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EDF Fail Ofgem Direct Debit Rules

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  • backfoot
    backfoot Posts: 2,700 Forumite
    Part of the Furniture 1,000 Posts Combo Breaker
    edited 29 June 2012 at 5:02PM
    jalexa wrote: »

    In a way I regret not being in a position to refer a complaint but given I achieved a satisfactory outcome I am not eligible.

    Yes because you are informed and had your own calculation and the knowledge to get the advisors to take the least line of resistance. Unfortunately, it resolves a problem at the time but fundamentally doesn't prevent a repeat.

    Neither my relative nor me had much idea about the basis for the change (which should be given at the outset) so put the request in writing. A 15% change must have an explanation, especially on a fixed tariff.

    From there it developed into obstruction, which was counter productive for EDF, because it has exposed them to further scrutiny. Trying to link another SLC to defend their position, imho, shows they have a systemic problem.

    On my own account, SP did a review of my DD and laid it out in a calculation at the time of the review. That was correct in terms of SLC27.14. Unfortunately, the calculation used was terribly flawed because they changed the anniversary date and accepted that the gas units forecast were nonsense.

    By chance, the combination of the two things, cancelled each other out so the review amount was about right. They promised me an explanation of the two errors but none has been forthcoming. (must chase) At least they had given me the data to understand what they had done......(wrong)....:)
  • jalexa
    jalexa Posts: 3,448 Forumite
    edited 29 June 2012 at 6:27PM
    backfoot wrote: »
    From memory,if you didn't have any knowledge of your consumption history,they would ask for details of the size of the property and number of occupants. I always assumed this was to do a best estimate by banding you into low,medium or high usage.

    That is an interesting point which begs as many questions as it answers. If a comparison website is used, then "banding" questions can be answered giving a £££s headline cost. As I mentioned earlier I have yet to hear an authoritative view whether the initial DD calculation is done by the comparison website or the supplier but I suspect that the information passed is identical (kWhrs or headline cost?) irrespective of how the cost (quotation?) is arrived at. In the case of a headline cost (quotation?) resulting from either kWhrs (or DD payment) no demographic information is collected by the comparison website.

    So the "Ofgem guidance" ...

    If you are a new customer, the payments will be based on a number of factors including previous meter readings and the number of rooms and/or the number of people living in the property.


    ...may be true for certain initial calculations but cannot be universally true for subsequent calculations. Which is, among other things, a concern I think we share.

    In fact the "Ofgem guidance" would appear to be silent on subsequent calculations. Of course that is because SLC27 etc applies:D but which is ignored roughshod by Edf Energy.

    The single thing which annoyed me most was when I found that the initial projected annual consumption, implicit in the initial payment amount, was subsequently unilaterally altered (without the courtesy of being so informed) to a figure of a provenance which I now know is not explained by the "Ofgem guidance" for new customers. And the revised payments on every occasion were an increase though there was no contemporaneous evidence of payment inadequacy. And I cannot forget the trained or scripted mantra every time I challenged the calculation of "we do not have 12 months of readings on file". Ha, not long before they are going to be compelled to put up or shut up on that.
  • backfoot
    backfoot Posts: 2,700 Forumite
    Part of the Furniture 1,000 Posts Combo Breaker
    I take Ofgem's new customer to be one who is applying for a supply and is getting their first DD set.

    Any other is existing. That should include someone staying with a supplier but changing contract.

    May be wrong as it's my interpretation.
  • snowcat53
    snowcat53 Posts: 602 Forumite
    Just had my draft complaint form and letter from the EO. They have removed the ref to 27.14, and it reads as semi-literate with at least one typo.
  • jalexa
    jalexa Posts: 3,448 Forumite
    edited 29 June 2012 at 9:12PM
    backfoot wrote: »
    I take Ofgem's new customer to be one who is applying for a supply and is getting their first DD set.

    Any other is existing. That should include someone staying with a supplier but changing contract.

    I tend to agree with that, but as a matter of fact that is not how Edf are behaving. I find the regulatory inaction (including associated EO conduct) to be inexplicable.

    However one thing to consider is that however it is calculated the initial payment is essentially "self-certificated". Some people here (not just me:)) manage this to the £, however others "haven't a clue". How therefore to establish the correct payment for what I call "actual projected" (a weighted projection from recent actual or customer reads normalised for weather, similar to Terrylw1's EAC for electricity)?

    I guess up to the supplier (to comply with regulatory requirements). I think that requires full disclosure of the calculation and justification of any assumptions. I also think a 12 month rolling calculation would be relatively fair, accurate and simple to follow.

    Why does it not seem clear to Ofgem (and in the last year Consumer Focus) that Edf's compliance is questionable (or commercial decision as the foot shooting EO argues)? No idea, I only do calculations.
  • Terrylw1
    Terrylw1 Posts: 7,038 Forumite
    Just to pose a question about Ofgem's fact sheet. Was it created prior to the comparison sites launching their utility services?

    Prior to switching sites, you would have spoken to a sales agent who would use those parameters. Comparison sites make it completely up to the customer, who could easily get this wrong if they only use bills, which could include estimates.
    :rotfl: It's better to live 1 year as a tiger than a lifetime as a worm...but then, whoever heard of a wormskin rug!!!:rotfl:
  • Terrylw1
    Terrylw1 Posts: 7,038 Forumite
    snowcat53 wrote: »
    Just had my draft complaint form and letter from the EO. They have removed the ref to 27.14, and it reads as semi-literate with at least one typo.

    I regard this attitude by the EO as an assistance to the supplier. Watering your complaint down by removing relevant facts is weighting it in the suppliers favour.

    And I thought the EO was independent? Or perhaps they are not very good at what they do and need everything simplified?...
    :rotfl: It's better to live 1 year as a tiger than a lifetime as a worm...but then, whoever heard of a wormskin rug!!!:rotfl:
  • Terrylw1
    Terrylw1 Posts: 7,038 Forumite
    edited 29 June 2012 at 11:29PM
    SLC25.6 states that if the customer is unable or unwilling to provide any previous record of consumption, it can use any information available, but to use Best Estimate, which can be individual to each supplier.

    This makes it difficult to enforce when it ends up in the rather shady "best endeavours" category like so many other issues.

    SLC27.5 (a) & (b), SLC25.9 then apply.

    The Ofgem fact sheet is clearly published recently, so that rules out aged document issues. However, I find their guidance very vague. Its not possible to base a DD for usage on a change on tenancy customer in a Deemed contract scenario, by using tge previous occupants consumption. I'm sure its used but its often the case that consumption changes between occupants as its often down to customer attitude to usage, number & type of appliances both permanent and not, number of kids, working patterns, etc...

    I'm not aware that any such calculation is applied on a change of occupant. The most likely DD value applied is probably "what did you pay before, what do you want to pay, wait and see if the DD covers it when you get your first bill".

    I'm not aware of any national guidance on rooms, heating, etc. Don't forget about location, height above sea level, sunset times, number of hours of daylight, it goes on...so its a complex calculation. As such, its going yo be way beyond a sales agent drifting from one sales job to another. I suspect its going to be basec on published data such as Elexon's load profiles which are heavily researched, Ofgem's annual kwh maybe, with some adjustment % for rooms/occupants...I don't know how though. To me, sales agents are not trained/qualified to understand these complexities and just aim for the customers bills, they couldn't get into accuracy on so many factors without software to do it for them. They are also hit & run merchants and you'll find customer service/back office people loathe sales people as they have to clear up the mess they cause.

    SLC22.9 happens without your consent as its contained in the BSCP's as an industry requirement. The SLC just prevents them from disclosing it if you ask them to.
    :rotfl: It's better to live 1 year as a tiger than a lifetime as a worm...but then, whoever heard of a wormskin rug!!!:rotfl:
  • Terrylw1
    Terrylw1 Posts: 7,038 Forumite
    jalexa wrote: »
    And I note the Ofgem guidance does not explicitly say actual previous or industry estimated actual consumption (EAC or similar).

    Until the switch is accepted by the distributor, the new supplier cannot attempt to access this or their contracted agent. It occurs during the switch prises but only once the objection period has expired hence the new supplier has started to take the supply.

    So, Ofgem are only talking about your bills from the old supplier for a switch.

    For existing customers, for me, this is very different since the industry is there and Ofgem's own SLC's do tell them to use all data they have access to. So, by building new systems to use it, they comply with the SLC but EAC/AA's are extremely complex and no system will ever fully use them, its always down to individuals to correct values, manipulate consumption histories, etc. Supply staff are not used to this, these very complex billing mechanisms are for the very advanced supply people working in settlement correction or industry compliance/financial teams, etc.

    You might find it interesting to look at SLC25.13 (a) & (b) which don't account for any telesales or web based activities. This is a big flaw. Its obviously been inserted later to counteract dodgy doorstep/supermarket sales.
    :rotfl: It's better to live 1 year as a tiger than a lifetime as a worm...but then, whoever heard of a wormskin rug!!!:rotfl:
  • amiehall
    amiehall Posts: 1,363 Forumite
    This thread has terrified me.... I'm switching to edf as a result of their penalty free fixed tariff. I'm very paranoid about building up arrears and tbh would always rather pay more and have it refunded than be slapped with a huge bill.

    I'm used to submitting regular readings so I can see my account balance and make sure I'm building up a bit of credit for the winter. I'm particularly paranoid of this now as it's my first year in an all electric property and if it's a cold winter that could be £££

    Is the consensus that once I have a DD that I feel is at the right level, I shouldn't submit any readings to edf?
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