205 1 161 0.62% 4207 40 2,265 1.77% 4208 10 614 1.63% 4209 15 845 1.78%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4210 11 316 3.48% 4211 43 1,695 2.54% 4212 14 928 1.51% 4213 5 539 0.93% 4214 43 2,472 1.74% 4215 35 2,658 1.32% 4216 12 882 1.36% 4217 24 1,868 1.28% 4218 13 920 1.41% 4219 0 12 0.00% 4220 51 2,896 1.76% 4221 6 475 1.26% 4223 16 676 2.37% 4224 3 167 1.80% 4225 9 448 2.01% 4226 13 729 1.78% 4227 8 506 1.58% 4228 0 66 0.00% 4230 0 0 0.00% 4270 0 66 0.00% 4271 0 18 0.00% 4272 10 413 2.42% 4274 0 1 0.00% 4275 5 168 2.98% 4280 8 346 2.31% 4285 24 1,084 2.21% 4287 1 130 0.77% 4300 17 825 2.06% 4301 2 228 0.88% 4302 0 1 0.00% 4303 0 103 0.00% 4304 9 437 2.06% 4305 47 1,760 2.67% 4306 10 760 1.32% 4307 9 202 4.46% 4309 25 382 6.54% 4310 6 429 1.40% 4311 27 607 4.45%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4312 6 173 3.47% 4313 7 322 2.17% 4340 8 326 2.45% 4341 16 601 2.66% 4342 21 337 6.23% 4343 41 1,096 3.74% 4344 2 238 0.84% 4346 0 38 0.00% 4347 4 211 1.90% 4350 0 0 0.00% 4351 0 2 0.00% 4352 4 130 3.08% 4359 0 11 0.00% 4370 0 0 0.00% 4380 0 0 0.00% 4386 0 1 0.00% 4390 0 7 0.00% 4500 26 1,961 1.33% 4501 5 436 1.15% 4502 2 127 1.57% 4503 9 469 1.92% 4504 7 417 1.68% 4505 6 325 1.85% 4506 2 348 0.57% 4507 11 627 1.75% 4508 6 369 1.63% 4509 10 701 1.43% 4510 28 1,559 1.80% 4511 1 137 0.73% 4512 3 149 2.01% 4514 7 269 2.60% 4515 6 255 2.35% 4516 2 80 2.50% 4517 0 33 0.00% 4518 4 131 3.05% 4519 6 416 1.44% 4520 8 290 2.76% 4521 1 183 0.55%

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcode Sum of number of Sum of total number of Proportion of customers customers switching customers in postcode switching (%) 4550 0 120 0.00% 4551 29 1,779 1.63% 4552 5 466 1.07% 4553 7 119 5.88% 4554 3 31 9.68% 4555 5 192 2.60% 4556 29 1,682 1.72% 4557 9 649 1.39% 4558 27 1,586 1.70% 4559 3 200 1.50% 4560 29 1,104 2.63% 4561 7 357 1.96% 4562 7 220 3.18% 4563 12 323 3.72% 4564 4 373 1.07% 4565 7 314 2.23% 4566 22 1,110 1.98% 4567 10 645 1.55% 4568 1 113 0.88% 4569 2 22 9.09% 4570 60 2,012 2.98% 4571 2 39 5.13% 4572 3 51 5.88% 4573 12 883 1.36% 4574 5 136 3.68% 4575 16 1,194 1.34% 4580 5 189 2.65% 4581 4 134 2.99% 4814 0 2 0.00% Source: Retailers' responses to part 2 of the QCA's information notice (unpublished).

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Queensland Competition Authority Appendix F: Switching customers (location) Full postcode data

Postcodes excluded from the analysis There were a number of postcodes provided by retailers that did not fall within of the Energex distribution area. These have been excluded from our analysis as they do not form part of the monitoring of SEQ; there were no switching customers in these postcodes and 10 customers in total. The table below shows all the location data provided by retailers for postcodes outside SEQ. Table 65 Postcodes excluded from analysis of switching customers

Postcode Postcode area Number of Total customers in switching postcode customers

9000 N/A 0 2

4881 and 4879 Koah, Kuranda, Mona Mona, Speewah 0 0

4878 and 4870 Yorkeys Knob, Barron, Machans Beach, Smithfield, 0 0 Caravonica, Holloways Beach Bentley Park, Centenary Park, Edmonton, Mount 4850 Peter, Tamarind Gardens, Wrights Creek 0 0

4815 Condon, Ganite Vale, Gumlow, Kelso, Pinnacles 0 0 Vincent, Murray, Heatley, Garbutt, Douglas, 4814 Cranbrook, Annandale, Aitkenvale 0 3 Townsville, Yarrawonga, Rowes Bay, Pallarenda, 4810 Castle Hill 0 1 Arkendeith, Carstairs, Down Riverm Inkerman, 4806 Keebah, Osborne, Wangaratta 0 0

4756 Finch Gatton, Netherdale 0 0

4745 Dysart, Norwich Park 0 2 Mackay, Paget, Hay Point, Glasstree Beach, 4740 Alexandra, Dundula, Glenella, Slade Point 0 0

4720 Emerald, Yamala 0 0

4717 Blackwater 0 1 Yeppoon, Rosslyn, Inverness, Cooee Bay, Maryvale, 4703 Bungundarra 0 0

4600 Cinnabar, Mudlo, Kilkivan, Oakview 0 1 Note: There were a further four postcodes reported that were not valid postcodes in Australia that have also been excluded from the location analysis. The excluded data amounts to four switching customers. The consumption data has not been amended for these exclusions as it is not possible to link the two data sets and remove the relevant customer data. Given the low number, we do not consider that the removal of these four switching customers will affect any conclusions. Source: Retailers' responses to part 2 of the QCA's information notice (unpublished).

197

Queensland Competition Authority References

REFERENCES

Reports

Australian Competition and Consumer Commission 2017, Retail Electricity Pricing Inquiry, preliminary report, September.

Australian Energy Market Commission 2015, 2015 Residential Electricity Price Trends, final report, December.

—— 2016, 2016 Residential Electricity Price Trends, final report, December.

—— 2017a, National Energy Retail Amendment (Notification of the end of a fixed benefit period) Rule 2017, consultation paper, September.

—— 2017b, National Energy Retail Amendment (Notification of end of fixed benefit period) Rule 2017 No. 2, November.

—— 2017c, National Energy Retail Amendment (Notification of end of fixed benefit period) Rule 2017, rule determination, November.

—— 2017d, 2017 AEMC Retail Energy Competition Review, final report, July.

Australian Energy Regulator 2011, AER (Retail Law) Performance Reporting Procedures and Guidelines, July.

—— 2014, Compliance and Enforcement: Statement of Approach, April.

—— 2015a, AER Retail Pricing Information Guidelines, August.

—— 2015b, Annual Report on the Performance of the Retail Energy Market 2014–15, November.

—— 2016, Annual Report on the Performance of the Retail Energy Market 2015–16, November.

—— 2017b, State of the Energy Market, May.387

Energex 2016a, Energex Tariff Schedule 1 July 2016 to 30 June 2017, June.

—— 2016b, Energex Annual Pricing Proposal 1 July 2016 to 30 June 2017, June.

Energy and Water Ombudsman Queensland 2017, Annual Report 2016–2017, September.

Essential Services Commission 2016, Interim Compliance and Performance Reporting Guideline for Energy Retail Licence Holders, June.

Essential Services Commission of South Australia 2017, Energy Retail Offers Comparison Report 2016–17, August.

Finkel, A, Independent Review into the Future Security of the National Electricity Market, June.

Grattan Institute 2017, Price Shock—Is the retail electricity market failing consumers?, Grattan Institute, March.

387 AER 2017a is in the 'Other' section of this reference list.

198

Queensland Competition Authority References

Independent Pricing and Regulatory Tribunal 2016, Review of the performance and competitiveness of the retail electricity market in NSW from 1 July 2015 to 30 June 2016, final report, November.

Queensland Competition Authority 2015a, Enforcement guidelines, October.

—— 2016a, SEQ retail electricity market monitoring 2016–17, scoping paper, October.

—— 2016b, Regulated retail electricity prices for 2016–17, final determination, May.

Queensland Government 2016, Queensland Government response to the Queensland Productivity Commission Electricity Pricing Inquiry, November.

Queensland Productivity Commission, 2016a, Electricity Pricing Inquiry, draft report, February.

—— 2016b, Electricity Pricing Inquiry, final report, May.

St Vincent de Paul Society 2016, Queensland Energy Prices July 2016, July.

Thwaites, Professor J, Faulkner AO, P & Mulder, T 2017, Independent Review into the Electricity & Gas Retail Markets in Victoria, August.

Legislation

Competition and Consumer Act 2010 (Cth).

Electricity Act 1994 (Qld).

Electricity Competition and Protection Legislation Amendment Act 2014 (Qld).

Electricity Competition and Protection Legislation Amendment Act 2014 (Qld) Proclamation (SL 2015 No. 32).

Electricity Competition and Protection Legislation Amendment Bill 2014 (Qld) explanatory notes.

Electricity Competition and Protection Legislation Amendment (Postponement) Regulation 2015 (Qld) (SL 2015 No. 33).

Electricity (General) Regulations 2012 (SA).

Electricity Industry Act 2000 (Vic).

Electricity Regulation 2006 (Qld).

National Energy Retail Law (Queensland) Act 2014 (Qld).

National Energy Retail Law (Queensland) Bill 2014 (Qld) explanatory notes.

National Energy Retail Law (South Australia) Act 2011 (SA).

National Energy Retail Regulations.

National Energy Retail Rules Version 7 [as in force at 30 June 2017].

Penalties and Sentences Act 1992 (Qld).

Penalties and Sentences Regulation 2015 (Qld).

Queensland Competition Authority Act 1997 (Qld).

199

Queensland Competition Authority References

Other

Australian Competition and Consumer Commission 2016, Ban on excessive payment surcharging, 26 May, https://www.accc.gov.au/update/ban-on-excessive-payment-surcharging.

AER 2017a, Former Urth Energy customers transferred to new retailers, media release, 2 February, http://www.aer.gov.au/news-release/former-urth-energy-customers-transferred-to-new-retailers.

Bailey M 2016a, New retailer brings more competition to SEQ electricity market, media release, Queensland Government, 15 September, http://statements.qld.gov.au/Statement/2016/9/15/new- retailer-brings-more-competition-to-seq-electricity-market.

Bailey M 2016b, Deregulation brings competitive electricity pricing to South-East Queensland, media release, Queensland Government, 1 July, http://statements.qld.gov.au/Statement/2016/7/1/deregulation-brings-competitive-electricity- pricing-to-southeast-queensland.

Click Energy 2016, Market Retail Contract Terms and Conditions, March.

Dodo Power & Gas, Energy Market Contract Terms and Conditions.

McArdle M 2014, Queensland Parliament, Record of Proceedings for 20 May 2014, p. 1552, http://www.parliament.qld.gov.au/documents/hansard/2014/2014_05_20_WEEKLY.pdf#page=38.

Queensland Government Gazette 2015, vol. 369, no. 36, 18 June.

Queensland Government Gazette 2016, vol. 372, no. 20, 31 May.

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