EDF Fail Ofgem Direct Debit Rules

backfoot

jalexa wrote: »

Do you mean the Ofgem DD guide says so or that is the case you describe?

Both in this case.

backfoot

jalexa wrote: »

"...the annual review of your budget direct debit plan is due in April rather than July so as to run in line with the reading and subsequent billing cycle for your address. As we only seek to bill our budget direct debit customer twice annually there is no scheduled billing due to take place in July and so no review can be taken at this time. We will only seek to complete bills and reviews to accurate information and so it is imperative that your billing and meter reading cycles coincide with each other to give the greatest chance of this happening..."

I will find out in the next few days whether that is a final (or more likely a default) Edf position.

IMHO, there is no basis for EDF to do what they are claiming.

In your case, I would be arguing the process is essentially unfair and unnecessary.

They could ask you for a meter reading/take one themselves/use an estimate.

They have not explained the process in advance and have altered the fixed regular amount of your DD without proper explanation.Such explanation was required at the time of the change.

It is contrary to the advice about the scheme given by Ofgem's Factsheet.

It is not compliant with SLC27 as you were not given any clear and understandable explanation of the basis of the DD calculation.i.e the consumption forecasted and the period covered.

EDf's process is in total chaos because it has been incorrectly specified and certainly not specified to abide with the Regulations.

I have asked Ofgem if they want me to take my case to the Ombundsman or whether they agree there is irrefutable evidence to take immediate action given that there is systemic failure affecting millions of customers.

quiet_advisor

I have taken my complaint to the Energy Ombudsman on the above point regarding the quality of information provided by EDF to justify changes to DD payments and I'll post the outcome in due course.

I followed the EDF complaint procedure to the letter, all by e-mail to keep a record, and encourage others to do the same and complain formally. EDF has proven to be the worst energy supplier that we have ever dealt with, and that takes into account experience gained from switching on a very regular basis.

The main surprise is that these problems continue to exist in a market that is now mature. Ofgem appears to have a lot to answer in terms of its obligation to protect customers - that's why licence conditions exist but if they are not enforced effectively by the Regulator customers are left at the mercy of inadequate suppliers.

jalexa

backfoot wrote: »

For customers whom we have supplied for less than a year...

Nonsense I think. I can see no relevant qualification in the relevant SLCs. Nevertheless a "good response" as it is begs "testing" via consumer and regulatory channels.

...we do not believe that we are required under the current Licence or the Ofgem guidance to provide a more detailed calculation...

I don't believe that has "legal input", at least not "verbatim" input. Rather it is an output of the same customer services "imagination works" section as my own and intended to dupe "uninformed" customers, unfortunately for Edf we are not "uninformed".

...including a forecast of future consumption up to the end of the Direct Debit anniversary date on your Direct Debit review letter. However, from August 2012, you will see this forcast on your bills as we would then hold a full year's energy consumption enabling us to offer an accurate forcast'

I think it is interesting to note that part year and full year appear to be treated differently in relation to the accuracy of forecast (even though SLC27.15 requires "best and most current information available").

If you research iMeasure you will see a reference that 2 months (winter) consumption data when used with Heating Degree Day data (obtainable from numerous sites nationally) is sufficient for a prediction of annual consumption accurate to 10%.

Supplier data (eg SSE) currently indicates a seasonal 19% reduction in gas sales. A nice little earner if not reflected in the assumption of future consumption.

backfoot

jalexa wrote: »

I think it is interesting to note that part year and full year appear to be treated differently in relation to the accuracy of forecast (even though SLC27.15 requires "best and most current information available").

If you research iMeasure you will see a reference that 2 months (winter) consumption data when used with Heating Degree Day data (obtainable from numerous sites nationally) is sufficient for a prediction of annual consumption accurate to 10%.

Supplier data (eg SSE) currently indicates a seasonal 19% reduction in gas sales. A nice little earner if not reflected in the assumption of future consumption.

EDF have created a justification for different treatement for over one year versus under one year.

If they truly thought that the less than one year data was insufficient they would not alter the DD. They have altered the DD but then won't share the assumptions.

Jokers ?:rotfl:

The claim for delay in my complaint was that they needed more time to resolve it as it involved questions regarding the License Conditions.

So apparently,legal opinion will have been sought.

jalexa

backfoot wrote: »

EDF have created a justification for different treatement for over one year versus under one year.

If they truly thought that the less than one year data was insufficient they would not alter the DD. They have altered the DD but then won't share the assumptions.

Jokers ?:rotfl:

No idiots. At least E.ON had a strategy comprising a "considered" narrow interpretation of regulations, coupled with some forum reported unpleasant hard-ball customer contact.

Ofgem, against the written opinion of Consumer Focus, drafted direct debit regulations intended (and I don't doubt Ofgem's positive intent) to create a "loose regulation" framework. In different ways E.ON and (apparently) Edf are cocking a snook at Ofgem's intent. Dangerous given the recently beefed-up Ofgem. E.ON may already be half-way to paying the penalty.

Edf on the other hand currently appear to be powerless in the cleft stick of their new MyAccount system, for some unfathonable reason unable to implement a change as simple as not automatically re-calculating the direct debit whenever a customer read is submitted.

Until now I haven't policed Edf's compliance with their own industry body's Code of Practice for Accuratate Bills.
http://www.energy-uk.org.uk/publication/finish/43-code-of-practice-for-accurate-bills/411-the-code-of-practice-for-accurate-bills.html

I now believe their conduct of my account does not comply with clauses 2.3, 3.2, 3.9, & 4.1. Note the definition of "valid reading". All of my submitted readings are "valid" by being accepted and used in a statement.

I think their absurd "less than a year argument" is something else in the minds of the "imagination works" section, perhaps something to do with there being no contractual necessity (5a in some tariff terms and conditions) to issue a bill/statement more frequently than once a year. Unfortunately for Edf, I believe the instant they choose to re-calculate then their actions are captured by both the Code and the Licence Conditions.

In due course I will invite "imagination works" insight on that.:D

Terrylw1

Well after all, they are called Erroneous Debit Forecast;)

backfoot

My complaint refers to the lack of explanation for a change to the DD. In my case, it actually is a reduction in the DD. A reduction can create greater problems for the customer if the reduction is unwarranted.

EDF's problems are systemic rather than just manipulative.

Either way, any change requires a level of information to accompany it. A simple requirement,stated in a simple License Condition for very good reason.

If EDf can't understand it, they could employ a translator.

jalexa

backfoot wrote: »

EDF's problems are systemic...

Indeed systemic.

Been reviewing my Edf customer service emails. There is a gem in every one. An early one advised "I have no answer why your direct debit was doubled based on zero consumption. This is a system issue...":D

Another gem is the explanation why I am 'short-year aligned' (April) and not 'anniversary aligned' (July). It is because "Edf uses quarterly billing and the 'review' must coincide with a billing period...". Now pay attention, this is a difficult calculation, which month is April + 1 quarter or 3 months?:D

"Joking" apart, why would an organisation want to give these absurd and questionable explanations.

I await my imminent 'review' including the forecast of the next 12 months consumption based on 9 months of "valid" customer (and at least 2 meter reader) reads. And of course the DD calculation. And I won't be as surprised as McKneff appeared to be to see the projected annual costs divided by 10.:D

I haven't personally "pursued" the lack of calculation, having been content to have the original payment reinstated. At review I will insist on my own calculation being set. Or else. I am confident they will agree to my very reasonable proposal.:)

jalexa

Been aware of this previously and referred to the Edf "Anniversary zero-balance" entry.

http://www.ofgem.gov.uk/Media/FactSheets/Documents1/directdebitleaflet.pdf

Just noticed something I have overlooked, the entry for "Number of reviews per year" includes "one every meter reading".

Anybody, Ofgem, Edf, Edf Insider, care to articulate how an anniversary zero-balance can be reconciled with a review every meter reading?:think: