Joint Submission to the Review of the AER exemptions framework for embedded networks: Draft Decision

This joint submission from SACOSS, the Tenants’ Union of NSW, and the Justice and Equity Centre responds to the AER’s Draft Decision on the exemptions framework for embedded energy networks. Drawing on over a decade of advocacy and consumer evidence, the submission highlights serious concerns about ongoing structural disadvantages for residents in embedded networks. It criticises the Draft Decision’s reliance on limited data and calls for a revised draft that properly weighs consumer harms, improves data transparency, ensures robust consumer protections—including family violence safeguards—and mandates consistent regulatory oversight. The submission puts forward eight clear recommendations to realign the framework with the principle that access to essential energy services should not be compromised by regulatory loopholes or business convenience.