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General commentary
COTA Victoria and Seniors Rights Victoria welcome the opportunity to contribute to DEECA’s consultation on reforming prices and consumer protections for customers in embedded electricity and gas networks. We support the proposed direction of reform and, rather than commenting on the broader embedded network framework, this submission focuses on one cohort that requires particular attention: older Victorians living in retirement villages.
Retirement village residents share many of the challenges experienced by embedded network customers generally, but often face additional barriers arising from fixed incomes, long-term contractual arrangements, increasing reliance on heating and cooling, limited digital confidence, and reduced capacity to navigate complex energy systems. These factors mean that reforms that may be appropriate for the broader embedded network sector may not provide sufficient protection for retirement village residents.
This issue will become increasingly important as Victoria’s population ages. The number of Victorians aged 60 years and over is projected to grow significantly over coming decades, with retirement villages playing an increasingly important role in meeting housing demand for older people. Ensuring that embedded network reforms work effectively for this growing cohort should therefore be considered an important element of an equitable energy market.