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COMMENTS ON THE PROPOSAL
In
our submission to the Commerce Select Committee on the Electricity
and Gas Industries Bill in January of this year, we strongly recommended
that the gas industry come under the existing electricity complaints
scheme. Therefore, we support the Gas Industry Steering Group's
proposal for incorporation of gas complaints into the Electricity
Complaints Commissioner Scheme.
We
agree that the revised title of the Electricity and Gas Complaints
Commissioner Scheme should refer to Electricity and Gas, and not
Energy, so as to avoid possible confusion for consumers about what
is meant by the term energy.
The
Association is pleased to note that the additional code for gas
deals with dual consumer contracts where a company supplies both
electricity and gas to a consumer.
We
support the requirement in Schedule CA, Gas Consumer Code (of the
revised draft Constitution) for accessible, easily understood language
in the Code. A Code that is easy to read and to navigate will benefit
the consumer and our bureau volunteers, who provide information,
advocacy and support services to the public including on consumer
issues relating to electricity and gas.
The
Association supports clause CA19.2, which requires gas companies
to advise consumers on how to turn off their gas in an emergency.
The clause mentions the possible use of consumer contract, brochures
and advertisements to convey this advice to consumers. We suggest
that thought should be given to ensuring this information reaches
and is understood by consumers who are not proficient in the English
language, particularly in the written form. The Citizens Advice
service is used by many different groups within our society, including
new migrants to New Zealand. Through our contact with these groups,
we are aware of the need for important public information to be
conveyed in forms that are accessible to non- English speakers and
those for whom English is not their first language. Advice relating
to safety issues within the home, such as how to turn off the household
gas supply, must be conveyed to all consumers regardless of their
language skills.
We
support the requirement that the Electricity Company Council members
and the Gas Company Council members must be mindful of the need
for consistency, where appropriate, between the dispute resolution
protocols for both electricity and for gas (clause 7.11a). This
will be particularly important for aiding consumer understanding
of and trust in the dispute resolution processes. It is also important
for those acting in a support or advocacy capacity for consumers
such as our bureaux workers.
We
are pleased to note the requirement (CA14 re Billing) for dual energy
consumer contracts to itemise separately the amounts payable for
electricity and for gas. This will have the effect of increasing
transparency where this is not already standard practice and it
will assist consumers with their household budgeting.
Conclusion
The
Association welcomes the proposed Electricity and Gas Consumer Complaints
Commissioner Scheme and endorses the amendments to the Constitution
for the Electricity Complaints Commissioner Scheme.
The
Association recommends that thought is given to ensuring the safety
information referred to in clause CA19.2 is required to be presented
in forms that can be understood by consumers who are not proficient
in the English language, particularly in the written form.
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