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Administrative burdens as a form of energy injustice: investigating energy hardship support pathways and dead ends in NSW

Environmental Politics and Policy
Public Policy Studies
Political Organizations and Institutions
Lee White
University of Sydney
Lee White
University of Sydney
Thea Bray
Justice and Equity Centre
Fred Marsh
University of Sydney

Abstract

Administrative burdens in accessing energy hardship support can represent injustices in distribution, procedure, and recognition. To understand the individual’s experience of attempting to access support, we review multiple levels of policymaking documents to trace the set of steps that a person seeking support would need to follow. This encompasses learning costs (finding information), compliance costs (proving eligibility), and psychological costs (potential stress points). We also identify the dead ends that they may encounter in their journey seeking support. Further, we interview 12 organisations involved in the provision of energy hardship supports, to understand burdens that may not be apparent from document review. We find that the potential burden of seeking support varies greatly depending on the demographic characteristics of the customer and on the type of energy hardship that they are experiencing. For example, people with Pensioner Concession Cards have access to passported benefits that can deliver small rebates. Those with specified types of life support equipment must complete additional forms with their medical practitioners to access rebates, and not all health conditions are recognised. Several other categories of energy known energy vulnerability, such as having inefficient housing, are not tied to any form of passported benefits. Beyond passported benefits, very few forms of direct financial support are available. Further, several forms of energy hardship are not recognised in supports. While crisis payments are available to all demographics in NSW via Energy Accounts Payment Assistance (EAPA), these are intended for short term payment difficulties and their design does not recognise chronic energy hardship. All supports outside passported benefits (namely EAPA, and retailer payment plans and hardship programs) are designed to address energy debt. This does not recognise energy hardship in the form of intentional underconsumption to avoid incurring debt, even if that underconsumption is detrimental to wellbeing. For many segments of the population, payment plans and crisis payments are the only available forms of support, and these cannot assist with either hidden or chronic energy hardship. Interviews emphasised these limitations of current supports, and the need for better recognition of chronic difficulties. Administrative burdens form a particularly high cost for those with chronic difficulties, because processes to access supports must be completed over and over, generating both compliance costs and psychological costs. In effect, processes for hardship support distribute benefits narrowly, do not recognise many categories of struggle, and create procedures that land most heavily on those already struggling. This constitutes a set of energy injustices in hardship support provision. We close by discussing policy changes that can alleviate these injustices.