Protecting consumers in digitized and multi-source energy systems

Abstract

This paper investigates if the consumer risks of digitized and multi-source energy systems are capable of being addressed under existing energy consumer protection frameworks. Two challenges are identified. First, under existing frameworks the decision about which entities are subject to consumer protection obligations is often binary and may not easily accommodate new energy products, business models, or supply arrangements. Second, the highly prescriptive and detailed nature of current frameworks are ill-suited to the changes occurring in energy markets that require policymakers to develop rules to mitigate consumer risks arising from a rapidly expanding group of products, sources and technologies. To address these challenges, we propose that frameworks adapt to be based around baseline rights for all consumers irrespective of how they source, manage, or consume energy. We also argue for greater reliance on co-regulation to develop, monitor, and enforce a series of codes to protect consumers from the risks of new energy products and services.