Submissions

To: NZ Electricity Authority
Date: September 2024

Purpose

This submission’s primary purpose is to welcome the introduction of new mandatory protections for electricity consumers, particularly highlighting and addressing the significant issues faced by disabled people and medically dependent customers who experience energy hardship and poverty. DPA aims to advocate for clearer processes, stronger safeguards, and accessible communication within the electricity sector to ensure equitable service for vulnerable/at-risk consumers.

Summary of DPA submission

DPA has collaborated with Electricity Allies in advocating for this change, which will shift the balance in the electricity market towards customers. DPA stresses that consumer care is vital for the disability community, as many disabled people require a stable power supply while often facing significant energy hardship and poverty. Statistics show disabled people are more likely to live in cold, damp, mouldy homes requiring more heating/cooling than non-disabled people. Studies indicate disabled people and those with health conditions need to consume more electricity for warmth, cooling, and charging disability-related equipment, adding to their living costs. This often forces disabled people to choose between heating, eating, or doctor's visits. DPA agrees with the new outcomes, but recommends adding outcomes about consumers knowing their rights and being empowered to make complaints. DPA supports full monitoring of electricity usage by retailers to identify and support customers in hardship. DPA agrees with proposed operational improvements for protecting consumers experiencing payment difficulties, including requiring companies to visit customers before disconnection. DPA agrees that the benefits of mandating the guidelines outweigh the costs.
 
However, DPA raises concerns regarding the assessment process for medical dependency, citing an example where a member was unsure about providing medical records to verify their status, emphasizing the need for clarity on what information is shared. DPA is also concerned about a freeze in operating costs for the Ministry of Health and Health New Zealand related to the strategy's oversight.
 
Key Recommendation:

DPA recommends that power companies make their complaints and other communications accessible through providing, for example, information and forms in accessible formats including, New Zealand Sign Language, Easy Read, Braille, captioned video, Plain English and audio formats.
 
Supporting Statement 1:

DPA stresses that flexibility in communication is important for disabled people and D/deaf people who may prefer to receive information in accessible formats.
 
Supporting Statement 2:

All retailers and their frontline staff should have the ability to support D/deaf, deafblind, and disabled users of the New Zealand Relay Service.