Tough times are exactly when we must invest in what matters most.

When things are hard, it’s tempting to tighten our belts and batten down the hatches.

But that’s not how you build a strong, safe, thriving Victoria.

Every Budget tells a story about the state of our State — what we value, what we fear, and what we’re willing to walk past.

Right now, Victoria’s story sits against a backdrop of growing economic inequity and social fragmentation – fuelled by the realities of rising cost of living, the housing crisis, community safety concerns, reverberations of international conflicts and intensifying climate impacts. Our social and economic fabric is under real strain.    

Meanwhile, the public purse is under pressure. There’s lots of talk about debt, budget repair, fiscal austerity and ‘efficiencies’.

In this context, some might say that now is not the time to invest in tackling root causes of entrenched problems like housing insecurity, family violence, climate-related impacts, social cohesion or the sharp edge of poverty. Some might say that’s in the ‘too-hard basket.’

They’d be wrong.

Now is precisely the time for smart investments that prevent social and economic problems from escalating and compounding, or ideally from starting in the first place.

With the political will to prioritise what matters most, we can break vicious cycles of crisis-end spending, avoiding long-term costs through prevention and early intervention.

By investing in what will pay off in the long run, Victorians can have secure housing, good healthcare, and genuine safety and security in their families and communities.

And critical to this is Victoria’s community sector – the fastest growing industry in the State, whose workforce shows up every day for people doing it tough.

Community services are operating under immense pressure, with rising demand, a changing regulatory landscape and a highly feminised workforce carrying the emotional load of the state’s most difficult and complex social issues.

No austerity agenda can fix entrenched problems like housing insecurity, family violence, social cohesion or the sharp edge of poverty.

Our sector deserves respect, fair funding and industry development support to meet the challenges of our times and keep doing what Victorians rely on. 

If we want a stronger, safer, fairer Victoria, we must invest across the whole spectrum of support – from crisis response to long-term recovery – but especially in the early intervention and prevention efforts that stop harm before it takes root. And we must invest in a skilled, flourishing, future-focused community sector that delivers across that spectrum of support.

That is how we stabilise our communities.

That is how we strengthen our economy.

And that is how ensure the things that matter most are never pushed into the too-hard basket.

Juanita Pope
VCOSS CEO

The cost of energy represents a large portion of the cost of living for Victorians. These costs have increased over the long term, but particularly in recent years.

Energy is an essential service, one that people cannot live without. And yet, it is delivered through a privatised system, subject to market forces. And energy retailers often don’t adequately support people when they’re struggling to afford energy costs.

The Energy Retail Code of Practice (known among energy experts as the ERCOP) regulates the terms and conditions of energy contracts, the marketing of energy offers, and billing practices. Included in the ERCOP is the Payment Difficulty Framework, which sets the rules and minimum standards by which energy retailers are required to assist customers experiencing hardship.

On 30 September the Essential Services Commission (ESC) announced their Stage 1 Final Decision as part of their ongoing review of the ERCOP.

These ambitious reforms represent a big win for Victorian energy consumers, and for the community sector organisations whose advocacy helped achieve it.

Changes to the code include increased protections for energy consumers, including strong new measures to support customers struggling with costly bills.

These ambitious reforms represent a big win for Victorian energy consumers, and for the community sector organisations whose advocacy helped achieve it.

Because of the importance of the reforms to the sector and many of our clients, VCOSS has produced a briefing document outlining the changes, how they happened, what they mean and why they matter.

Download the briefing document below.

You can also read VCOSS’s submission to the review, and the Government’s announcement.

Joint Submission to the VDO Review 2025-26 Draft Decision

This is a joint submission made by the Victorian Council of Social Service (VCOSS), Brotherhood of St. Laurence, Consumer Action Law Centre, Council on the Ageing Victoria, Energy Consumers Australia, Financial Counselling Victoria, and Uniting. This group brings a deep knowledge of people’s experiences navigating the Victorian electricity market and the impacts of energy hardship and poverty. Collectively, we work towards a Victoria free from all forms of hardship, where everybody can experience genuine wellbeing. 

The Victorian Default Offer (VDO) is a crucial safeguard for consumers who face structural barriers to engaging with the electricity retail market. We strongly support the VDO’s continuing role in the Victorian energy market, and the Essential Services Commission’s (ESC) role in regularly reviewing and renewing the VDO. 

Consumer advocates are pleased to see that the ESC’s draft decision on the VDO for 2025-26 keeps electricity costs stable, on average. However, it does represent around 1 per cent average rise across the distribution zones during a cost-of-living crisis.  

While this is a better outcome for Victorian consumers when compared to other jurisdictions, where the Default Market Offer draft price increased between 2.5 per cent and 8.9 per cent, we do stress that consumers are still dealing with very high prices. Electricity prices have been increasing over time since the establishment of the VDO, and especially with the 2023-24 VDO which increased prices 25 per cent. We also note that while the average cost in the 2025-26 draft price is stable, in CitiPower’s distribution zone, consumers will face a rise of up to 5 per cent under the draft decision. 

On a positive note, we acknowledge that the ESC has adjusted the methodology for wholesale load profiles to exclude solar exports. We support this decision. This is in line with the VDO’s role as a consumption price, and the ESC’s remit to set an efficient cost stack. This decision helps contain rises to the VDO price. 

This submission is made at a time when high costs for essential services like electricity are causing severe financial hardship in Victorian communities. For many people supported by the community sector, incomes are simply not sufficient to cover expensive energy as well as the costs of other essentials, especially if they are living in poor quality housing that is difficult to heat and cool.  

The ongoing impact of high energy costs is that tens of thousands of Victorians are in energy debt. Social services report that community demand for assistance is at unprecedented highs. Meanwhile, large energy businesses make record profits. 

In this context, we encourage the ESC to consider the costs of pricing decisions holistically, and to centre the consumer in decisions, rather than businesses. This is especially important for vulnerable and low-income households, for whom costs and benefits are a required consideration for the ESC, under the Commission’s statutory obligations. 

We also urge the ESC to undertake deeper analysis of retail behaviours and seek more granular detail of operational costs and, where possible, make that information public. This would provide for greater scrutiny on retailer behaviour and help to address the information asymmetry experienced by consumer advocates representing Victorian households in processes such as the VDO review. 

Finally, we note that, although the VDO works as a crucial regulatory safeguard, it is ultimately a price calculated on the costs of an unfair and unaffordable market. As such, consumer advocates urge regulators and policymakers to investigate complementary measures above and beyond the VDO, such as a targeted social tariff, to deliver electricity to low-income households at a truly affordable rate. 

This submission includes case studies detailing the lived experience of electricity consumers who have been supported by community sector organisations. The names of individuals have been changed. 

VCOSS submission to the Building Electrification Regulatory Impact Statement

The Victorian Council of Social Service (VCOSS) strongly supports getting fossil gas out of homes. Electrification is the best pathway to decarbonising the residential sector, and efficient electric appliances are cheaper to run, healthier, and create fewer emissions. 

Historically, Victorian households were encouraged to connect to gas and use it liberally. Often this abundance led to the use of less efficient appliances, and the building of homes that were extremely energy inefficient – that is, difficult to cool in summer and difficult to heat in winter.  

Depleting gas fields, high demand, policy settings favouring export, and international market forces mean that gas is no longer a cheap source of energy for Victorians. Modern electric appliance technologies such as heat pumps are far more efficient than fossil gas alternatives. They are therefore cheaper to operate, consuming less energy for the same tasks. 

It is now also clear that burning fossil gas is a key contributor to greenhouse gas emissions that drive climate change. Meanwhile, our electricity network is increasingly based on renewable energy sources. As such, getting off gas is essential to reaching our net zero targets. 

There is also a growing body of evidence that burning gas in the home is damaging to health, with fugitive (unintentional) emissions linked to increased rates of asthma and respiratory illnesses, especially among children. As much as 12 per cent of all childhood asthma cases in Australia can be attributed to gas cooktops.¹ 

Victoria uses more fossil gas for residential and commercial purposes than other states, accounting for two-thirds of national household and commercial consumption, and three times more than the next highest user, New South Wales. ² In fact, Victoria is the only state where the residential use of gas is higher than industrial usage. Victoria is also the only state where fossil gas usage is higher than electricity usage in the homes.³ 

In this context, VCOSS has long supported the Victorian Government’s policy of gradual household electrification, and reversal of historic policies that encourage new gas connections. 

If planned well, electrification, as with all climate policies, has the potential to address many of the drivers of inequality in our economy, such as the quality and energy efficiency performance of housing. The reverse is also true: a poorly handled transition will entrench and exacerbate existing inequalities.  

Low-income households already spend a disproportionate portion of their income on energy bills. As such, any effort that assists low-income households to electrify their homes will see a significant reduction in bill stress. This is particularly true when costs for all of life’s basics are high, stretching household budgets from all angles.  

The government has a crucial role to play in ensuring all Victorians can access the benefits of electrification, as some households face structural barriers to electrifying their home. This includes the upfront cost of appliances, the potential costs of rewiring homes, differing rights over modifications to properties between owner-occupiers, renters and people in apartments, the costs of goods and services in rural and regional areas, and language and digital barriers. Often those that would benefit the most from electrification are those that face the most challenging barriers. 

These obstacles can be overcome only through government interventions. We cannot leave the energy transition to market forces.  

In this submission, VCOSS details its support for the Victorian Government’s proposed regulatory changes and recommends: 

• The Victorian Government lead the way with social housing retrofits. 

• Support for low-income households to benefit from electrification. 

• Phasing out gas cooktops. 

• Enacting strong enforcement and compliance measures, alongside proactive community outreach. 

• Planning long-term for the eventual end of fossil gas usage in the home. 

Alongside the proposed building electrification requirements discussed here, VCOSS is also a strong supporter of the Victorian Government’s proposed energy efficiency minimum standards for rentals.⁴ Taken together, these policies represent a significant and ambitious step forward in improving the quality, liveability, and affordability of housing in Victoria. 

VCOSS submission to the Building Electrification Regulatory Impact Statement

The Victorian Council of Social Service (VCOSS) strongly supports getting fossil gas out of homes. Electrification is the best pathway to decarbonising the residential sector, and efficient electric appliances are cheaper to run, healthier, and create fewer emissions.

Historically, Victorian households were encouraged to connect to gas and use it liberally. Often this abundance led to the use of less efficient appliances, and the building of homes that were extremely energy inefficient – that is, difficult to cool in summer and difficult to heat in winter.

Depleting gas fields, high demand, policy settings favouring export, and international market forces mean that gas is no longer a cheap source of energy for Victorians. Modern electric appliance technologies such as heat pumps are far more efficient than fossil gas alternatives. They are therefore cheaper to operate, consuming less energy for the same tasks.

It is now also clear that burning fossil gas is a key contributor to greenhouse gas emissions that drive climate change. Meanwhile, our electricity network is increasingly based on renewable energy sources. As such, getting off gas is essential to reaching our net zero targets.

There is also a growing body of evidence that burning gas in the home is damaging to health, with fugitive (unintentional) emissions linked to increased rates of asthma and respiratory illnesses, especially among children. As much as 12 per cent of all childhood asthma cases in Australia can be attributed to gas cooktops.[1]

Victoria uses more fossil gas for residential and commercial purposes than other states, accounting for two-thirds of national household and commercial consumption, and three times more than the next highest user, New South Wales. [2] In fact, Victoria is the only state where the residential use of gas is higher than industrial usage. Victoria is also the only state where fossil gas usage is higher than electricity usage in the homes.[3]

In this context, VCOSS has long supported the Victorian Government’s policy of gradual household electrification, and reversal of historic policies that encourage new gas connections.

If planned well, electrification, as with all climate policies, has the potential to address many of the drivers of inequality in our economy, such as the quality and energy efficiency performance of housing. The reverse is also true: a poorly handled transition will entrench and exacerbate existing inequalities.

Low-income households already spend a disproportionate portion of their income on energy bills. As such, any effort that assists low-income households to electrify their homes will see a significant reduction in bill stress. This is particularly true when costs for all of life’s basics are high, stretching household budgets from all angles.

The government has a crucial role to play in ensuring all Victorians can access the benefits of electrification, as some households face structural barriers to electrifying their home. This includes the upfront cost of appliances, the potential costs of rewiring homes, differing rights over modifications to properties between owner-occupiers, renters and people in apartments, the costs of goods and services in rural and regional areas, and language and digital barriers. Often those that would benefit the most from electrification are those that face the most challenging barriers.

These obstacles can be overcome only through government interventions. We cannot leave the energy transition to market forces.

In this submission, VCOSS details its support for the Victorian Government’s proposed regulatory changes and recommends:

• The Victorian Government lead the way with social housing retrofits.
• Support for low-income households to benefit from electrification.
• Phasing out gas cooktops.
• Enacting strong enforcement and compliance measures, alongside proactive community outreach.
• Planning long-term for the eventual end of fossil gas usage in the home.

Alongside the proposed building electrification requirements discussed here, VCOSS is also a strong supporter of the Victorian Government’s proposed energy efficiency minimum standards for rentals.[4] Taken together, these policies represent a significant and ambitious step forward in improving the quality, liveability, and affordability of housing in Victoria.

[1] Knibbs, L. D., Woldeyohannes, S. Marks, G. B. and Cowie, C.T. (2018), “Damp housing, gas stoves, and the burden of childhood asthma in Australia,” Medical Journal of Australia, 208: 299- 302.

[2] Infrastructure Victoria (2021) Towards 2050: Gas infrastructure in a net zero emissions economy; Department of Transport and Planning (2024) Building Electrification – Regulatory Impact Statement, p32.

[3] Department of Transport and Planning (2024) Building Electrification – Regulatory Impact Statement, p32.

[4] For the minimum standards see: Deloitte Access Economics and Department of Energy, Environment and Climate Action (2024) Minimum energy efficiency and safety standards for rental homes – Regulatory Impact Statement. For VCOSS’ response to the proposal, see: Victorian Council of Social Service (2024) VCOSS Submission on Energy Efficiency Minimum Standards for Rental Properties and Rooming Houses.

People are hurting. It’s time for a budget focused on care – and the care economy.

A note from VCOSS CEO Juanita Pope

In a time of constrained fiscal conditions and mounting social disunity, there’s one thing most of our state – indeed our country – can agree on: people are hurting.

The current cost of living is placing immense strain on Victorians. Many people are being pushed to the brink, an increasing number skipping meals just to pay the rent.
This is not a new phenomenon – it’s just more visible. Well before the cost-of-living crisis became a media talking point, 800,000 Victorians were living in poverty. The current situation is symptomatic of deep rooted social and economic inequality.

Now is the time for strong, compassionate, smart responses from government. And bold action on poverty and economic exclusion.

Governments make choices about how public funds will be spent. That’s what budgets are for. The choices that government makes – who it chooses to invest in – send a powerful message, especially to people who need support. If decisions are made that prioritise commercial interests over the wellbeing of people, this is not only socially and morally unsound, it’s economically shortsighted.

A truly prosperous economy is one that enables all citizens to thrive – that lifts them up when they are down. It’s an economy underpinned by robust, holistic foundational supports – things like housing, healthcare, good schooling, childcare, community connections and the skills to get a decent job and lead a fulfilling life.

Investing in these foundations – and in the services that provide them – is key to Victoria’s economic and social prosperity. Drip-fed, short term, siloed support will not cut it.

In 2025, Victoria needs a budget that values care and focuses on the care economy. When we invest in care and wellbeing, we unlock the potential for a more resilient, inclusive economy.

The organisations that deliver care and social supports for Australians – including health and human services, children’s early education and community development – represent the largest employing industry in the country. They offer enormous potential for economic and social returns.

As more Victorians turn to care services in hard times, Victoria should invest in the sector that has caring at its core. Investing in the care economy not only generates real jobs, but also builds a solid social foundation – both for Victorians who are hurting right now, and for future generations.

When we invest in care and wellbeing, we unlock the potential for a more resilient, inclusive economy.

Victoria’s investment in the care economy must be approached strategically. We need to ensure support for the workers who make the industry successful and sustainable. Boosted resources for workforce development, core operations and care infrastructure will ensure that the care economy remains a stable, sustainable driver of good jobs, social wellbeing and economic growth. This allows us to tackle both immediate needs and long-term challenges, like the ageing population and the escalating impacts of climate change.

It’s about priorities.

Compassionate and smart policy-making puts social equity and human wellbeing as its central tenets.

It’s time for leaders to return to the basics: alleviate poverty, provide essential services, help people and invest in care that works.

Only when we prioritise these fundamental pillars will we achieve an inclusive, sustainable economy that our society desperately needs.

Juanita Pope
VCOSS CEO

This is a joint submission made by VCOSS, Brotherhood of St. Laurence, Consumer Action Law Centre, Council of the Ageing Victoria, Energy Consumers Australia, Financial Counselling Victoria, and Uniting.

The Victorian Default Offer (VDO) has provided an important safeguard for consumers that are unable or unwilling to engage with the electricity retail market, and a key benchmark price for market offers. The VDO directly serves around 13 per cent of households and 20 per cent of small businesses, and since September 2020, operates as the maximum price for embedded networks (around 180,000 customers).[1] As the VDO is a benchmark, market offers tend to be priced below it, and so the VDO also indirectly influences the bills paid by all Victorian electricity users.

Broadly speaking, the VDO has been largely successful in its objectives, especially in eliminating unreasonably priced standing offers. The Victorian Council of Social Service (VCOSS) strongly supports the continued operation and regular review of the VDO.

Currently however, high costs for essential services like electricity are causing severe hardship among the cohorts that social and community services support. These organisations are experiencing unprecedented demand from Victorian households that are struggling to absorb mounting cost of living pressures.

This is critical context for the ESC’s deliberations. In this submission, we emphasise the need to recentre people in pricing decisions, put less emphasis on retailer profit margins, and more focus on the wellbeing of Victorians experiencing financial pressures limiting their capacity to pay for an essential service.

This is a joint submission made by VCOSS, Brotherhood of St. Laurence, Consumer Action Law Centre, Council of the Ageing Victoria, Energy Consumers Australia, Financial Counselling Victoria, and Uniting. This group brings a deep knowledge of people’s experiences navigating the Victorian electricity market and the impacts of energy hardship and poverty. Collectively, we work towards a Victoria free from all forms of hardship, where everybody can experience genuine wellbeing.

Household energy is an essential service that Victorians on low incomes struggle to afford, and because of high energy costs, many are accruing unmanageable amounts of debt.

The average energy arrears for customers who cannot pay for their ongoing usage when entering tailored assistance from their retailer is currently $1,145 for electricity, and $1,003 for gas. VCOSS understands from our members that cases of debts above $10,000 are often observed by energy support services. Consumer Action Law Centre recorded a debt of $34,102 for one energy contact to the National Debt Helpline in 2023.

These impacts are compounded by retailer practice. Community sector consumer advocates observe that retailers often fail to deliver adequate assistance to customers in payment difficulty. A primary concern raised by VCOSS members is that retailers do not adequately support people onto cheaper energy offers or check for and apply eligible concessions.

In this context, VCOSS welcomes the ESC’s proposed reform objectives for this phase of the Energy Retail Code of Practice (ERCOP) review – Energy and Climate Change Ministerial Council reforms. We are particularly pleased that the ESC has heard advocates’ calls to consider ways to require retailers to lower the ongoing cost of energy for households struggling with bills, and to explore options for automating some elements of this process.

Our submission has been written with input and support from VCOSS member organisations in the community sector, and from other energy consumer advocates.

Submission on the Energy Retail Code of Practice Review

As regulator of the energy sector, the Essential Services Commission (ESC) has demonstrated a commitment to significantly improving outcomes for Victorian energy consumers experiencing vulnerability. Measures like the Payment Difficulty Framework (PDF) have raised the standard of assistance that consumers are entitled to and ensured that disconnections are only ever a measure of last resort. Recent processes to align protections in other jurisdictions with the Victorian PDF show that the ESC has been leading the way. But we can still do better.

Household energy is an essential service. You cannot live without it, even if you are unable to pay for continued use and will accrue significant debt. Despite this, several factors including market failure have been allowed to push energy prices sky-high over several years. Often even with tailored assistance under the PDF, customers end up accruing unmanageable amounts of debt.

Compounding this, retailers are often failing to deliver adequate assistance to customers. VCOSS is consistently told that there is deep inconsistency between retailers and amongst retailer customer support staff in terms of the quality of assistance, the knowledge of staff, and the treatment that customers in energy hardship receive.

Structural barriers such as digital exclusion and language are poorly addressed by retailers, exacerbating the impacts of energy hardship. For victim-survivors of family violence, retailers often place barriers in the way of financial recovery and even customer safety, for example, by referring energy debts to debt collection agencies.

In this context, VCOSS welcomes this timely review of the Energy Retail Code of Practice (ERCOP).

Our submission has been written with input and support from VCOSS member organisations in the community sector, and from other energy consumer advocates. Uniting Vic.Tas and Ethnic Communities’ Council of Victoria are signatories to this submission.

EVENT SUMMARY

Three years after the introduction of Victoria’s new rental rules, the changes to the Residential Tenancies Act are ‘only just starting’ to make a real impact to renters’ lives.

This is the assessment from lead lawyer at Tenants Victoria, Ben Cording.

In the latest Renters’ Rights Rundown, Mr Cording told the forum that some of the biggest improvements from the legal changes are associated with the Equal Opportunity Act, which now covers renters.

“It creates a global awareness. So whenever you apply for a rental property, now they have to actually give you a full statement: ‘This is what discrimination is, these are what are protected attributes’.”

“It gives someone a much stronger position to say you’ve engaged in discrimination,” he said.

Mr Cording also deemed getting rid of no-fault evictions “a cracker” move, saying it has improved stability for renters.

The Tenants Victoria legal expert told the forum minimum standards have, according to some research, led to improvements in the housing being offered in the rental market, but renters are still struggling to assert their rights in a burning hot market, and many are a long way from realising the dream (and the essential service) of safe, stable and affordable housing.

“Has it had an impact? Absolutely, it has. But the pressure, all of this anxiety about being able to have an essential service, comes from supply. It comes from affordability and benchmarking.”

“So when we talk about the rent increase framework … there is no cap. We have no benchmark that refers to the hardship on the renter, which ironically we did in older legislation, in the old 1958 Act. There was ‘what’s going to be the impact on the renter?’ And we don’t have that anymore.”

“So, has it had an impact? Yes. But are we impacting the right spots? We’re only really just starting to look at them.”

Mr Cording provided practical tips for renters and support workers about topics including getting a first foothold in the rental market without any references, how the laws apply to people in social and public housing, and attending VCAT.

“The biggest challenge for people is that they’re scared to go [to VCAT], they’re scared of retaliation … There’s a whole bunch of baggage, legitimate baggage that we need to try and unpack and understand to get our clients to feel safe and even confident to get there.”

Other topics included how the new rules are operating in relation to:

• Evictions
• Pets
• Discrimination
• Rent increases
• Rent arrears
• Minimum standards
• Modifications
• Bonds
• Family violence
• VCAT

“We know that if people say yes, I have a dog, you don’t always find out why you don’t get your rental property. They don’t come back and say…  this is why you didn’t get. It doesn’t work like that, which makes it really hard for people.”

A full transcript of the session and a copy of Mr Cording’s presentation are available here.

VCOSS’s new report Renting in Victoria will be available soon: it’s a deep dive into the current realities of renting, with insights from community sector workers.

Joint submission to the Victorian Default Offer Review 2024-2025

Victoria’s Default Offer for electricity, or ‘VDO’, has provided an important safeguard for consumers that are unable or unwilling to engage with the electricity retail market, a key benchmark price for market offers and, since September 2020, a crucial maximum price for embedded network customers.

The VDO has also been successful in eliminating excessively priced standing offers from the market.

As a reference price, the VDO has made it easier for consumers to compare alternative market offers and deterred misleading discounting practices.

However, some changes are required to ensure the method used to calculate the VDO remains fair and fit-for-purpose.

It is unfair for customers on the VDO to have the costs passed on to them of acquisition channels (such as third-party comparison websites or telemarketing), retention teams, and marketing costs targeted at driving customer acquisition or retention.

VCOSS Submission to Ministerial Guidelines Relating to Payment of Rates and Charges

VCOSS supports the establishment of a standard set of guidelines for local governments to use when considering hardship relief on council rates. Households need better support when they’re having trouble paying rates. Having standardised guidelines would establish consistency across the state, support council staff in making decisions, and produce fairer outcomes for ratepayers experiencing hardship.  

To this end, VCOSS commends the Victorian Government for taking this important step to strengthen support for vulnerable households.  

However, VCOSS does not support the Draft Ministerial Guidelines (‘the Guidelines’) in their current form. In our view, they would benefit from further refinement, with the support of subject matter experts from the community sector.  

We call on Local Government Victoria to undertake urgent work with community sector organisations that have deep knowledge of vulnerable households (and the requisite technical expertise) to improve the Guidelines.  

The concerns that we are seeking Local Government Victoria to address with the sector are set out over the page. 

Aspects of the Guidelines that require further refinement in consultation with the community sector  

While the policy objective is to enact positive support for vulnerable households, the draft Guidelines are, in fact, currently written in a way that is paternalistic and conveys a judgemental attitude to households that struggle to pay their rates. Further, the draft Guidelines do not present an accurate definition of hardship or a best practice approach for providing support.  

The disconnect between the policy objective and the language and construction of the Guidelines will have implications for how frontline customer service staff engage with vulnerable members of the community. VCOSS anticipates a material negative effect on these households. 

VCOSS recommends that Local Government Victoria redraft the Guidelines to better reflect the approach laid out in the Initial Views provided to the Minister for Local Government by the Essential Services Commission (ESC).¹ 

The Initial Views state that a broad definition of hardship, covering both the notions of “hardship” and “financial hardship,” is best for encompassing the wide range of unique experiences that people who need support face.² As a place to start, the Initial Views recommend the Municipal Association of Victoria’s 2013 guideline: “the simplest definition of hardship is a customer or ratepayer who wants to pay but cannot.”³ The Initial Views further state that whatever the definition is, it is the need for understanding what it means to be in hardship that is central to a best-practice approach:  

In dealing with a ratepayer in hardship, the focus should be on understanding the ratepayer’s circumstances and what support can be provided, not on determining whether the ratepayer falls into a particular definition of hardship.⁴ 

VCOSS is concerned that the Guidelines, as they are currently drafted, do not reflect this advice.  

The definition in the Guidelines is narrow and needlessly complicated by splitting hardship into two categories of “hardship” and “financial hardship.” This is unnecessary and will only work to hinder the efforts of council staff who are tasked with enacting the Guidelines. 

VCOSS strongly urges that this section is removed from any redraft of the Guidelines. What goods and services individuals choose to spend money on is not an adequate indicator of financial security, and the unique circumstances a person in hardship faces might necessitate spending on many of the goods and services listed. 

The inclusion of this section in the definition propagates the paternalistic notion that financial hardship is the result of an individual’s personal failings. In reality, financial hardship is usually a consequence of structural barriers in the Australian economy. For example, insecure work and inadequate wages, and insufficient and highly conditional social security. 

By laying out a set of spending habits that disqualifies a person from being considered in hardship, the Guidelines will obscure diverse experiences of hardship, make the job of council workers harder, and restrict the self-determination of people struggling to pay rates. 

VCOSS also warns that including such a section in the final Guidelines will open the door to invasive surveillance by local government officials looking to verify if a ratepayer conforms to the definition.  

The ESC’s Initial Views were formulated through an extensive research process involving feedback from stakeholders including social service organisations and councils, and a desktop review of approaches to hardship support across different essential services sectors. VCOSS urges Local Government Victoria to revisit the Initial Views and redraft the Guidelines to better reflect that document.  

As part of the redrafting process, Local Government Victoria should consult with key stakeholders including social service organisations and community legal centres. 

Submission to the Banning Telemarketing Under the Victorian Energy Upgrades Program consultation

VCOSS supports the proposed ban on telemarketing under the Victorian Energy Upgrades (VEU) program.

Such a ban would represent a strong consumer protection against misconduct by marketing agencies employed by accredited VEU providers, a problem that is increasing in frequency. This would also bring regulation of VEU-related marketing into line with regulation of the energy retail market.

As stated in the consultation paper by the Department of Energy, Environment and Climate (DEECA), reported instances of misconduct such as persistent unwanted calls, abuse and pressure tactics, and misleading and deceptive conduct have been increasing over the 2020-2023 period. There were 1,645 complaints in 2022 alone, and likely many more that went unreported. 

To make matters worse, the Essential Services Commission and Australian Communications and Media Authority have reported that in these cases there are very few avenues for consumers to make a complaint and limited ability for regulators to enforce the VEU Code of Conduct or Australian Consumer Law. Consumers are not getting the proper protections that they are entitled to under the law. 

Markets like that created by the VEU program can be complex for many consumers to navigate. These challenges are heightened for some groups including older Victorians, those from newly arrived communities and those from culturally and linguistically diverse backgrounds, putting them at significant risk of predatory behaviour. 

As the VEU program has been created by the Victorian Government and forms an important pillar of the state’s efforts to reduce greenhouse gas emissions, the government must ensure that consumers are able to participate fairly and safely in the program. We welcome and acknowledge the Victorian Government initiating this consultation as a key step in strengthening consumer protections. 

VCOSS supports a ban on all telemarketing to customers of the VEU program.

We would also urge that the ban include doorknocking. We also call for the ban to include contacting previous customers of the VEU program by telemarketing and doorknocking.

Digital marketing (texts, emails, social media, websites) and direct marketing (stalls, leaflets, brochures, mailers) should be sufficient for accredited providers of the VEU program to advertise their products, as long as these forms of marketing follow the VEU Code of Conduct and conform to Australian Consumer Law.

VCOSS would prefer that this ban be put in place sooner rather than later, to ensure that customers are given greater protection from misconduct as soon as possible.

As noted in the DEECA consultation paper, previous bans of this kind have been put in place with a brief period of notice for providers, a three-month period for the Solar Homes program, and a six-month period for traditional energy retailers. We see no reason that a ban on telemarketing and doorknocking in the VEU program should be preceded by a notice period that exceeds three to six months, and our preference is three months. 

VCOSS supports the suggestion in the consultation paper that the Victorian Government continue or expand its existing marketing of the VEU program, to ensure continued uptake of energy efficient appliances by Victorian consumers.

FLAGSHIP RESEARCH

A whopping 14% of people eligible for a power concession Victoria are not claiming it.

The key reasons are lacklustre communications from energy companies, a lack of awareness among energy users and digital, literacy and language barriers.

This report – undertaken against a backdrop of a global energy crisis and skyrocketing
energy bills – identifies exactly who is missing out, why they’re missing out, and what should
be done to fix the problem.

Our research is based on a comprehensive survey and series of interviews with community sector workers (people who help people in energy and financial stress), and a fresh analysis of sector data.

Key findings include:

• Lack of awareness is the number one reason people are missing out on the energy
  concessions they’re entitled to. Households experiencing language and digital
  inclusion barriers are more likely to miss out.
• For people who do know about concessions, a range of process issues are creating
  barriers to access.
• Stigma is also a barrier for some households.
• Workers from diverse parts of the community sector – beyond the ‘ground zero’ of
  emergency relief and material aid – regularly encounter energy affordability,

Feedback to the Essential Services Commission (ESC) on its draft decision for the Victorian Default Offer (VDO) tariffs that will apply in 2023-24.

The VDO is a crucial safeguard for household consumers who are unable to engage in detailed comparisons of market offers for an essential service. Uncertain economic times underscore its importance. 

In this submission, VCOSS highlights the damaging impact that the currently proposed increase will have on Victorian households.  

VCOSS is not convinced an increase of the magnitude proposed by the ESC is justified.  

Our submission identifies VDO cost-stack components where VCOSS believes the key assumptions or proposed regulatory choices should be subject to additional stress-testing by the ESC. 

Our submission also identifies cost-stack components where VCOSS believes the ESC should take another look at the impact of the proposed cost increase on consumers – noting that, under the price-setting methodology, for each part of the cost-stack there is a price range. It is VCOSS’s view that the ESC should always tend towards the lowest end.

Submission on the Protecting consumers of distributed energy resources consultation paper

VCOSS welcomes the opportunity to contribute to the Victorian Department of Environment, Land, Water and Planning (DELWP’s) current thinking on the consumer protection dimensions of the evolving landscape for distributed energy resources (DER) in Victoria.

Given DELWP’s acknowledgement that this consultation paper serves as the start of an exploratory phase into potential next steps for reform, VCOSS’ focus at this time is on articulating both some areas for immediate actions, alongside our foundational priorities in this evolving area.

All homes should be energy efficient and healthy so Victorians can be thermally comfortable and save money on energy bills.

The Victorian Energy Upgrades (VEU) program is working towards this in tandem with rental minimum standards, social housing retrofits, the Home Heating and Cooling Upgrades program, and more.

VCOSS supports adding home energy rating assessments to the VEU program. The activity provides households with tailored advice about improving thermal comfort and the subsidy will increase uptake.

Our concern is that the assessments will still be unaffordable for low-income households and the upfront cost will disincentives renters. This is problematic because Victorians experiencing disadvantage are more likely to live in homes with poor energy efficiency and have the most to gain from the new activity.

Submission to the Essential Services Commission (ESV) on the Victorian Default Offer (VDO) draft determination 2022-23

The VDO is an important safeguard for consumers who are on retailers’ standing offers and those who are unable or unwilling to engage in detailed comparisons of current market offers.

By establishing a simple and independently-assessed retail electricity price for all residential consumers, it is also key reference point for those households who are able to “shop around”.

VCOSS strongly supported the development and introduction of the VDO. As we noted in our preliminary observations on 31 March at the ESC’s public forum on the current draft decision, the VDO now provides a vital direct safeguard for over 200,000 households on standing offers. In addition, as the maximum price that embedded network operators may charge residential customers in relevant caravan parks, retirement villages and apartment buildings, the VDO is also serving an important consumer protection for a further 140,000 households in potentially highly vulnerable circumstances.

Feedback to the Essential Services Commission (ESC) on its draft decision for the Victorian Default Offer (VDO) tariffs intended to apply from 1 January 2022.

The VDO is a key safeguard for consumers who are on retailers’ standing offers and those who are unable or unwilling to engage in detailed comparisons of current market offers. It also provides a credible reference point for those households who are able to “shop around”.

As an important equity measure in the retail market, VCOSS welcomes the headline anticipated saving of five percent on VDO-compliant average bills in the first half of 2022.

VCOSS also notes that, with the temporary bad debt allowance removed, the final calculations of this household saving may be even greater.

Staying true to reform goals

VCOSS supports the ESC’s decision to manage the re-alignment of the VDO with the regulated prices of electricity distribution network charges by applying a six-month period for this VDO regulatory period.

Given this shorter period, VCOSS also supports the ESC applying the same underlying methodology in setting 2022 VDO tariffs as it has adopted in past years.

In this vein, VCOSS would encourage a consistent approach to using 12-month forecasts and averages on the wholesale cost and Victorian Energy Upgrade components, consistent with the ESC’s observation in the draft decision that retailers are better placed than consumers to manage short-term price risks.