EDF Fail Ofgem Direct Debit Rules

Terrylw1

Jalexa, to answer your points.

An EAC is purely a 12 month forecast of future consumption based on the previous 12 months.

An AA is some firm consumption for instance, the difference between 2 readings. This can be slightly out though due to some other factors used, but its not by much. If you need to know this part, I'll have to recap myself as its been a while since I've looked at Daily Profile Coefficients (DPC) but if consumption is normal, I don't think they would influence this.

The supplier only sends the initial EAC on a new connection or when the meter is changed to one that differs in terms of payment method, timings, etc as this causes a data item to change hence the old meters EAC is no longer valid. The supplier can also pass the EAC they last received from their Data Collector to the new supplier, but the new supplier cannot pass it on anyway (the old suppliers Data Collector gets a data flow request from the new suppliers Data Collector asking for the EAC). So, wiki isn't correct there. In fact, there is even a data flow process where the Data Aggregator asks the supplier to get the missing EAC to them. The supplier can also send a zero EAC inline with the industry vacant sites process which aims to reduce overpaying by suppliers.

AA's are provided only when some firm data is entered into "settlement" which can only be triggered by a reading. The reading can come from a meter change of any kind, a meter reader visit or even a data correction being applied to correct a previous problem.
So, AA's occur to events. Also, if no valid reading is entered into settlement at 720 days, the Data Collector has to create one.

The EAC is different, its the basis on actual settlement payments, hence there must always be one to allow the Data Aggregator to inform the distributor what they should charge the supplier at 14 months. If there isn't one sent from the Data Collector to the Data Aggregator, the DA sends a data flow to the supplier telling them of this so they resolve it since the supplier is held accountable for their agents performance by the industry. An EAC can be missing due to awaiting for the supplier to update them in the new connection and type of meter change mentioned earlier. Otherwise, it will be a system or process issue in the DC.

Since an EAC always has to be in place, a change of supply triggers one up to the switch reading for the old DC up to the switch date, then the new DC uses the consumption they get off the old DC to issue the new EAC from the switch date. This is why this previous 12 months of consumption is sent to the new DC since until they take readings, they don't know what the consumption is.

Firm data that produces an AA, means the EAC is recalculated in the same transaction since the AA gives more accurate data. So, the principle is that over 12 months, AA's should bring the EAC inline by reducing or increasing it. Where an AA is created, the parties who receive this data (both EAC and AA's whether together or not are always send to both the supplier and DA) St a data flow with the AA and recalculated EAC in it together.

In terms of AA's and their impact in causing the EAC to be recalculated, its important to understand that the DC has to validate the data to enter it into settlement. They can fail it though. Whether valid or not, the supplier is sent a data flow indicating it. If valid, the AA with recalculated EAC is sent in a data flow. If they fail the reading though, there is no AA hence no recalculated EAC...so in settlement terms, it never happened. In the case of an event making a change to standing data, the whole process stops until resolved by correcting and revalidating the reading or Deeming one based on the current EAC. This event will be a meter change, change of supply, fuse fit or remove and one other type which is a change of tariff from E7 to standard rate or vice versa (not all meters are allowed to do this)

So for a customer to influence this do one of the above events. The most obvious way to influence the EAC is to give your reading to your supplier, who has to pass it to the DC for validation and confirmation whether they believe it to be valid or not. You create an AA this way and cause recalculation of the EAC. Its worth noting that it relies on the supplier being compliant in passing your readings on and arguing with the DC to get it validated if they have rejected it as failed.

Does that make sense?

Gas is a bit different and I don't know it as well. The terminology differs in that they use AQ instead and they do a yearly review that can result in your data being altered and its done at industry level so the supplier has to argue not to default it and keep the data in place

In terms of the trigger events, its all the same, gas has less than elec. Customer reads work the same though. Some of the update procedures are different as the set up of supplier, agents and distributor differ. The supplier in the gas case, doesn't provide the AQ.

A point I should also mention on elec again, is that in the scenarios where the supplier provides the EAC, its only a default one set by the industry. It is then recalculated as readings get entered.

Terrylw1

One thing I will say, is that industry agreements whether SLC, MRA, BSC, etc are always legal documents as as such they are extremely careful in terms of what links to what, interacts or overrules.

So for EDF to say, SLC31A overrules SLC27, it would have to say so in the SLC. Where it does, Ofgem have included it.

Its very clear that they don't need to show the projections and costings until the 12+ months period, but they always have to show how they calculate the DD's whether <12 months or 12+ months.

jalexa

Terrylw1 wrote: »

An EAC is purely a 12 month forecast of future consumption based on the previous 12 months...

...A point I should also mention on elec again, is that in the scenarios where the supplier provides the EAC, its only a default one set by the industry. It is then recalculated as readings get entered.

Reading this on a small screen so still to digest in full.

I realise that the industry, particularly the generators, needs an "EAC" for planning purposes, but last year's "EAC" would be of little use to them as a planning tool, yet "inaccurate EAC" is what Edf Energy (which this thread is about) appear to be relying on for 12 months (and perhaps longer). I say "appear" because the real issue is they won't say. An outcome is "free-money" for the supplier and cost to the customer.

This encourages low up front initial monthly payments being replaced with a hiked calculation incorporating at least one bogus concept.

This is a competition hornet's nest which deserves to get seriously poked. And wobetide regulators, consumer representatitives and (particularly) politicians who fail consumers.

backfoot

Hi Terry and Jalexa,

We have to be a bit careful here. I want to keep the thread I started on a straight track. Clear and understandable if you like.;)

Data validation routines, from my knowledge, were more to do with ensuring meter reads, opening and closing make sense and are used as part of the purchasing cost routines i.e. settlement data.

The upstream billing and estimating routines used by suppliers may or may not be connected to the systems you have started talking about.

The point being is that for the average Joe,it really doesn't matter. The License Condition SLC27 was introduced to provide a framework for a customer to be given simple information about how a DD value has been derived. That is an information requirement of the Supplier and it is that which is missing from the piece.

EDF are failing to produce it at the required time (on a change) and subsequently are claiming that they have no obligation to do so.The bogus SLC31A defence.

It is a blatant fingers up to the Regulation.

I think there are simple ingredients such as an annual estimated consumption or remaining estimated consumption to a review date.This is then converted to a tariff cost and divided by the months to the review date.

How some of that consumption data is derived may or may not be impacted by EAC or AA's but I actually doubt it. As long as a customer is given the answer, they can look at how reasonable it is. As a customer, that is all I want.

Unfortunately, EDF have taken a very strange route to deny the customer even any explanation of it.

My belief is that in doing so,they will have to amend their newly specified system because the data currently isn't linked into a sensible format and that it also unreliably produced.

As they have chosen to review at every meter read they have now realised the horrific implications and have shut up shop. That is their problem not ours.:D

meggsy

Final EDF Energy Penalty Notice for failure to comply with Standard Licence Conditions 23, 25 and 27

http://www.ofgem.gov.uk/Pages/MoreInformation.aspx?docid=140&refer=ABOUT%20US/ENFORCEMENT/INVESTIGATIONS/CLOSEDINVEST&utm_source=Ofgem+Website+Mailing+List&utm_campaign=d774f16353-Ofgem_Email_Alert5_28_2012&utm_medium=email

backfoot

Thanks Meggsy,

From Section 4.8:

'The Authority cannot overstate the importance of SLCs 25, 23.1 and 27.15 as tools that aim to ensure that accurate and adequate information is provided to customers and go to the heart of the Authority’s principal objective to protect the interests of consumers.'

I think the findings of this penalty notice are mainly relevant to sales activities and predate the main thrust of this thread.

However,I have picked out the part relevant to Direct Debits.The wording above shows that Ofgem take very seriously the importance of provision of accurate and adequate information.

Despite admissions by EDF in relation to these previous investigations,it is blatantly clear that such messages have not been taken on board. In relation to specific DD Management and communication with customers,there are even more ongoing obvious failings in abiding by the SLC27.

I will be lobbying Ofgem strongly on this aspect.:)

Terrylw1

One of the big industry issues and has been for some years is accurate settling. The Industry bodies, namely Elexon have been imposing targets to make suppliers and their agents create a more accurate payment into the distributors.

What has started happening since is that suppliers have started to look at the difference between what they pay to the distributor and what they pass on to the consumer, this has led to large scale projects to reduce the gap. Part of this has been to ensure settlement data is more accurate so it can then be used in the calculation to the customer.

The software the Data Collectors use in production of these forecasts is far more advanced than what suppliers use. Its industry standard software as opposed to the suppliers old legacy systems. Suppliers then upgrading to SAP are most likely going to rely on this transmitted data since they know that is coming from a trusted source using far superior software calculations and as long as all data is fed in, should accurately reflect the customers usage.

I don't know how they are all working but I do know some going into SAP have designed their systems to load these consumption data flows with rejections for those which are out of tolerance.

The fact remains that this is all too complex for the customer and the supplier needs to explain it in simple terms. Given EAC's are based on weather as well, I doubt this will ever truly happen.

snowcat53

backfoot wrote: »

The point being is that for the average Joe,it really doesn't matter. The License Condition SLC27 was introduced to provide a framework for a customer to be given simple information about how a DD value has been derived. That is an information requirement of the Supplier and it is that which is missing from the piece.

EDF are failing to produce it at the required time (on a change) and subsequently are claiming that they have no obligation to do so.The bogus SLC31A defence.
.:D

Backfoot - I agree 100%. This very detailed discussion about meter readings, settlementss, EACs and AAs - while interesting and perhaps deserving of attention in its own right - is a red herring to the main point- the lack of ANY explanation when edf notify a change in DD.

Terrylw1

Ofgems investigation is all about the values to sell to a customer, so any data is out of the window. Its all going to be about using a more accurate assessment of the customers property which really means getting their previous billed firm readings.

However, once you're switched, if they change the DD, if they intend to hide behind SLC31A to override SLC27 (which is incorrect since its not stated in the SLC's as an exception) the situation regarding lack of info given to the customer and an explanation of changes to DD, still remains.

They are always going to pull the excuse that the sales agent got it wrong. Sales and service people don't see eye-to-eye, since sales cut & ran, service spend time taking the flack and clearing up the mess...cottage industry.

I don't think this should be left to the suppliers to determine other than how to multiply their charges over the kwh. The industry should devise the method to calculate the comparison into kwh. This is what I find so lax since the whole settlement side is dictated in terms of average values and how to generate estimates.

backfoot

snowcat53 wrote: »

Backfoot - I agree 100%. This very detailed discussion about meter readings, settlementss, EACs and AAs - while interesting and perhaps deserving of attention in its own right - is a red herring to the main point- the lack of ANY explanation when edf notify a change in DD.

Thanks.

The perverse stance of EDF has no logic. Every change generated by the system (whatever its source) has consumption data, a calculated cost and a period of time.

So to withold that calculation must be a tactical decision. I can only assume they are so fearful that the assumptions are flawed and will cause even more Customer Service problems.

The tactical stonewall now added to, with a bogus legal argument, is pure desperation.Even after numerous requests they failed to send me any data whatsoever. It can't have been difficult to resolve my request or abide by the SLC27. Instead, they searched for a legal loophole.

It may have suceeded with many, but the MSE posters are much more enlightened and determined.

Today EDF have been fined for breaches of various SLC's,connected to the sales and marketing processes.

Other complaint handling investigations are still open and now, I and others, have illustrated beyond doubt that they breach SLC27.

EDF appear to be in a total downward spiral of customer service and their Management don't appear to have a grasp of the situation. Their strategy of gaining market share at the time of a botched system implementation has backfired horribly.

I have asked Ofgem to follow this thread.