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Submission to the Economic Regulation Authority on the framework and approach for Western Power’s sixth access arrangement review

The purpose of this submission is to set out key concerns for electricity customers who are at risk of, or experiencing, energy stress and other forms of marginalisation. At this pivotal stage in the energy transition, it is critical that all stakeholders work together to ensure the shift to a decarbonised and modernised energy system is a just transition — one that corrects, rather than reinforces, the inequities embedded in current structures.

Without deliberate action, those who are already struggling risk being further disadvantaged as system changes unfold. This review presents a valuable opportunity to drive innovative and effective investment that advances equity and affordability.

WACOSS’ overarching position is that the AA6 framework and approach should ensure Western Power’s planning, services and tariffs are customer-centric, meaningfully prioritise affordability and equity, and are supported by accessible engagement and transparent reporting.

Summary of recommendations

WACOSS recommends that Western Power be required to:

  • Demonstrate prioritisation of affordability for electricity customers.
  • Explicitly assess the distributional impacts of their proposal across customer cohorts, including households on low income and those experiencing energy stress.
  • Provide clear justification where costs are recovered from all electricity customers, and explain who benefits and how.
  • Treat vulnerability to heat stress and other extreme weather events as a key factor in determining network reliability upgrades.
  • Identify priority customer cohorts (including households on low income, renters, and customers experiencing other forms of disadvantage) and explain how Western Power engaged them in the development of the proposal.
  • Demonstrate their consideration of customer engagement and feedback, with an accessible and appropriately detailed “you said / we did” approach.
  • Demonstrate development of innovative solutions to address the challenges electricity customers are facing.