Embedded Network Sub Meter Billing in the Spotlight

Energy Policy WA (EPWA) are proposing amendments to the Electricity Industry (Alternative Electricity Services) Amendment Bill 2023 that will include future regulations for people who use, operate or have an interest in embedded networks.

The EPWA process involves implementing a “learn by doing” phase of 6-12 months, with a Voluntary Embedded Networks Code of Practice. It is intended that the obligations contained in the Voluntary Embedded Networks Code will be used as a basis for developing and refining obligations in the Mandatory Alternative Electricity Services (AES) Code that is proposed to come into effect in early 2025.

This will include all properties that have a private electricity network, with submetering for lots and tenancies.

EPWA has just released a draft Voluntary Embedded Networks Code of Practice for feedback (feedback closing date 23 June 2023). This draft Code of Practice is aimed at providing consumer protections for customers of electricity embedded networks; however, it is important that strata managers are aware of the proposed changes and the work practice changes required to meet obligations.

The draft Voluntary EN Code of Practice outlines that an ‘Embedded Network Seller (ENS)’ will be nominated and be responsible for meeting the obligations in the Code of Practice.

A number of different business models of Embedded Networks are outlined in the draft Code of Practice, with many existing brownfield strata properties operating the ‘Self Managed Strata’ model. In this case, whereby a Strata Manager manages the complex on behalf of the Strata Company, it will be the Strata Company that would be the nominated ENS and will need to ensure its contracts with service providers (e.g. Strata Managers) allow it to fulfil it’s obligations.

There are a range of different proposed regulations outlined however the following is a brief summary of those items directly related to the new billing requirements for customers by the ENS;

  • An ENS must have a supply arrangement with each customer (tenant/owner) that outlines the tariff arrangements and fees and charges that may be payable by the customer (and when and how these can be varied);
  • An ENS must provide each customer with a written copy of a completed Disclosure Statement which outlines what an EN is, the name of the ENS and customer, if the electricity is measured by a separate meter or if not the method of calculating consumption and where the electricity bills will be received from e.g. strata manager;
  • That in the future each supply address has a meter (not a retrospective obligation);
  • An ENS must provide a customer on request, access to an interval meter (at the customer cost) or meter test (at the customer cost if meter test determines Meter is not faulty);
  • The ENS must issue a bill to the customer at least every 60 days unless the customer agrees but can not be longer than 100 days;
  • An ENS must retain billing data for at least 2 years; and
  • An ENS must provide the following information onto a bill; Supply address, customer details, meter identification number (if applicable), start and end date of supply period, number of days covered by bill, consumption or estimated consumption in units, applicable tariff, any fees and charges and total amount due, sufficient information to verify calculation of electricity charges, amount of arrears or credit, amount of fees or charges and details of that service, date by which bill must be paid, summary of applicable payment methods, statement advising the customer that assistance is available if customer is experience problems paying the bill, details of where to direct complaints, legal name of ENS and payment plans.

The draft Code of Practice outlines that the AES framework is not intended to be burdensome or create onerous costs for parties, while acknowledging that many ENS may already be providing most of the customer protections proposed.

Existing customers of Energy-Tec are aware that we already provide the professional advice, data and information required to meet these obligations and we can assist your ENS to make the transition through these proposed changes.

For the last 30 years, Energy-Tec has guided energy market self-regulation by industry expertise in meter reading, reconciliation and billing services.

With the spotlight now clearly on new code of practice requirements, and its implementation looming, now is the perfect time to review your embedded network billing arrangements to ensure it is meeting the billing and charging obligations, ensuring lot owners and tenants in your complexes are being fairly charged for their electricity.