Submission to Electricity Distribution Code Review

This submission is based on the experiences of our members and clients living in retirement housing, who have embedded networks in their villages.

HAAG members report that they are often not provided with clear, concise information on what their Embedded Network is, how much it will cost and how that cost is calculated and then paid, and how that cost is incorporated into other costs in the park or village.

Many EN electricity prices are bundled into general ‘maintenance fees’ or ‘rental fees’ that are paid weekly, fortnightly or monthly. The specific electricity amount is not always obvious, and sometimes is actively not included.



  • Exempt sellers must provide EN customers with separate documentation outlining the cost-price and the on-sale price, any ‘deals’ the exempt seller is receiving, the individual costs or bill the EN customer is required to pay. EN costs must not be combined with any other costs such as rent or maintenance fees. Document should be a standardised and prescribed form that exempt sellers are required to provide.
  • All protections afforded to the exempt seller should also be afforded to the EN customers as they are the people whose lives are impacted directly. Similarly, the GSLS compensation should be forwarded onto benefit EN residents impacted.
  • Exempt seller must be transparent about the resident’s rights to change energy provider, and their ability to practically be able to do that. Documentation should be provided before a resident moves into their housing of what the exempt seller is willing and able to do to facilitate changing electricity providers, and if they are not able to do this, explicit indication of this lack of choice. Document should be a standardised and prescribed form that exempt sellers are required to provide.
  • Solar panels installed on resident-owned dwellings should be to the benefit of the resident who lives there. A percentage or fair figure of the solar energy collected should be deducted from the EN energy costs the resident is liable to pay each bill.
  • The outsourcing of the management of ENs to exempt sellers and their agents needs to be regulated and prescribed. Requirement such as these need to be standardised to protect those who are vulnerable, isolated, disempowered and ‘trapped’ in ENs that afford them no choice, control or protection