Tax on, Tax off: Electricity prices before and after the repeal of the carbon tax. Disclaimer. Alviss Consulting Pty Ltd

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1 Tax on, Tax off: Electricity prices before and after the repeal of the carbon tax November 214

2 Disclaimer The energy, tariffs and bill calculations presented in this report should be used as a general guide only and should not be relied upon. The information presented in this report is not provided as financial advice. While we have taken great care to ensure accuracy of the information provided in this report, it is suitable for use only as a research and advocacy tool. We do not accept any legal responsibility for errors or inaccuracies. Alviss Consulting Pty Ltd does not accept liability for any action taken based on the information provided in this report or for any loss, economic or otherwise, suffered as a result of reliance on the information presented. If you would like to obtain information about energy available to you as a customer, go to the relevant regulator s website or contact the energy retailers directly. Tax on, Tax off: Electricity prices before and after the repeal of the carbon tax May Mauseth Johnston, Alviss Consulting Canberra, 17 November 214 Alviss Consulting Pty Ltd This work is copyright. Apart from any use permitted under the Copyright Act 1968 (Ctw), no parts may be adapted, reproduced, copied, stored, distributed, published or put to commercial use without prior written permission from the Alviss Consulting. Tax on, Tax off: Electricity prices before and after 3

3 Acknowledgements This project was funded by grant from the Consumer Advocacy Panel (www.advocacypanel.com.au) as part of its grants process for consumer advocacy projects and research projects for the benefit of consumers of electricity and natural gas. The views expressed in this document do not necessarily reflect the views of the Consumer Advocacy Panel or the Australian Energy Market Commission. Several consumer groups and energy advocates have provided assistance through alerting their networks to this project and by forwarding energy bills, as well as other retailer communications, received by consumers. The assistance from the Victorian Council of Social Service, the South Australian Council of Social Service, the Consumer Action Law Centre, the Consumer Utilities Advocacy Centre, Camcare, St Kitts Associates and St Vincent de Paul Society Victoria has been much appreciated. The St Vincent de Paul Society is also an advocacy partner of this project. Gavin Dufty, Manager of Policy and Research, has provided input into this report and is the project s spokesperson. 4

4 CONTENT Foreword Executive Summary 9 1. About this project Retailers obligations, statements and communications Methodology and assumptions Retailers estimates based on substantiation statements Assumptions about consumption levels Data collection What bill calculations include/exclude Comparison of the impact the repeal has had on bills across the NEM Standing Market Jurisdictional analyses Bill impacts in the ACT Changes to ACT market Bill impacts in NSW Changes to NSW market Bill impacts in South Australia Changes to South Australian market Bill impacts in Tasmania Bill impacts in Victoria Changes to Victorian market 48 Tax on, Tax off: Electricity prices before and after 5

5 5.6 Bill impacts in Queensland Changes to Queensland market Issues regarding retailers strategies and behaviour Combining price increases with carbon tax adjustments Cost savings versus new prices Reduced discount on market Changes to tariff structures Changes to supply charges Allocation issues and potential windfall gains 61 Conclusion 64 6

6 FOREWORD St Vincent de Paul Society Victoria (SVdP Society) welcomes this study into the impact of the repeal of the carbon tax on electricity prices across the National Electricity Market (NEM). The SVdP Society has been a long-standing advocate for energy consumers in Victoria and nationally. The SVdP Society Victoria has over 7 members and volunteers. Across Victoria our members see what poverty looks like in a highly developed nation It is in this context that we are particularly concerned about the access to affordable essential services. In the last year alone, the SVdP Society has assisted over 12, households through providing over $1 million in direct assistance. A significant proportion of this assistance goes to pay for utility costs. It is in response to such needs that the SVdP Society decided to obtain a thorough understanding of changes to energy markets and prices, and the impact they have on household bills in order to increase community awareness about these changes and whether there are ways for households to reduce their bills. In partnership with Alviss Consulting, the SVdP Society has systemically monitored residential electricity and gas prices since July 21. This project, also commonly referred to the Vinnies Tariff-Tracking project, has produced numerous reports examining price changes as well as market trends, retail competition and regulatory shortcomings. 1 The cost of energy is significant to many Australian households, and especially to those on lower or fixed incomes. We therefore believe it is important to inform households about what is happening in energy markets, when and why prices go up (or down), and how they can minimise their own costs. At the same time, we believe that it is important to represent the interests of residential energy consumers in policy and regulatory debates, in order to influence policy decisions and regulatory arrangements that have an impact on households across the NEM. This study shows that while some households will receive significantly lower electricity bills in 214/15 due to the repeal, others will experience modest price decreases or none at all. We believe households should be made aware of which category they belong to as well as why. Furthermore, we encourage all consumers that can get a better price reduction from a different retailer to either call their existing retailer and ask for a discount or shop around. For example, we note the report s findings in relation to and Alinta, which have significantly increased their market offer discounts for new customers in some jurisdictions. We would therefore encourage existing and Alinta customers to request the same level of discounts that they are willing to offer new customers. 1 See Tax on, Tax off: Electricity prices before and after 7

7 The SVdP Society will endeavor to share the information provided in this report with our colleagues, as well as look for opportunities to engage with policy makers and regulators on issues we believe are important for our constituencies. Finally, in relation to the issue of potential non-distributed cost savings due to the repeal (section 7 of the report), we call on the Federal Government to conduct an inquiry into how these monies should be accounted for, collected and distributed. We do believe that the amounts in question can be significant and while we acknowledge that it could be impossible, and impractical, to identify the rightful owners of the monies, we do not believe that would justify any windfalls to entities within the energy supply chain or a revenue stream for the government. We are grateful to May Mauseth Johnston of Alviss Consulting for undertaking and involving us in this important study. Gavin Dufty Manager, Policy and Research, SVdP 8

8 Executive Summary Leading up to the carbon tax repeal, households were regularly reminded about how much this tax was adding to their energy bills and that savings of 9%, or $2 per annum for electricity alone, would occur if repealed. 1 This report shows that there is no magic number and household savings on electricity bills vary significantly. Average reductions For households using 6, kwh per annum, the average price reduction to customers on standing offer contracts across the NEM is $16 (or 8%). For customers on market offer contracts, the average price reduction is $11 (or 6%). 2 The jurisdictional differences are, however, significant. Table 1 below shows that households in the ACT (on the regulated rate) would receive a reduction of 12% while South Australian households would receive a 4% reduction. Table 1 Annual price reductions for households using 6, kwh/annum (single rate) by network area Standing / regulated % Standing / regulated $ Market % Market $ ACT - Actew 12% $165 1% $155 NSW - Essential 6% $145 6% $135 NSW - AusGrid 9% $16 5% $1 NSW - Endeavour 9% $16 5% $9 SA - SAPower 4% $11 4% $9 Tas - Aurora 9% $15 8.5% $14 Vic - Citipower 9% $17 6% $1 Vic - Powercor 8% $18 5% $95 Vic - SP Ausnet 8% $175 5% $9 Vic - Jemena 8% $175 5% $9 Vic - United 8% $175 6% $1 Qld - Energex 8% $175 7% $14 1 Australian Government, Department of Environment, Repeal of the carbon tax Impacts on households and businesses, Fact Sheet which estimated that electricity bills in would on average be $2 less than they would have been with a carbon tax in place at pages/59388d77-a9b5-4e4c-87b7-d732baf7c45b/files/factsheet-impacts-households-and-businesses_. pdf and Prime Minister Abbott s statement on 15 October 214: When this bill is passed, this Government estimates that power prices will go down by 9 per cent available at 3/tony-abbott-carbon-tax-gas-electricity-bills/ See section 4 for more detail about and calculations. Tax on, Tax off: Electricity prices before and after 9

9 Differences and more differences Jurisdictional differences were expected. A common explanation offered was that the carbon tax made up a smaller proportion of the total bill in Tasmania and South Australia than in, for example, the ACT. 3 Similarly, households actual consumption levels are unlikely to be the same as the assumed average. However, it is not as easy as looking at cost savings by jurisdictions, or across different consumption levels, to make sense of the average 1% (or $2) estimate. 4 Some of the reasons for this are: SS SS SS SS SS For jurisdictions with more than one network area there are significant differences to the reductions in bill depending on geographic location. In Victoria, for example, households in the northern part of inner city Melbourne (i.e. the suburb of Carlton) will experience an average decrease of 6% in 214/15. 5 Households in the inner northwestern suburb Flemington, on the other hand, will experience an average decrease of 5%. 6 There is a difference between standing (or the regulated rate in some jurisdictions) and market. The NEM average reduction to standing is 8% while the NEM average reduction to market is 6%. There tends to be a difference between jurisdictions where retail prices remain regulated and jurisdictions that have deregulated. That is, the difference in reduction between standing and market is typically less (albeit with some exceptions) in jurisdictions where the standing are still regulated. There are significant differences between the reductions offered by the various retailers within each network area or jurisdiction. Some retailers offer different cost reductions to existing customers compared to price reductions for new customers. Overall, most electricity customers have received price reductions, but for many households the price reduction is significantly lower than the averages estimated by the Government. An inadequately informed community Due to extensive and ongoing messages about the savings that the repeal of the carbon tax would create, it is understandable if the community s interest and expectations are high. Furthermore, as it is important that consumer confidence in energy markets does not erode further, we believe consumers need, and deserve, better information about the impact the repeal of the tax has had on their bills. We do not believe that the substantiation statements or the notices to customers that we have examined as part of this project adequately explain the impact the repeal has had on electricity costs. As illustrated by the three examples from, and Click below, the information provided in the substantiation statements was of a very general character. s statement: Residential electricity customers in Victoria/New South Wales/ South Australia A residential customer using 6,5 kwh of electricity a year will receive an approximate saving from 3 Several commentators have provided reasons for why the reductions will be lower in some jurisdictions compared to others. See for example, The Conversation, Carbon tax axed: how it affects you, Australia and our emissions, 15 July 214, The Canberra Times, Canberra to save more than most from carbon tax repeal, 19 July 214 and Carbon tax scrapped: how the changes will affect Australian consumers, 15 July 214. The claim that Tasmanians would receive the lowest reduction now appears to be wrong. 4 See Fn 1 5 Based on market in Citipower s network area. 6 Based on market in Jemena s network area. 1

10 the Carbon Tax Removal of $13 per year before any discounts and concessions are applied. 7 Energy s statement: The carbon tax was repealed with effect from 1 July 214. This has led to the reduction in our costs which we will pass on to our customers. We estimate that on average, each customer in each class set out below, will save approximately the following amount between 1 July 214 and 3 June (Note: only part of table included below) State Fuel Customer Type Reduction Vic Electricity Residential 8.2% Commercial 1.7% Gas Residential 6.4% Commercial 9.5% SA Electricity Residential 7.3% Click Energy s statement: Based on Click s assumptions regarding customer volumes, seasonal usage profiles, pay on time discounts and tariff types, the estimated annual saving of New South Wales (NSW) customers that is attributable to the removal of carbon tax repeal [sic] is 7.5% for residential customers. 9 In our view, both the Federal Government and retailers, through the Energy Retail Association of Australia, have a role to play in ensuring that consumers are adequately informed about the impact the repeal of the carbon tax has had on their bills. Strategic retailers and confused consumers One retail approach that made it impossible for consumers to identify the impact of the repeal on their bill was the application of price increases and carbon tax adjustments in the same price reset. One retailer s reason for delaying the introduction of price increases from July to September (when they adjusted for the repeal) was to ensure that customers only receive one price change. 1 In some cases, the bill impact of decreases to the consumption charges has also diminished due to increases to the fixed supply charge. While several retailers decreased their daily fixed supply charge for new market, others increased theirs., Red and Alinta all introduced significant increases to their fixed supply charges in some network areas. is the retailer with the greatest increases, with the fixed supply charge increasing by as much as $15 per annum in one Victorian network area (Jemena). In Victoria, South Australia and NSW, where the retailers set their own prices for standing as well as market, there may be a significant difference between the cost savings retailers pass through to existing customers and the price they offer new customers in a post carbon environment. For example: SS SS In Victoria, Alinta increased its pay on time discount for new customers to 25% while existing customers on Alinta s Fair Go offer continue to receive a 15% pay on time discount. In South Australia they increased the discount to 2% (up from 15%). s guaranteed discount off consumption charges for new customers went up from 22% to 26% in Victoria and from 7% to 13% in NSW. 7 s substantiation statement 8 s substantiation statement 9 Click Energy s substantiation statement 1 As per information on electricity bill from Alinta to customer in South Australia Tax on, Tax off: Electricity prices before and after 11

11 SS SS People Energy s pay on time discount (off consumption charges) increased from 25% to 35% in Victoria. increased its pay on time discount (off the bill) from 2% to 22% in Victoria and from 12% to 15% in South Australia., on the other hand, reduced its pay on time discount for new customers in NSW and Queensland. In NSW, s market offer (Daily Saver Plus) contained a pay on time discount of 1% in July 214. On the 4th of August, however, this discount was reduced to 7%. This is the same discount that is offered to customers post the carbon repeal price reset that took effect 15 September. In Queensland, s market offer (again the Daily Saver Plus) offered a pay on time discount of 5% in July 214. Post the carbon repeal price reset (that took effect 15 September), however, this discount was reduced to 3%. 11 Furthermore, while non-conditional discounts allow us to apply discounts to the retailers rates and determine whether households are paying more or less compared to before, conditional discounts (such as pay on time discounts) do not allow us to make that comparison. As raised in a report by Alviss Consulting and the St Vincent de Paul Society in December 213: Only the retailers know what their customers ended up paying but nothing would stop them from claiming that higher (conditional) discounts reflect the reduction in wholesale costs, lower network charges or the repeal of the carbon tax, to give a few examples. 12 It certainly looks like some retailers have decided to pass on lower wholesale prices, due to the repeal of the carbon tax, as conditional pay on time discounts. After all, the cost of late paying customers (e.g. the cost of debt) is clearly nothing near the 2% to 35% pay on time discounts now offered in South Australia and Victoria. Potential windfall gains The repeal of the carbon tax effects all energy consumed since 1 July 214. For customers on a quarterly billing cycle that do not have a smart meter it is, however, impossible to determine actual consumption post 1 July unless all meters were manually read on that day. As July is a particularly cold month in many parts of Australia, we can fairly assume that July energy consumption is higher than, for example, that of May. To examine this potential issue we analysed the bills of one Canberra household. They show that Actew has no knowledge about when the total consumption of 4,2kWh actually occurred within the three month long period. To estimate the daily consumption Actew simply divide total consumption by the number of days (89 in total). Then, in order to allocate what consumption occurred before and after the repeal, they multiply daily consumption by the number of days (in this case it was 67 days prior to 1 July and 22 days post 1 July). Based on this methodology, Actew determined that the customer had been overcharged by $29 for electricity consumed between 1 and 22 July 214 due to the repeal. However, if we assume that 4% of total consumption actually occurred post 1 July, the customer would be under compensated by $12. The question therefore becomes who keeps the windfall? 11 When we checked the fact sheets on Energy s website on 3 September 214, listed two sets of fact sheets, one was the current offer and the other was the offer that took effect on 15 September. The current offer stated that it took effect on 1 July 214 and contained a 3% pay on time discount. However, when we compared that to the Factsheet that we had downloaded from s website in July, appears to have altered the discount at a later stage. Our saved fact sheet also states that it was effective from 1 July and the pay on time discount is listed as 5%. 12 Gavin Dufty and May Mauseth Johnston, The National Energy Market Is there a devil in the retail? December 213, p 23 12

12 This would be a smallish amount for the individual household ($12) but Actew has approximately 15, residential electricity customers and $12 per household would equate to $1.8 million. If the customers do not receive the money someone else keeps it. The vast majority of homes, and small businesses, in the NEM do not have smart meters installed and someone in the supply chain, and most likely retailers, can end up with a significant windfall. This raises issues in relation to how these savings should be accounted for and how they could be redistributed (noting that it would be impossible to know which individual consumers used more kwh than the retailer estimated post 1 July 214). Lessons for the future We believe this study can provide a strong lesson for the implementation of future decisions where government policies directly impact on customers energy bills. Just as the GST is a line item on bills, other taxes, levies or policy decisions (such as mandated smart meter roll outs) should be itemised. We recognise that it may be more politically expedient to hide unpopular policy costs from the electorate, but as policies can and do change, itemising these costs are necessary to ensure market transparency and promote consumer confidence. Tax on, Tax off: Electricity prices before and after 13

13 1. About this project On 1 July 212 the federal government introduced a carbon tax that was based on a fixed carbon price for the first three years. On 17 July 214 the tax was repealed. The tax caused extensive public debate and its removal was a key election promise by the Coalition prior to the federal election in September 213. Figures estimated by Treasury show that household costs on average will be $55 less in 214/15 than they would nave been with the tax in place. 13 In relation to electricity, they have estimated that households will pay $2 less on average. 14 The purpose of this project is to produce a report that demonstrates the impact of the repeal of the carbon tax on residential electricity bills across the NEM. Furthermore, Alviss Consulting has partnered with the St Vincent de Paul Society to provide an independent consumer voice on the impact of the repeal, raise issues consumers should be aware of, and provide reasons and explanations for differences between jurisdictions. Structure of this report: Section 2 Discusses the relevant legislative obligations on energy retailers, as well as examining retailers substantiation statements and communications to customers. Section 3 Outlines the methodology, as well as assumptions, used for the analysis presented in this report. Section 4 Presents a comparative analysis of the impact the repeal has had on bills across the NEM. It analyses changes to standing and market using a fixed consumption level (6, kwh per annum) for all jurisdictions. Section 5 Contains the various jurisdictional analyses. For each of the six NEM jurisdictions, the analyses show changes to standing and market offer bills based on consumption levels typical for each jurisdiction. The purpose of this section is thus to investigate likely bill impacts for each jurisdiction, rather than comparing jurisdictional differences (as per section 4). Section 6 Discusses issues regarding retailers strategies and behaviours that emerged from the above bill analyses. Section 7 Examines allocation issues and potential windfall gains. It highlights that retailers do not have the ability to accurately determine exactly how much a household consumed before and after 1 July within a billing cycle. This can result in windfall gains for the retailers. Conclusion The concluding section of this report summarises reasons for why there is no magic number that can illustrate the impact of the repeal of the carbon tax on households. It also advice on how government policy decisions impacting on the cost of an essential service can be implemented more transparently. 13 Australian Government, Department of Environment, Repeal of the carbon tax Impacts on households and businesses, Fact Sheet available at a9b5-4e4c-87b7-d732baf7c45b/files/factsheet-impacts-households-and-businesses_.pdf 14 Ibid 14

14 2. Retailers obligations, statements and communications Since the Clean Energy Legislation (Carbon Tax Repeal) Act was passed on 17 July 214, electricity and gas retailers have had a legal obligation to pass through the cost savings attributed to the repeal of the carbon tax to consumers. The ACCC states that: All suppliers of regulated goods must pass through all their costs savings directly or indirectly attributable to the carbon tax repeal to customers. Suppliers of regulated goods that do not pass through all carbon tax costs savings are engaging in price exploitation, which is against the law. 15 Businesses that retail electricity and gas were thus required to provide a carbon tax removal substantiation statement to the ACCC of their estimated cost savings from repeal. 16 In addition, gas and electricity retailers were required to provide a statement for their customers. The substantiation statements had to be submitted to the ACCC by 18 August 214, as well as being published on their own websites. The deadline for communicating their statements for customers was 15 September 214. For their statements, retailers could choose whether they estimated cost savings for the 214/15 financial year as an average annual percentage or as an average annual price. The ACCC explained these two options as: Cost savings on an annual average percentage price basis are the average annual cost savings customers will receive expressed as a percentage of what the annual price would have been if the carbon tax remained on foot. Cost savings on an annual average dollar price basis means an average annual cost savings customers will receive now that the carbon tax has been removed compared to the situation if the carbon tax remained on foot. 17 However, the legislation did not stipulate what the percentage or dollar saving was coming off. 18 As such, some of the substantiation statements showed estimated percentage saving off bills (including fixed supply charges), others showed estimated dollar savings per annum, while others showed estimated reduction to the unit price of energy. Furthermore, as the legislation did not stipulate whether these cost savings should be GST inclusive or exclusive, some retailers made it inclusive and some made it exclusive, and the majority did not state whether the amounts were inclusive or exclusive. Table 2 shows the retailers estimated average cost savings for residential electricity consumers across the NEM. 15 https://www.accc.gov.au/business/carbon-tax-repeal/requirements-for-suppliers-of-regulated-goods 16 See https://www.accc.gov.au/business/carbon-tax-repeal/our-role-in-carbon-tax-repeal 17 https://www.accc.gov.au/business/carbon-tax-repeal/requirements-for-suppliers-of-regulated-goods/faq-for-suppliers-of-regulated-goods#what-is-nbsp-cost-savings-on-an-annual-average-percentage-price-basis- 18 Paragraph 2(a) under Division 2B of Clean Energy Legislation (Carbon Tax Repeal) Bill 214 Tax on, Tax off: Electricity prices before and after 15

15 Table 2 Retailers estimated average cost savings as per substantiation statements Vic SA NSW Qld ACT Tas * 8.9% 5.2% 7.8% 8.2% * 7% 6% 8% 8% 11.5% Energy Australia^ Red Energy ^^ 7.2% 6.3% 8.9% 8.3% 11% 2.41 c/kwh or $ c/kwh or $ c/kwh or $179 ^^^ $13 $13 $13 $17 Click 1.2% 7.5% 8.8% 12.4% 5.9% 8.4% 9.2% + 8.2% 7.3% 8.7% 8.6% Simply+ 8% 8% 1% 9% * ** c/ kwh or c/ kwh or c/ kwh or QEnergy % 9.11% 9.11% Alinta 2.29 c/kwh 2.29 c/kwh Actew* $222 People Energy c/kwh Aurora 9.4% Pasific Hydro+ Powershop#.24% *,, and Actew state that this is off customer s bills ^ Energy Australia s states that this is off customers bills and includes GST ^^ Red Energy states that the dollar saving is GST inclusive ^^^ states that these savings are based on an annual consumption of 6,5kWh + and Simply and Pacific Hydro s statements do not state what these discounts are off. Simply states that the amounts are GST exclusive (but the document contains no amounts). ** s estimated reductions are NEM wide and customers that are on contracts that did not contain a carbon pass through provision will not receive a reduced price ++ QEnergy estimated reductions are NEM wide. # Powershop stated that savings of approximately $146 per annum have already been passed on Apart from the somewhat confusing reporting format, most retailers provided plain statements stating estimated savings. The three examples from, and Click below illustrate the level of information that was typically provided in these statements. s statement: Residential electricity customers in Victoria/New South Wales/ South Australia 16

16 A residential customer using 6,5 kwh of electricity a year will receive an approximate saving from the Carbon Tax Removal of $13 per year before any discounts and concessions are applied. 19 Energy s statement: The carbon tax was repealed with effect from 1 July 214. This has led to the reduction in our costs which we will pass on to our customers. We estimate that on average, each customer in each class set out below, will save approximately the following amount between 1 July 214 and 3 June (Note: only part of table included below) State Fuel Customer Type Reduction Vic Electricity Residential 8.2% Commercial 1.7% Gas Residential 6.4% Commercial 9.5% SA Electricity Residential 7.3% Click Energy s statement: Based on Click s assumptions regarding customer volumes, seasonal usage profiles, pay on time discounts and tariff types, the estimated annual saving of New South Wales (NSW) customers that is attributable to the removal of carbon tax repeal [sic] is 7.5% for residential customers. 21 Four retailers, Powershop, Red Energy, and Pacific Hydro, however, provided more conditional statements. Powershop: Foreshadowed the repeal and passed on costs early Powershop stated: Not long after the introduction of the carbon tax, we identified that the carbon tax was unlikely to remain and that this would be reflected in lower costs to us. We then passed on actual and expected cost savings by introducing a guaranteed discount of at least 15% for all customers and absorbing the network increases we incurred in January 214. These savings represent approximately $298 per customer. We are therefore already passing on savings greater than the cost savings attributable to the carbon tax repeal. 22 Powershop customers also received an with the subject line: Powershop has increased your discount and has gone Carbon Neutral on 29 August The contained a link to the substantiation statement as well as stating that: Powershop is introducing bigger discounts, and for you that means a further 3% off. On 1 September 214 Powershop will introduce these new Carbonator products that provide a further 3% discount, beyond what was previously offered, to make our prices even cheaper. This further discount is guaranteed until at least 31 December 214, and we hope to permanently reduce our pricing after that. We always want to be offering the best deals in market s substantiation statement 2 s substantiation statement 21 Click Energy s substantiation statement 22 From Powershop s substantiation statement 23 As part of the data collection for this project, we encouraged consumer advocates to forward information about their retailers communications regarding the repeal (see discussion on methodology in section 3). 24 provided by Powershop customer Tax on, Tax off: Electricity prices before and after 17

17 On Powershop s website one customer provided her thoughts about Powershop s carbon tax statement: What rubbish! lol if you could afford to absorb the increases then you could afford to absorb them now! I don t think anyone ever expected the electricity companies to pass on the savings to their customers. Bit of a joke really. I wonder what the other companies have put in their statements? 25 The company s reply to the customer followed: Thanks for your comment. You seem to have assumed that Powershop simply absorbed the cost impact of the Carbon Tax, but it had real cost impacts for us and they re reflected in the numbers we have quoted in our statement. However it s also the case that, as the repeal of the Carbon Tax became more certain, those cost impacts began to reduce. Because Powershop is committed to offering our customers the best possible deals in market we started passing these savings through to our customers. We did this through introducing our guaranteed discounts and absorbing network costs. It s because of this commitment that we have announced this week a further 3% increase in our discounts. And remember those discounts apply to the whole bill. We remain committed to ensuring Powershop some of the cheapest Power in the market. After these discounts we believe we still will. But, because we have no lock in contracts or exit fees, the option to switch to another retailer is always available. 26 : Contracts without a carbon cost stated: Energy estimates that, on an average annual dollar basis, its cost savings that have been, are, or will be, directly or indirectly attributable to the carbon tax repeal and that have been, are being, or will be, passed on to its customers supplied through the National Electricity Market are: c/kWh for customers who have entered into contracts that include a carbon pass through provision; and zero for customers who have entered into contracts that do not include a carbon pass through provision. 27 One Victorian customer received the following message attached to his bill (via ): The Federal Government has passed the Carbon Tax repeal legislation. customers the choice of a clean energy plan that does not attract a carbon charge, or a standard energy plan which passed through a carbon charge Ibid 27 From s substantiation statement 18

18 The impact of the Carbon Tax Repeal legislation will depend on which energy plan customers are on. Visit for more information and how to identify your plan type. We are required to prepare a formal statement for customers and communicate it to you in accordance with the Carbon Tax repeal legislation. Our statement for customers will be available for you to read on our website at after 18 August 214 and no later than 15 September In the link to the statement for customers finally made it clear that its standard market offer product SmilePower did not attract a carbon charge: SmilePower customers have benefited from a clean energy product that did not attract a carbon charge. Our parent company, Hydro Tasmania, ensures that the equivalent amount of renewable energy used by SmilePower customers is fed directly into the National Electricity Market. There are no cost savings for SmilePower customers that are attributable to the Carbon Tax repeal. This means there will be no changes to SmilePower rates. 29 However, it was not necessarily obvious to customers that they did not pay for carbon if they were on Momumentum s SmilePower contract prior to the repeal. s Price and Product Information Statement (PPIS) did not reveal this, rather their PPIS effective on 29 November 213 simply stated: SmilePower is more than just renewable energy generated from nature. It is renewable energy with exceptional rates and flexibility of 12, 24 or 36 month contracts. So it s sure to make you smile. 3 Red Energy: Changed its price on 1 July Red Energy stated: Red Energy passed on to its electricity customers in Victoria an average saving of 2.41c/kWh from 1 July 214, being its forecast saving arising from a reduction of its wholesale cost of electricity due to the repeal of the carbon tax. 31 Similar statements were made in relation to gas as well as other jurisdictions (New South Wales and South Australia). Red Energy did change its rates on 1 July 214 (along with many other retailers) and existing customers received bills stating From 1 July your rates exclude the impact of carbon tax due to its repeal. 32 They also stated on their Price and Product Information statements available from 1 July 214 that: These electricity rates will remain fixed until 31 December 214 regardless of any changes to the wholesale energy market including any changes as a result of the repeal of the Carbon Tax from to customer 4 September pdf 3 Energy, Price & Product Information Statement, Victoria, 29 November Red Energy s substantiation statement 32 Bill provided by Victorian gas customer 33 Red Energy, Price and Product Information statement, Residential offer: Living Energy Saver, 1 July 214 Tax on, Tax off: Electricity prices before and after 19

19 Pacific Hydro: Envisaged the repeal Pacific Hydro stated: Pacific Hydro commenced retailing electricity to the small and medium sized business customers and residential customers in April 214. Energy Tariffs offered to customers between April and the Carbon Repeal date included a relatively small carbon component due to the expectation that the carbon price would be repealed. Following the carbon repeal, Pacific Hydro determined new carbon free tariffs for all customers in this class. 34 Strategic behaviour versus market transparency We believe the examples discussed above show that there is a fine balance between retailers right to strategically position themselves within a competitive market and ensuring that customers are adequately informed. July is typically a time when many retailers increase their prices, and the decision by Red Energy to include the cost saving of the repeal before the repeal actually occurred would have made Red Energy s offer look highly competitive compared to many other retailers. We note that Red Energy s Price and Product Information Statements did state that this price would not change if the carbon tax was repealed, but we question how easily consumers would have realised that the comparatively higher price charged by other retailers would only be temporary (and ultimately refunded). In relation to retailers claiming that their prices were already so low that they will not be able to pass on further cost savings, we question whether this is in line with the legislation. Even if the retailer can prove to the ACCC that they did absorb the carbon tax for a while (and that they foreshadowed its repeal) we do believe such strategies are questionable conduct. If Powershop, for example, had played it straight with its customers, it could have introduced the carbonator product prior to the repeal, making it clear that they would not pass on the cost of carbon to their customers., at least, included a line item on their smilepower bills that stated that the carbon cost for the bill was zero. That said, they could have easily been more transparent if they included this information in their product offerings as well. The result of all four retailers strategies is that consumers were not necessarily comparing apples with apples when shopping around for a better energy offer prior to the repeal. 34 Pacific Hydro s substantiation statement 2

20 3. Methodology and assumptions 3.1 Retailers estimates based on substantiation statements As discussed above, the retailers presented their estimated average bill reductions in various formats and with various degrees of intelligibility. In order to assess the retailers estimates (as per substantiation statements) against actual tariff changes, we have thus been required to interpret these statements and make certain assumptions in regards to what the discounts are off and whether amounts include or exclude GST. Table 3 Interpretation and methodology to calculate bill impacts based on retailers statements Their statement Our assumption / methodology Provided % off bill for each jurisdiction % discount applied to bill inclusive of GST for each network area Provided % off bill for each jurisdiction % discount applied to bill inclusive of GST for each network area Energy Australia Red Energy Provided % off bill for each jurisdiction Provided figure for carbon component (c/kwh) as well as ($/annum) for each jurisdiction Provided one combined figure for the carbon component ($/annum) for households using 6,5 kwh in Vic, NSW and SA, and a separate figure for Qld. % discount applied to bill inclusive of GST for each network area c/kwh figure deducted from initial consumption rate inclusive of GST in each network area (for jurisdiction with more than one network area, the jurisdictional average % was applied) $ figure deducted from initial bill (incl. GST) for customers with this consumption level in each network area (for jurisdiction with more than one network area, the jurisdictional average % was applied) Click Provided % reduction for each jurisdiction % discount applied to bill inclusive of GST for each network area Provided % off bill for each jurisdiction % discount applied to bill inclusive of GST for each network area Provided % reduction for each jurisdiction % discount applied to bill inclusive of GST for each network area Simply Provided % reduction for each jurisdiction % discount applied to bill inclusive of GST for each network area QEnergy Alinta Provided one NEM-wide figure for carbon component (c/kwh) to be applied where a carbon charge previously had been passed on Provided % reduction for NEM and Queensland Provided one figure for carbon component (c/kwh) in SA and Vic c/kwh figure deducted from initial consumption rate exclusive of GST in each network area (for jurisdiction with more than one network area, the jurisdictional average % was applied) % discount applied to bill inclusive of GST for each network area c/kwh figure deducted from initial consumption rate exclusive of GST in each network area (for jurisdiction with more than one network area, the jurisdictional average % was applied) Tax on, Tax off: Electricity prices before and after 21

21 Actew People Energy Their statement Provided figures (incl GST) for the carbon component ($/annum) for households using 8, kwh in each jurisdiction Provided one figure (c/kwh) for carbon component Our assumption / methodology $ figure deducted from initial bill (incl. GST) for customers with this consumption level c/kwh figure deducted from initial consumption rate exclusive of GST in each network area (for jurisdiction with more than one network area, the jurisdictional average % was applied) Aurora Provided % reduction for Tasmania As this reduction was passed through from 1 July, % discount applied to bill inclusive of GST as of January 214 Pasific Hydro Provided % reduction for each jurisdiction % discount applied to bill inclusive of GST for each network area Powershop Statement did not foreshadow any specific reductions No reductions calculated or applied Based on the assumptions and methodology outlined above, we applied the following % discounts to bills or usage components inclusive of GST. Table 4 Percentage discounts off bill or consumption used for the analysis presented in this report Energy Australia Vic SA NSW Qld ACT Tas 8.9% off bill and standing 7% off bill and standing 7.2% off bill and standing 5.2% off bill and standing 6% off bill and standing 6.3% off bill and standing 7.8% off bill and standing 8% off bill and standing 8.9% off bill and standing 8.2% off bill and 9.41% off usage for regulated offer 8% off bill for market and 9.41% off usage for regulated offer 8.3% off bill and 9.41% off usage for regulated offer 11% off bill 22

22 Red Energy Click Simply Vic SA NSW Qld ACT Tas Zero reduction for market and 9% off usage for standing 5.4% off bill and standing 1.2% off bill and standing 12.4% off bill and standing 8.2% off bill and standing 8% off bill and standing Zero reduction and 8.3% off usage for standing Zero reduction for market and 7% off usage for standing 5% off bill and standing 5.9% off bill and standing 7.3% off bill and standing 8% off bill and standing Zero reduction and 6.7% off usage for standing Zero reduction and 9.3% off usage for standing 5.8% off bill and standing 7.5% off bill and standing 8.4% off bill and standing 8.7% off bill and standing 1% off bill and standing Zero reduction for market and 8% off usage for standing 8% off bill for market and 9.41% off usage for regulated offer 8.8% off bill and 9.41% off usage for regulated offer 9.2% off bill and 9.41% off usage for regulated offer 8.6% off bill and 9.41% off usage for regulated offer 9% off bill for market and 9.41% off usage for regulated offer Tax on, Tax off: Electricity prices before and after 23

23 QEnergy Alinta Actew People Energy Aurora Pasific Hydro Powershop Vic SA NSW Qld ACT Tas 9.11% off bill and standing 8.9% off usage for market and standing 1% off usage for market and 1.9% off usage for standing Zero reduction and standing 9.11% off bill and standing 6.4% off usage for market and standing.24% off bill and standing 9.11% off bill and 9.41% off usage for regulated offer 11.3% off usage for market and standing 9.4% off January 214 bill for market and standing 3.2 Assumptions about consumption levels All bill impact analysis presented in this report is based on the single, or flat rate, tariff. Bill impacts for households with controlled off-peak load or a time varying tariff are thus not covered by this analysis. In order to compare the impact the repeal of the carbon tax has had on electricity bills across the NEM, this comparison (section 4 below) assumes an annual consumption of 6, kwh per annum. We note that this consumption level is representative for South Australia but lower than average in the ACT, Queensland, Tasmania, as well as most of NSW, and higher than average for Victoria. 24

24 The more detailed analysis investigates bill impacts within each of the jurisdictions. As this analysis aims to provide a better understanding of price changes due to the repeal of the carbon tax within each network area, we have used consumption levels that are representative for each jurisdiction. The following consumption levels have been applied: SS SS SS SS SS SS ACT: 8, kwh/annum NSW: 7,2 kwh/annum South Australia: 6, kwh/annum Tasmania: 9,6 kwh/annum Victoria: 4,8 kwh/annum Queensland: 8, kwh/annum 3.3 Data collection New tariff data has been collected on an ongoing basis between 18 July and 15 October 214. Most of the data has been sourced from retailers Price and Product Information Statements, as well as directly from retailers websites. Another information source used, was the statements available from the Australian Energy Regulator s Energy Made Easy website. In order to compare post repeal tariff data to prior to the repeal, we have used datasets collected through the Vinnies Tariff-Tracking Project. The latest update of the Vinnies Tariff-Tracker was based on tariffs available across the NEM in July 214, and these are the we have compared the post carbon prices to. In relation to South Australian standing, the Tariff-Tracker has not included all retail standing to date. The South Australian standing offer analysis is therefore only based on the incumbent retailer s standing offer (). 35 It is important to note that a methodology based on comparing retail has its limitations when it comes to comparing cost reductions for customers on market contracts. Offers are available to new customers and do not always reflect what existing customers pay. Collecting data about customers actual bills would have required an extensive survey beyond the scope of this project. We therefore decided to supplement the comparison of published market offer rates with as many actual bills that we could easily, and readily, collect. The bills, as well as other retailer communications to their customers regarding the repeal of the carbon tax received for this project, have thus been sourced through various consumer groups and their networks. In relation to customers on standing, or the regulated rate, on the other hand, the new rates published by the retailers will be the same rate as existing customers now pay. 3.4 What bill calculations include/exclude All bill calculations and amounts presented in this report are GST inclusive. Furthermore, as some customers have controlled off-peak load or a time varying tariff, it should be noted that all tariffs and bill calculations presented in this report are based on the single rate or flat tariff. Market offer discounts, guaranteed and/or conditional upon bills being paid on time, have been included in some of the market offer analysis (section 4.2) but other incentives such as Direct Debit discounts and welcome credits have not been included. Finally, the bill calculations do not include penalty fees for late payment or other contract conditions. 35 The South Australian market offer analysis, however, includes 12 retailers. Tax on, Tax off: Electricity prices before and after 25

25 4. Comparison of the impact the repeal has had on bills across the NEM 4.1 Standing An analysis of residential standing/regulated before and after the repeal of the carbon tax shows that ACT customers have received the greatest percentage decrease to their electricity bills when assuming an annual consumption of 6, kwh per annum. 36 However, the greatest saving occurs in Victoria and Queensland, where households on average save $175 per annum in electricity costs due to the repeal of the carbon tax. Households in South Australia receive the lowest reduction at just over $1 per annum (or 4.4%). Chart 1 shows decreases to the annual cost of standing/regulated post the carbon repeal for households using 6, kwh (single rate) per annum in all of the six NEM jurisdictions. 37 The columns show the annual amounts and the rhombus shaped markers show percentage decreases. Chart 1 Reduction to annual bills (standing ) by jurisdiction ACT NSW SA Tas Vic Qld $ % $ % Chart As NSW and Victoria consist of several network areas with different prices households within these jurisdictions have received different price reductions. Households in country NSW (Essential s network area) have only received a 6% price reduction compared to almost 9% in other parts of the state. In Victoria, households in central Melbourne (Citipower) have also received a price reduction of 9%, while the price reduction for households in eastern Victoria (SP Ausnet) is closer to 7%. 36 6, kwh per annum has been used to facilitate NEM comparison only. Households in the ACT, Tasmania and Queensland typically use more than this per annum while Victorian customers typically use less (due to the high penetration of gas). 37 For NSW and Victoria, the standing are calculated using the three incumbents/major retailers (, and Energy Australia) average standing as well as the average across all network areas. s standing have been used for South Australia while the regulated have been used for the remaining jurisdictions. 26

26 Chart 2 shows decreases (%) to annual standing/regulated post the carbon repeal for households using 6, kwh (single rate) per annum across the twelve NEM network areas. 38 The black line indicates the NEM average. Chart 2 Percentage decreases (standing ) by network area and NEM average ACT - Actew NSW - Essen8al NSW - AusGrid NSW - Endeavour SA - SA Power Tas - Aurora Vic - Ci8power Vic - Powercor Vic - SP Ausnet Vic - Jemena Vic - United Qld - Energex Reduc&on (%) Similarly, chart 3 shows dollar decreases to annual standing/regulated post the carbon repeal for households using 6, kwh by network areas and the NEM average. 39 It shows that the NEM average for households using 6, kwh per annum is a $16 reduction to the annual electricity bill while customers in Tasmania, South Australia and country NSW (Essential) will receive less than the average amount. 38 For NSW and Victoria, the standing are calculated using the three incumbents/major retailers (, and Energy Australia) average standing. s standing have been used for South Australia while the regulated have been used for the remaining jurisdictions. 39 Ibid Tax on, Tax off: Electricity prices before and after 27

27 Chart 3 Reduction to annual bill (standing ) by network area and NEM average ACT - Actew NSW - Essen8al NSW - AusGrid NSW - Endeavour SA - SA Power Tas - Aurora Vic - Ci8power Vic - Powercor Vic - SP Ausnet Vic - Jemena Vic - United Qld - Energex $ per annum Market Charts 2 and 3 above show that the average NEM reduction to standing offer bills is 8% or approximately $16 per annum. However, after many years of full retail competition, as well as the deregulation of retail in Victoria, South Australia and NSW many residential customers have been switching retailers and are currently on market. Charts 4 and 5 analyse average reduction to market (including market offer discounts) in each of the network areas. 4 As some retailers have more customers than others, it must be noted that these are average reductions offered by retailers and not average reductions received by customers. 4 These calculations are based on annual bills for households using 6, kwh per annum and include all market offer discounts (guaranteed and pay on time discounts) as per contract in July 214 (not per contract for new customers). The average bill reduction is based on 15 retailers in Victoria, 1 or 11 (depending on network area) in NSW, 12 in South Australia, 5 in Queensland, 2 in the ACT and 1 (Aurora s PAYG ) in Tasmania. As discussed in section 2, some retailers have not changed their market offer rates and if we exclude these retailers from the averages presented in charts 4 to 6, we get the following, and slightly higher, amounts and percentages: Essential ($15/6%), AusGrid ($11/6%), Endeavour ($1/6%), SA Power ($1/4%), Citipower ($115/7%), Powercor ($11/6%), SP Ausnet ($15/5%), Jemena ($15/6%), United Energy ($115/7%) and Energex ($16/8%). 28

28 Chart 4 Percentage decreases (market ) by network area and NEM average Chart 5 Reduction to annual bill (market ) by network area and NEM average ACT - Actew NSW - Essen8al NSW - AusGrid NSW - Endeavour SA - SA Power Tas - Aurora Vic - Ci8power Vic - Powercor Vic - SP Ausnet Vic - Jemena Vic - United Qld - Energex ACT - Actew NSW - Essen8al NSW - AusGrid NSW - Endeavour SA - SA Power Tas - Aurora Vic - Ci8power Vic - Powercor Vic - SP Ausnet Vic - Jemena Vic - United Qld - Energex Network (%) NEM Avg (%) Network ($) NEM Avg ($) Tax on, Tax off: Electricity prices before and after 29

29 Charts 4 and 5 above show that the average NEM reduction to market is 6% (or $11 per annum) and that the reductions are greatest in jurisdictions that still offer a regulated rate (and have fewer retailers). Furthermore, as illustrated by chart 6 below, the average reductions to market are typically lower than the average reduction to standing, with the exception of Essential s network area in NSW as well as Tasmania (where Aurora is the only retailer). Chart 6 Standing Vs. Market, reduction to annual bill by network area ACT - Actew NSW - Essen8al NSW - AusGrid NSW - Endeavour SA - SA Power Tas - Aurora Vic - Ci8power Vic - Powercor Vic - SP Ausnet Vic - Jemena Vic - United Qld - Energex Reduc&on % Standing Market

30 5. Jurisdictional analyses 5.1 Bill impacts in the ACT In the ACT, the annual bill for households using 8, kwh per annum has reduced by 1-11%. Chart 7 below shows that annual electricity bills for ACT households with this consumption level have reduced by $22 if they are on the regulated rate or Actew s market offer. Energy Australia customers have experienced a slightly lower reduction of $21. The black line markers in chart 7 show estimated changes to annual bills (based on retailers substantiation statements) and the columns show the actual change to annual bills post the carbon repeal. The calculations are based on households using 8, kwh per annum (single rate) and the two market do not include additional discounts. Chart 7 ACT: Estimated and actual change to standing and market Regulated Actew (market) (market) Actual Retail Changes to ACT market Pay on time discounts that are deducted from the consumption charges are common market offer features across the NEM. When the fixed daily supply charge as well as the percentage discount offered off consumption charges (either as a guaranteed discount or as a conditional pay on time discount) remain the same after the price reset, the bill reduction offer customers that receive these discounts becomes lower. In other words, while their overall bill would have been reduced since the repeal, the amount it is being reduced by is less. Chart 8 compares the difference between the annual bills based on rates available before and after the price reset, and it shows that Energy Australia s offer, which contains both a guaranteed discount and a pay on time discount, can produce a saving of less than $19 for customers using 8, kwh per annum Actew only discounts if customers bundle several products/services (e.g. gas, telephone etc.) with their electricity offer and these discounts have not been included in this analysis. Tax on, Tax off: Electricity prices before and after 31

31 Chart 8 ACT: Changes to market offer discounts - 17 Actew Actual excl discount Actual incl guaranteed discount Actual incl all discounts

32 5.2 Bill impacts in NSW The size of the reduction to NSW standing offer bills post the repeal vary significantly between network areas as well as retailers. The NSW electricity retail market was deregulated on 1 July 214 and the retailers now therefore set the standing offer price themselves. As discussed in section 4 above, customers in Essential s network have on average received lower bill reductions than customers in Ausgrid and Endeavour s areas. In the case of Simply Energy, however, the reduction is significant in both the Endeavour and the Essential network (they do not offer contracts in AusGrid s area). In Essential s area Simply s standing offer rates have reduced by over 1%. Energy, which is the host retailer in this network area, has reduced their offer by just over 5%. There are significant differences between the bill reductions in other network areas too. In AusGrid s network area, for example, s annual bill has reduced by 4.5% compared to s reduction by more than 1%. Note that Red Energy has not published new standing in NSW and that QEnergy does not offer contracts to customers in Essential s network. Chart 9 shows the percentage changes to annual bills for standing published post the repeal compared to July 214, based on households using 7,2kWh per annum (single rate). Chart 9 NSW: Change (%) to standing Red Energy Click Simply QEnergy EssenGal AusGrid Endeavour Charts 1-12 below compare actual reductions to NSW standing to the average reductions estimated by retailers in their substantiation statements. All of the comparisons are based on annual bills for households using 7,2 kwh per annum (single rate). As a general trend, price reductions are lower than the average estimate in Essential s area, while in AusGrid and Endeavour s areas the estimates vary between being higher and lower, depending on the retailer. Tax on, Tax off: Electricity prices before and after 33

33 Chart 1 Essential: Estimated and actual change to standing offer Red Energy Click Simply New bill Retailer esgmate Chart 11 AusGrid: Estimated and actual change to standing offer Red Energy Click Qenergy New bill Retailer esemate

34 Chart 12 Endeavour: Estimated and actual change to standing offer Red Energy Click Simply Qenergy New bill Retailer esgmate Changes to NSW market All retailers except for Red Energy have published new market offer rates. While it would be impossible to verify whether all retailers have passed these rates on to their existing customers, we would assume that this has occurred (see section 3.3 about data collection). An exception may be QEnergy, which has increased its published market offer rates for new customers since the repeal of the carbon tax. 42 Nonetheless, the comparison of NSW market before and after the repeal, shows the impact the removal of the carbon price has had on retailers prices (rather than costs to consumers). Chart 13 shows the impact the removal of the carbon tax has had on annual bills for households consuming 7,2 kwh per annum QEnergy s offer was collected from QEnergy s website (http://www.qenergy.com.au/what-are- Your-Options) and the tariffs listed under the Home Your Way offer (the only offer available) were used for this analysis. 43 Note that Simply and QEnergy do not have in all three network areas. The calculations for these market offer bills do not include additional discounts. Tax on, Tax off: Electricity prices before and after 35

35 Chart 13 NSW: Change (%) to market Red Energy Click Simply QEnergy EssenDal AusGrid Endeavour On average, the annual cost of electricity for households using 7,2 kwh per annum is now $18 less in Essential s network and approximately $13 less in AusGrid and Endeavor s areas. The columns in charts below show the reduction to the annual bill for the various market in each of the network areas (households using 7,2 kwh per annum). The black dots indicate the retailers estimated cost reductions for existing market offer customers. Note that did not envisage any reductions for existing customers on market that did not attract a carbon price prior to the repeal (the Smile Power product used for this analysis is one of those ). 44 Chart 14 Essential: Estimated and actual change to market offer Red Energy Click Simply New offer Retailer esgmate The calculations for these market offer bills do not include additional discounts. 36

36 Chart 15 AusGrid: Estimated and actual change to market offer Red Energy Click Qenergy New offer Retailer esemate Chart 16 Endeavour: Estimated and actual change to market offer Red Energy Click Simply Qenergy New offer Retailer esgmate Tax on, Tax off: Electricity prices before and after 37

37 As half of the NSW retailers included in this analysis offer a guaranteed discount or a conditional pay on time discount that are deducted from the consumption charges, the bill reduction offer customers that receive these discounts can be lower. While the overall bill may have reduced since the repeal, the actual reduction is lower compared to customers that do not receive a pay on time discount if the fixed daily supply charge as well as the percentage discount offered off consumption charges remain the same after the price reset. Charts below show the impact the repeal of the carbon tax has had on price reductions, excluding all discounts, including guaranteed discounts only and including guaranteed as well as pay on time discounts. Again the bill calculation is based on households using 7,2 kwh per annum (single rate). The charts show that s price reduction in a post carbon environment is significantly less for customers that pay their bills on time. This is the result of reducing its pay on time discount off consumption charges (from 1% to 7%) in their post carbon offer as well as reducing the consumption charges (for new and existing customers) while the fixed charges, that do not attract a discount, have remained the same. This effectively means that s post carbon market offer is only 4-5% less (depending on the network area) than it was when a price on carbon was in place. This issue is discussed in more detail in section 6.3 below., on the other hand, has increased its guaranteed discount off the consumption rates (from 7% to 13%), which makes their post carbon market offer price between 1 14% lower than before (depending on the network area). Chart 17 Essential: Changes to market offer discounts Red Energy Click Simply Actual excl discounts Actual incl guaranteed discouts Actual incl all discounts

38 Chart 18 AusGrid: Changes to market offer discounts Red Energy Click Qenergy Chart 19 Endeavour: Changes to market offer discounts Red Energy Click Simply Qenergy Actual excl discounts Actual incl guaranteed discouts Actual incl all discounts Actual excl discounts Actual incl guaranteed discouts Actual incl all discounts Tax on, Tax off: Electricity prices before and after 39

39 5.3 Bill impacts in South Australia The South Australian electricity retail market is deregulated and the retailers therefore determine the standing offer price themselves. 45 As discussed in section 4 above, customers in South Australia have on average received lower bill reductions compared to other NEM jurisdictions. As a result of the repeal, s standing offer has decreased by 4.4%. For households consuming 6, kwh per annum the annual electricity bill will be approximately $11 less than if the price on carbon had remained in place Changes to South Australian market All retailers except for Red Energy have published new market offer rates. While it would be impossible to verify whether all retailers have passed these rates on to their existing customers, we would assume that this has occurred (see section 3.3 about data collection). Nonetheless, the comparison of South Australian market before and after the repeal shows the impact the removal of the carbon price has had on retailers prices (rather than costs to consumers). Chart 2 shows the impact the removal of the carbon tax has had on annual bills for households consuming 6, kwh per annum. 46 Chart 2 SA: Change (%) to market Simply Alinta Qenergy Red Pacific Hydro On average, the annual price of electricity for households using 6, kwh per annum is now $1 less than it was prior to the repeal. The columns in chart 21 below show the reduction to the annual bill for the various South Australian market (households using 6, kwh per annum). The black dots indicate the retailers estimated cost reductions for existing market offer customers. Note that did not envisage any reductions for existing customers on market that did not attract a carbon price prior to the repeal (the Smile Power product used for this analysis is one of those ) Note: We have not been able to compare changes to the standing across retailers in SA due to limited pre carbon repeal datasets (outlined in the methodology section above). 46 The calculations for these market offer bills do not include additional discounts. 47 Ibid 4

40 For some of the retailers the significant difference between estimated cost reductions and new prices can be partly explained by increases to the fixed daily supply charge. Alinta s fixed supply charge, for example, increased by $32 per annum in their post carbon price reset. By taking account of the cost reduction due to the carbon repeal at the same time as they take account of potential non-carbon cost increases the retailer produces a final price where the effect of the repeal, and other cost components, cannot be readily identified. Alinta did pass on savings similar to the 2.29 cents/kwh they estimated in their substantiation statements, but the impact of the non-carbon related increase to the fixed supply charge reduced the impact of the 2.29 cents/kwh significantly. For South Australian Alinta customers that use 6, kwh per annum, the annual electricity bill is thus only $25 less than it was prior to the repeal. Chart 21 SA: Estimated and actual change to market offer Simply Alinta Qenergy Red Pacific Hydro - 5 New offer - 1 Retailer esgmate As half of the South Australian retailers included in this analysis offer a guaranteed discount or a conditional pay on time discount that is deducted from the consumption charges, the bill reduction offer customers that receive these discounts can be lower. While the overall bill may have reduced since the repeal, the actual reduction is lower compared to customers that do not receive a pay on time discount if the fixed daily supply charge as well as the percentage discount offered off consumption charges remain the same after the price reset. Chart 22 below shows the impact the repeal of the carbon tax has had on price reductions, excluding all discounts, including guaranteed discounts only and including guaranteed as well as pay on time discounts. Again the bill calculation is based on households using 6, kwh per annum (single rate). The chart shows that,, Energy Australia, Simply, QEnergy and s price reductions post the repeal of the carbon tax are lower for customers that pay their bills on time compared to customers that pay late. Alinta and, on the other hand, have increased their pay on time discounts for new customers. Alinta has increased its discount off the consumption charges from 15% to 2% and now a 15% pay on time discount off the bill (up from 12%). Tax on, Tax off: Electricity prices before and after 41

41 Chart 22 SA: Changes to market offer discounts Simply Alinta Qenergy Red Pacific Hydro Actual excl discounts Actual incl guaranteed discounts Actual incl all discounts

42 5.4 Bill impacts in Tasmania The Tasmanian electricity retail market opened up for full retail competition in July 214 but Aurora remains the only electricity retailer offering contracts to residential consumers. As Aurora s electricity prices decreased from 1 July, due to the expected repeal of the carbon tax, the Tasmanian price comparison is based on July 14 rates ( post repeal prices) and January 214 (pre repeal prices). 48 As a result of the repeal, Tasmania s regulated consumption rate for the single rate tariff (Tariff 31) has decreased by 8.5%. Unlike other jurisdictions, the fixed supply charge has decreased as well as the consumption charge. The fixed supply charge is now $27 less per annum compared to the January 214 rates. For households consuming 9,6 kwh per annum the annual electricity bill will be approximately $215 less than if the price on carbon had remained in place. Aurora also pay as you go (pre-paid) market and approximately 14.5% (or 33,16) of Tasmanian households are on a PAYG product. 49 Households on the standard PAYG offer will pay $2 less per annum since the repeal. The black markers in chart 23 show estimated changes to annual bills (based on Aurora s substantiation statement) and the columns show the actual change to annual bills post the carbon repeal. The calculations are based on households using 9,6kWh per annum. 5 Chart 23 Tas: Estimated and actual change to regulated and PAYG Regulated PAYG Standard New offer Retailer es=mate Aurora Energy, 213 Standing Offer Determination, Pricing Proposal Period 2, July June 215, p 3 49 OTTER, Energy in Tasmania - Performance Report , January 214, The PAYG tariff is a seasonal TOU tariff. We have allocated 4% of consumption to summer rates and 6% to winter. The time of week, and day, consumption assumptions are based on figures presented in OTTER, 213 Aurora Pay As You Go price comparison report, August 213. Note that our summer evening proportion is 1% less than that used by OTTER in order to ensure that it adds up to 1%. Tax on, Tax off: Electricity prices before and after 43

43 5.5 Bill impacts in Victoria All Victorian retailers except for Powershop and People Energy have gazetted new standing since the repeal of the carbon tax was passed. Standing offer electricity bills for households consuming 4,8 kwh per annum (a typical usage level for dual fuel households) have decreased by 5 12%, depending on network area and retailer. Chart 24 below shows the following standing offer price decreases in the five network areas: SS SS SS SS SS Citipower Between 6.5% () and 12% (Click) Powercor Between 5.5% (QEnergy) and 11% (Click) SP Ausnet Between 4% () and 9% (Click) Jemena Between 5.5% (QEnergy) and 9.5% (Click) United Energy Between 5.5% (QEnergy) and 11.5% () The Victorian electricity retail market is deregulated and the retailers therefore determine the standing offer price themselves. Consequently, the size of the reduction to Victorian standing offer bills post the repeal varies significantly between retailers. Chart 24 shows the percentage changes to annual bills for standing published post the repeal compared to July 214, based on households using 4,8kWh per annum (single rate). Chart 24 Victoria: Change (%) to standing Powershop Click Red Energy Simply Qenergy Alinta People Energy CiIpower Powercor SP Aus Jemena United Energy 44

44 Charts below show the annual amount standing offer bills, for households using 4,8 kwh per annum, have decreased by in each of the five network areas as well as the estimated amount based on retailers carbon price substantiation statements. It must be noted that the price reductions estimated by retailers were averages (across various network areas and tariff types) and assumptions about consumption levels were not included in these statements. The charts show that standing offer bills have decreased by a minimum of $1 per annum (QEnergy) and up to around $2 (Click). Among the three incumbent retailers, which have the majority of standing offer customers, bills have been reduced by between $12 and $17 per annum. s bill reductions are at the higher end while Energy Australia and are at the lower. Chart 25 Citipower: Estimated and actual change to standing offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New bill Retailer eshmate Tax on, Tax off: Electricity prices before and after 45

45 Chart 26 Powercor: Estimated and actual change to standing offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New bill Retailer eshmate Chart 27 SP Ausnet: Estimated and actual change to standing offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New bill Retailer esimate

46 Chart 28 Jemena: Estimated and actual change to standing offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New bill Retailer eshmate Chart 29 United Energy: Estimated and actual change to standing offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New bill Retailer eshmate Tax on, Tax off: Electricity prices before and after 47

47 5.5.1 Changes to Victorian market All retailers except for Powershop have published new market offer rates. While it would be impossible to verify whether all retailers have passed these rates on to their existing customers, we would assume that this has occurred (see section 3.3 about data collection). Nonetheless, the comparison of Victorian market before and after the repeal shows the impact the removal of the carbon price has had on retailers prices (rather than costs to consumers). Chart 3 shows the impact the removal of the carbon tax has had on annual bills for households consuming 4,8 kwh per annum. 51 It shows that the cost of electricity (for customers shopping around) typically is between 5% and 1% less than it was in July 214. While one retailer, QEnergy, has significantly increased its rates for new customers. As was the case for standing, the percentage decrease to market offer bills is typically greatest in Citipower s network and lowest in SP Ausnet s area. As discussed in section 2 above, Powershop, Red Energy and did not foreshadow price decreases offer customers due to the repeal of the carbon tax. New Red Energy and customers, however, will receive annual bills that are between 5 and 1% lower compared to customers that switched in July 214 (except for customers in SP Ausnet s are where the difference is less). In terms of QEnergy, we can only assume that existing customers on average received a price reduction of around 9% due to the repeal (as estimated by QEnergy). 52 Prices for new customers, however, have increased significantly since the repeal. 53 Chart 3 Victoria: Change (%) to market Powershop Click Red Energy Simply Qenergy Alinta CiGpower Powercor SP Aus Jemena United Energy 51 The calculations for these market offer bills do not include additional discounts. 52 Note that QEnergy s estimated average bill reduction is NEM wide (not Victoria specific). 53 QEnergy s offer was collected from QEnergy s website (http://www.qenergy.com.au/what-are- Your-Options) and the tariffs listed under the Home Your Way offer (the only offer available) were used for this analysis. 48

48 Charts below show estimated average change to annual bills (based on the retailers substantiation statements) and the actual difference between retailers July 214 rates and October 214 for households consuming 4,8kWh per annum for each of the five network areas. 54 On average, the annual price of electricity for households using 4,8 kwh per annum is now approximately $1 less than it was prior to the repeal. The columns in the below charts show the reduction to the annual bill for the various Victorian market (households using 4,8 kwh per annum). The black dots indicate the retailers estimated cost reductions for existing market offer customers. Chart 31 Citipower: Estimated and actual change to new market offer Powershop Click Red Energy Simply Qenergy Alinta People Energy New offer Retailer eshmate 54 The calculations for these market offer bills do not include additional discounts. Tax on, Tax off: Electricity prices before and after 49

49 Chart 32 Powercor: Estimated and actual change to new market offer Powershop Click Red Energy Simply Qenergy Alinta People Energy Chart 33 SP Ausnet: Estimated and actual change to new market offer New offer Retailer esimate Powershop Click Red Energy Simply Qenergy Alinta People Energy New offer Retailer esimate 5

50 Chart 34 Jemena: Estimated and actual change to new market offer Powershop Click Red Energy Simply Qenergy Alinta People Energy Chart 35 United: Estimated and actual change to new market offer 2 New offer Retailer eshmate Powershop Click Red Energy Simply Qenergy Alinta People Energy New offer Retailer eshmate Tax on, Tax off: Electricity prices before and after 51

51 As the majority of retailers did not change their fixed daily supply charge as a result of the repeal and most retailers offer additional discounts (including pay on time discounts) off consumption charges only, the difference to annual bills based on as of July 214 compared to as of October 214 is in some cases less for consumers receiving a pay on time discount compared to consumers who do not receive this discount.,, Energy Australia, Click, Simply and all lowered their consumption rates and kept the same fixed charges as well as market offer discounts in place. Charts 36-4 below show that the reduction in costs (shown as annual saving) can be significantly lower for consumers that receive pay on time discounts. Other retailers have changed the discount applicable to new customers post the repeal. has increased its guaranteed discount off consumption from 22% to 26%, is now offering 22% pay on time discount off consumption compared to 2% in July, and Alinta and People Energy have increased their pay on time discount off consumption by 1 percentage points (25% and 35% respectively). As existing customers will continue to receive the original (lower) discount, their savings will not be as high as those shown for market offer customers in the charts below. However, the charts do demonstrate that some of the retailers in Victoria are increasing their market offer discounts for new customers post the carbon repeal reset. Red Energy has not changed its market offer discount (1% off bills when paid on time) but as their post repeal offer contains higher fixed supply charges and lower consumption charges, the difference to the annual bill is marginally lower for pay on time customers with this consumption level. Charts 36-4 below show the impact the repeal of the carbon tax has had on price reductions, excluding all discounts, including guaranteed discounts only and including guaranteed as well as pay on time discounts. Again the bill calculation is based on households using 4,8 kwh per annum (single rate). Chart 36 Citipower: Changes to market offer discounts Powershop Click Red Energy Simply Qenergy Alinta Actual excl discount Actual incl guaranteed discount Actual incl all discounts 52

52 Chart 37 Powercor: Changes to market offer discounts Powershop Click Red Energy Simply Qenergy Alinta Chart 38 SP Ausnet: Changes to market offer discounts Actual excl discount Actual incl guaranteed discount Actual incl all discounts Powershop Click Red Energy Simply Qenergy Alinta Actual excl discount Actual incl guaranteed discount Actual incl all discounts Tax on, Tax off: Electricity prices before and after 53

53 Chart 39 Jemena: Changes to market offer discounts Powershop Click Red Energy Simply Qenergy Alinta Chart 4 United Energy: Changes to market offer discounts Actual excl discount Actual incl guaranteed discount Actual incl all discounts Powershop Click Red Energy Simply Qenergy Alinta Actual excl discount Actual incl guaranteed discount Actual incl all discounts 54

54 5.6 Bill impacts in Queensland As a result of the repeal, Queensland s regulated consumption rate for the single rate tariff (Tariff 11) has decreased by 9.41%. The fixed supply charge, of almost 92 cents per day, has remained unchanged. For households consuming 8, kwh per annum the annual electricity bill will be approximately $23 less than if the price on carbon had remained in place Changes to Queensland market Unlike some of the other jurisdictions, retailers have introduced very similar levels of price reductions for their market offer rates in Queensland. All of the retailers estimates produced savings of between $2 and $25 for households using 8, kwh per annum (8.3% reduction to bills). Furthermore, all new market offer rates deliver such discounts with the exception of, which has not published new market offer rates. Chart 41 shows the impact the removal of the carbon tax has had on annual bills for households consuming 8, kwh per annum. 55 Chart 41 Queensland: Change (%) to market. Click Chart 42 below shows estimated average change to annual bills (based on the retailers substantiation statements) and the actual difference between retailers July 214 rates and October 214 for households consuming 8,kWh per annum. 56 On average, the annual price of electricity for households with this consumption level is now approximately $2 less than it was prior to the repeal (or $23 if we exclude from the average). The columns in the below charts show the reduction to the annual bill for the various Queensland market (households using 8, kwh per annum). The black dots indicate the retailers estimated cost reductions for existing market offer customers. 55 The calculations for these market offer bills do not include additional discounts. 56 Ibid Tax on, Tax off: Electricity prices before and after 55

55 Chart 42 Qld: Estimated and actual change to new market offer Click New offer Retailer esdmate As in other jurisdictions, the annual saving to market with pay on time discounts are less post the repeal (due to lower consumption rates that the discounts apply to). s significant reduction (chart 45 below), however, is not just because consumption rates are lower. s pay on time discount has also decreased since July 214 (from 5% to 3%). The price for new customers, that will receive the 3% discount, is thus only 6.6% (which equates to $175 per annum) less than the pre carbon price. This issue is discussed in more detail in section 6.3 below. Energy Australia, on the other hand, has slightly increased its pay on time discount (from 6% to 7%) resulting in the post carbon price being the same for both existing and new customers. Chart 43 Qld: Changes to market offer discounts Click - 5 Actual excl discounts - 1 Actual incl guaranteed discounts Actual incl all discounts

56 6. Issues regarding retailers strategies and behaviour The above analyses of the impact the repeal of the carbon tax has had on electricity costs and prices in each of the NEM jurisdictions identified several key issues in relation to retailers pricing strategies and impacts on post carbon prices. This section discusses these in detail. 6.1 Combining price increases with carbon tax adjustments The clearest example of a retailer combining price increases with the cost reductions occurring as a result of the repeal in the same price reset is Alinta s approach. In October 214 bills from Alinta to their South Australian customers contained the following notice: Our Standing Tariffs for electricity will decrease on 8 September 214. The new tariffs take into consideration the removal of the carbon tax as well as the impact of increased network costs and operating costs. These increases have been delayed from the usual July pricing change cycle so that our customers only receive one price change, which will result in a reduction in their charges. 57 Alinta did reduce the consumption charges but they also increased the fixed supply charge by just over $3 per annum. The South Australian analysis above (section 5.3) showed that Alinta s annual bill would only be reduced by $25 for households using 6, kwh per annum. A low consumption household (using 4, kwh per annum), however, will not experience an overall bill decrease post the September 8 price reset because the increase to the fixed supply charge is greater than the value of the decrease to consumption charges. At the same time, Alinta increased its pay on time discount for new customers to 2% while existing customers on Alinta s Fair Go offer continue to receive a 15% pay on time discount. Had Alinta extended this offer to its existing customers, households using 4, kwh per annum that paid their bills on time could have seen an annual saving of $7 post the repeal of the carbon price instead of nothing. 6.2 Cost savings versus new prices In Victoria, South Australia and NSW, where the retailers set their own prices for standing as well as market, there may be a significant difference between the cost savings retailers pass through to existing customers and the price they offer new customers in a post carbon environment. Alinta s approach, discussed above (section 11.1), where new customers receive a 2% pay on time discount compared to the 15% awarded to existing customers is one example of a retailer where the impact of the carbon repeal manifests itself differently for bill reductions compared to the new price of electricity.,, People Energy and Energy Australia are also retailers that have increased discounts for new customers only. s guaranteed discount off consumption charges for new customers went up from 22% to 26% in Victoria and from 7% to 13% in NSW. This effectively means that for households using 6, kwh per annum, s electricity price post the carbon price reset has been reduced by $22 per annum for new customers in Victoria s Citipower area and $275 for customers in NSW s AusGrid network. At the same time, the cost saving for existing customers, with the same consumption level, is $16 in Victoria and $18 in NSW. Other examples include: 57 Information provided on bill to South Australian Alinta customer Tax on, Tax off: Electricity prices before and after 57

57 SS SS SS People Energy s pay on time discount (off consumption charges) increased from 25% to 35% in Victoria. increased its pay on time discount (off the bill) from 2% to 22% in Victoria and from 12% to 15% in South Australia. In Victoria, Alinta increased its pay on time discount for new customers to 25% while existing customers on Alinta s Fair Go offer continue to receive a 15% pay on time discount. Furthermore, while non-conditional discounts allow us to apply discounts to the retailers rates and determine whether households are paying more or less compared to before, conditional discounts (such as pay on time discounts) do not allow us to make that comparison. As raised in a report by Alviss Consulting and the St Vincent de Paul Society in December 213: Only the retailers know what their customers ended up paying but nothing would stop them from claiming that higher (conditional) discounts reflect the reduction in wholesale costs, lower network charges or the repeal of the carbon tax, to give a few examples. 58 It certainly looks like some retailers have decided to pass on lower wholesale prices, due to the repeal of the carbon tax, as conditional pay on time discounts. After all, the cost of late paying customers (e.g. the cost of debt) is clearly nothing near the 2% to 35% pay on time discounts now offered in South Australia and Victoria. Understandably, some retailers may wish to take advantage of a time when there is an increased focus on electricity prices to offer higher discounts to new customers. However, it also means that we cannot simply assess retailers new to estimate the impact the removal of the carbon tax has had on electricity prices. Similarly, we cannot entirely rely on changes to existing customers bills in order to assess the impact. 6.3 Reduced discount on market In contrast to the increase in market offer discounts for new customers discussed above (section 6.2), has reduced its pay on time discount for new customers in NSW and Queensland. In NSW, s market offer (Daily Saver Plus) contained a pay on time discount of 1% in July 214. On the 4th of August, however, this discount was reduced to 7%. This is the same discount that is offered to customers post the carbon repeal price reset that took effect 15 September. In their substantiation statement, estimated an average 8% reduction in cost for NSW electricity customers. Customers that signed up for s Daily Saver Plus in July 214 will presumably continue to receive the 1% pay on time discount for 12 months (which is the benefit term for this contract). For households using 7,2kWh per annum the new rates will produce a saving of between 6.5% and 8.1% depending on network area. For new customers, receiving a 7% pay on time discount however, the repeal of the carbon tax will only reduce annual electricity costs by 4% in Essential Energy s network area and 5.5% in the rest of NSW. 58 Gavin Dufty and May Mauseth Johnston, The National Energy Market Is there a devil in the retail?- December 213, p 23 58

58 In Queensland, s market offer (again the Daily Saver Plus) offered a pay on time discount of 5% in July 214. Post the carbon repeal price reset (that took effect 15 September), however, this discount was reduced to 3%. 59 In their substantiation statement, estimated an average 8% reduction in cost for Queensland electricity customers. Customers that signed up for s Daily Saver Plus in July 214 will presumably continue to receive the 5% pay on time discount for 12 months (which is the benefit term for this contract) and for households using 8,kWh per annum the new rates will produce a saving of 8.3%. For new customers, receiving a 3% pay on time discount however, the repeal of the carbon tax will only reduce annual electricity costs by 6.5%. 6.4 Changes to tariff structures In addition to changing their rates and discounts, retailers can also change the structure of the tariffs they offer. In Victoria, s smile power offer has changed from being an inclining block tariff to a declining block tariff. At the same time, the consumption threshold for the first block is lower than previously. This means that consumption charges have decreased significantly for households consuming more than 6 kwh/quarter. In some network areas, however, has significantly increased its daily fixed supply charge. 6.5 Changes to supply charges While a couple of retailers have decreased their daily fixed supply charge for new market, others have increased theirs. is the retailer with the greatest increases, with the fixed supply charge increasing by as much as $15 per annum in one Victorian network area (Jemena). Unlike other jurisdictions, Victoria s network charges do not change on 1 July every year (it changes on 1 January), which means there must be other reasons for these increases. Chart 44 below shows, Red and Alinta s annual increase to the supply charge in various network areas. 59 When we checked the fact sheets on Energy s website on 3 September 214, listed two sets of fact sheets, one was the current offer and the other was the offer that took effect on 15 September. The current offer stated that it took effect on 1 July 214 and contained a 3% pay on time discount. However, when we compared that to the Factsheet that we had downloaded from s website in July, appears to have altered the discount at a later stage. Our saved fact sheet also states that it was effective from 1 July and the pay on time discount is listed as 5%. Tax on, Tax off: Electricity prices before and after 59

59 Chart 44 Increases to the fixed supply charge $ per annum Red Alinta 2 Ci#power Powercor SP Aus Jen UE SA Power Essen#al AusGrid Endeavour 6

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