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Cynthia Gebert

"As customers seek to access concessions for the first time, we're hearing that they're having trouble doing so"

EWOV cases continue to fall — in the first full 'COVID-19' quarter (April to June 2020), they fell 17%. Within this, billing cases fell 15% and credit cases fell 38%. The falls are surprising — billing and credit issues are linked to affordability and so many Victorians are facing financial pressures. We think our low case numbers reflect the extensive financial support that's been provided to people so far. We're very aware of the likely change that lies ahead — as shifts and reductions in financial support combine with the winter bill payment problems we see every year, and which are likely to be more significant this year as a result of stay-at-home policies.

In March 2020, we began tracking cases where customers mentioned COVID-19. While it was useful to help us keep government and regulators informed about case trends, we soon realised this approach was just too narrow. COVID-19 is affecting all customers in some way, and it's become evident that people who've never needed payment assistance before are increasingly in need.

Highlighting this particularly well is an emerging problem around energy and water concessions. As customers seek to access concessions for the first time, we're hearing that they're having trouble doing so, and not because they've done anything wrong. It's a matter of mismatched information and it needs to be addressed swiftly.

This is our first issue of EWOV Reflect — a new quarterly, web-based publication, which consolidates the content we previously published in three separate publications (ResOnline, Affordability Report, Connect). A major difference, and improvement, is that Reflect links directly to the Data Hub on our website, which provides 'live' views of case trends and key observations.

The big picture

From April to June 2020, EWOV received 4,754 cases, down 17% from the previous quarter:

  • The falls were across all three industry sectors.
  • They were most notable in credit (down 38%) and billing (down 15%).

Significant falls in disconnection cases reflected the pause on disconnections during COVID-19:

  • In electricity, actual disconnection cases fell 84%, and imminent disconnection cases fell 68%.
  • In gas, actual disconnection cases fell 73%, and imminent disconnection cases fell 66%.

There were significant falls in the top billing issues:

  • High bill cases fell 27%.
  • Billing error cases fell 16%.
  • Tariff cases fell 14%.

Bucking the downward trend, land cases were up 32%, and mostly from residential customers:

  • 89 cases were about the effect of energy and water network assets on properties:
    ○ placement (51 cases), maintenance (24 cases), health and safety (14 cases)
  • 66 cases were about property damage.


  • This is an archive version of Reflect without data visualisations.
  • Reflect and Data Hub data is a ‘live’ view of case data up to the end of the previous period.
  • Cases can sometimes be amended, reopened and reallocated — adjustments made to cases in previous quarters will be shown in the previous quarter's figures within the visualisations.
  • For these reasons, there may be discrepancies between previous quarter data presented in the visualisations and the information presented in past editions of Reflect.

Issues watch

Barriers to receiving energy and water billing concessions

As the financial effects of COVID-19 deepen, more customers are becoming eligible for regular concessions on their energy bills, and for assistance through the Utility Relief Grant Scheme. For an increasing number of customers, ongoing energy affordability is linked to the need to take up their entitlement to concessions. Immediate relief — such as 17.5% off electricity and gas bills — makes a big difference when money is tight, and bills are bigger due to home confinement.

However, customers new to eligibility for concessions — and possibly new to experiencing payment difficulties — are starting to contact us. Their complaints highlight that applying concessions to the accounts of large numbers of customers who haven't received them before isn't straightforward. The problems appear to be associated with validation of concession card details, because of information mismatches — especially around names and addresses.

We've raised the issue with the Department of Health and Human Services. We also think energy retailers need to be actively working with customers to address the mismatches and get these details right. If the problem isn't addressed, it has the potential to create unnecessary hardship and unsustainable energy debt — and lead to more complaints.

What customers seeking concessions on bills have told EWOV

  • The retailer said their bill didn't show concessions because their name was spelt incorrectly.
  • They held a concession card, but it had expired.
  • They couldn't get an answer about whether they were already receiving concessions.
  • They were told they didn't qualify because they hadn't paid their bills on time.
  • The concession 'dropped off' their bill due to details (variously postcode, name, middle initial) not matching those held by Centrelink.
  • Their retailer wouldn't backdate missing concessions when no error was found.

What customers seeking a Utility Relief Grant have told EWOV

  • The retailer said it was putting applications on hold and not sending out forms.
  • The retailer was unhelpful, uninformative, and obstructive when they asked for the form.
  • They'd asked several times for the form, but it wasn't received.
  • The retailer refused to send the form because their account balance was 'low'.
  • The retailer quizzed them on why they needed the form, saying the grant cap was less than they owed.
  • The retailer said it didn't send the form as they had to pay the balance of their account first.
  • The retailer couldn't help because they were in an embedded network. No payment options were offered.


Not being able to take part in community outreach and engagement activities in person for some months now hasn't stopped us engaging. We've continued our outreach by videoconference — largely focusing on building awareness of customer rights and responsibilities, and EWOV's role in reaching fair and reasonable dispute resolution outcomes.

We've created information to help Victorians affected financially by COVID-19 — with a focus on helping customers at risk of being unable to pay their energy and water bills. In March and June, we sent COVID-19 updates to over 600 community groups and agencies. In this, we included advice about our priority line for agencies working with vulnerable consumers.

We've expanded our social media activity and targeted communications to 'vulnerable' areas of Victoria — including the location of the public housing towers that were subject to a 'hard lockdown' in July — to help people understand their rights and responsibilities, and how EWOV can help.

We've also developed and delivered an information session for staff at State Trustees who manage the financial affairs of over 9,000 Victorians — again, this focused on customer rights and responsibilities, and the role EWOV plays.

From our outreach, we understand that financial counsellors haven't seen an increase in the number of consumers contacting them — due, they tell us, to the financial support that's helping people meet their financial commitments. We also understand that emergency relief organisations are receiving more funding, which is allowing people to access food packages several times a week.

Customer stories

Billed even though property was destroyed in bushfires


CASE NUMBER: 2020/3476

Ms W rang EWOV after receiving an electricity bill for early January to early April 2020. She said her power went out on the last day of 2019 and her property was burnt down during the January 2020 bushfires.

Despite ringing her electricity retailer and closing her electricity account, she'd received reminder and imminent disconnection notices. She said the retailer maintained there was an active meter onsite, which would need to be checked. Ms W said the meter was destroyed in the fires. She also said the retailer's representative displayed no empathy or awareness of the extent of the bushfires.

When Assisted Referral didn't resolve the complaint for Ms W, we opened an Investigation. Responding to our Investigation, the retailer said there were two accounts for Ms W. One had already been closed and final-billed to the beginning of January 2020, with a credit balance of $40. The second account was still open — following further investigation it would be closed and retrospectively final-billed to the end of December 2019, with a credit balance of $41.50.

The retailer apologised to Ms W. In recognition of the inconvenience caused. It credited each account with a customer service payment of $100. It said Ms W would receive two refund cheques — one for $140 and one for $141.50. Following this, she wouldn't receive any further bills relating to these accounts. Ms W accepted this outcome. The complaint was closed.

Frustrations when trying to apply for a Utility Relief Grant


CASE NUMBERS: 2020/4885 & 2020/4886

Ms P obtained her electricity through an embedded network arrangement and she was on bulk-billed hot water. When she contacted EWOV, she'd been stood down from her employment due to COVID-19. When she asked her energy retailer about applying for a Utility Relief Grant, she was told to contact the Department of Health and Human Services (DHHS). She said she'd tried for a week to get through to someone at DHHS, but she got no further than a recorded message about technical difficulties.

At Assisted Referral, the energy retailer maintained Ms P had to contact DHHS directly because she was in an embedded electricity network. Ms P returned to EWOV dissatisfied. She also emailed DHHS, copying EWOV in. She said she was still awaiting an outcome. She continued to be worried about her capacity to pay the arrears, but believed she'd be able to pay her bills going forward.

Responding to EWOV's Investigation, the retailer confirmed the advice it had given to Ms P about contacting DHHS. It suggested she may be eligible for a Non-Mains Utility Relief Grant (NURG) for non-mains embedded electricity or bulk hot water bill.

At this point, Ms P owed $365.51 for electricity and $389.75 for gas. The retailer offered a $250 credit on each account and a three-month payment plan for the account balances. Ms P accepted this outcome. The complaint was closed.

Responsibility for the cost of undergrounding a private line


CASE NUMBER: 2020/6456

In August 2019, Mr V's electricity was disconnected after his private electricity pole was assessed as unsafe. His request of the local electricity distributor for a temporary pole was refused. By the time he contacted EWOV in mid-May 2020, he'd also been told the power now had to be put underground because he was in a high fire danger area.

Mr V said that, in October 2019, the distributor quoted him $5,300 to underground the line. It had since told him the quote was likely to increase because of the time that had passed. He was concerned about not having access to electricity during COVID-19. He was also worried about the potential effects on his health coming into winter. He wanted either a temporary pole or a payment plan to help him pay for the undergrounding.

Due to the special circumstances of the case — severe vulnerability, disadvantage (no employment for more than 12 months) and health issues — we used our discretion to bypass Assisted Referral and move directly to open an Investigation.

Responding to our Investigation, the distributor confirmed that the electricity installation to Mr V's premises didn't meet safety standards and it was Mr V's responsibility to remedy that. It confirmed that Mr V's supply was disconnected in August 2019, as soon as inspection showed it was hazardous.

Its location in a high bushfire risk area meant the pole couldn't be replaced and supply had to be relocated underground. It said the cost would be $5,358.10. It provided EWOV with the details of this, which we reviewed. It proposed that if Mr V could pay 50% ($2,679.05) upfront, the remainder could be paid in instalments of $50 a week. Mr V accepted our independent assessment of the situation, and the resolution offered. The complaint was closed.

Vulnerable customer seeks EWOV's help at a community event


CASE NUMBER: 2019/19381

Ms K approached an EWOV team member at a community outreach event, saying her electricity was about to be disconnected for non-payment. A local financial counsellor agreed to act on Ms K's behalf due to her evident distress and vulnerability, and the assessed likelihood that she'd disengage. Ms K's ongoing health issues qualified her for 'life support' supply; she was on a disability pension; she lived in government housing, and she was financially supporting and caring fulltime for her granddaughter.

Due to Ms K's circumstances, we used our discretion to bypass Assisted Referral and open an Investigation.

The retailer said it hadn't been able to reach Ms K for some time, despite letters and multiple contact attempts by phone and SMS at different times of day. Through her financial counsellor, Ms K maintained she'd made payments, but couldn’t provide receipts. The retailer couldn't find the payments, and the account reconciliation we reviewed didn't show any. The retailer agreed to adjust Ms K's account by applying all the pay-on-time discounts she'd missed (worth $5,202.14). This reduced her arrears to $9,384.93.

From the contact notes the retailer provided to us, we could see that bills, reminder notices and 'supply at risk' letters had been sent. However, despite Ms K's growing arrears, it didn't appear that the retailer had reviewed her account with her. This wasn't helped by Ms K's evident disengagement.

Ms K's financial counsellor provided us with an assessment of her financial situation. We arranged for EWOV's Technical Adviser to review her usage patterns; we considered similar cases EWOV had dealt with; and we sought advice on good industry practice from several other retailers.

We had extensive discussions with the retailer about 'fair and reasonable' options for a sustainable resolution. It backdated Ms K's concessions 12 months, a credit of $558.79. It set up a payment plan of $25 a fortnight (in line with what she was paying through our Investigation) for six months. It agreed to match every sixth payment Ms K made with a credit. Her arrears were put on hold for six months, while it worked with her to cut the cost of her usage, which at that time was $206.50 a fortnight. It agreed to move her to its 'best offer'. It identified a range of other assistance which could also be provided, including a Utility Relief Grant. Ms K was made aware that she must stay in touch with the retailer. The complaint was closed.

Scheme participants

In our Data Hub, you'll find the latest quarterly case data for all of EWOV's scheme participants.

Systemic issues

We identified 12 systemic issues (9 energy and 3 water) from our April to June 2020 case handling.

Better checking for voltage variation events An energy distributor rejected customer claims for damage caused by a voltage variation on the basis that it had no record that an event occurred. The distributor changed its process to draw on other information/records, which allowed it to determine with more certainty whether a voltage variation event had occurred. SI/2019/22 & SI/2019/23

Non-compliant disconnection warning notice An energy retailer’s disconnection warning notice for deemed customers didn't outline applicable reconnection procedures, so it didn't appear to be compliant with clause 110(2)(e) of the Energy Retail Code. The retailer amended the disconnection notice and made wrongful disconnection payments to 43 customers. SI/2019/3

No notice of remote disconnection for smart meter properties An energy retailer’s disconnection notice for occupier accounts didn't state that customers with a smart meter could have their electricity supply disconnected remotely. This is a breach of clause 110(2)(h) of the Energy Retail Code. The retailer amended the notice and made a total of 52 wrongful disconnection payments. SI/2019/40

Unable to contact energy retailer Customers complained about being unable to contact a particular retailer — due to long phone wait times, or no response to emails, or both. The retailer implemented several initiatives, including changes to its telephone system, putting on more staff, and IT system changes. SI/2020/9

Billing delays for large customers Large electricity customers of one energy retailer complained about significant billing delays. The retailer advised it had since allocated more resources to the billing process for these customers. SI/2019/42

Fees charged for failed direct debits An energy retailer continued to charge customers fees when their direct debit was rejected, despite the welcome pack it sent to some customers not saying this would happen. EWOV formally referred the matter to the Essential Services Commission under section 54X of the Essential Services Commission Act 2001. SI/2019/4

Provision of information about COVID-19 relief package An energy retailer wasn't following correct process in providing customers with information about Energy Networks Australia (ENA)’s COVID-19 Electricity and Gas Relief Network Package for customers. After discussions with ENA, the retailer developed training and materials for use by its staff. SI/2020/24

No mention of EWOV on notices An energy retailer’s initial disconnection warning notices didn't mention EWOV or include EWOV's contact details as required by clause 110(2)(f) of the Energy Retail Code. The retailer corrected this from May 2020. SI/2020/22

Customer data shared in emails Three water companies notified us that a data breach by a third-party research company resulted in email distribution of data relating to about 4,000 customers. It said all affected customers were notified. The water companies said they'd revised procedures, made system changes, and retrained staff to prevent it happening again. SI/2020/11, SI/2020/12 and SI/2020/13

Public submissions

Draft Guidelines on Part XICA – Prohibited conduct in the energy market

Australian Competition & Consumer Commission (ACCC)

We expressed EWOV's support for the Draft Guidelines in the context of our 'small customers' jurisdiction, high billing being the top issue of complaint to us, and the importance of Part XICA in ensuring the fairness of energy deals from which customers must choose. We provided some further commentary -- largely around retail pricing, and compliance and enforcement.

EWOV's submission online

ACCC's Draft Guidelines

Electricity Distribution Code Review – Draft Decision – Customer Service Standards

Essential Services Commission (ESC)

In responding to the ESC's Draft Decision, we observed that it will raise the standards of customer service required of distribution businesses -- especially around guaranteed service levels (GSLs) and payments, and communication with customers. We provided further comments around planned outages, the GSL scheme, reporting requirements, and the proposed implementation timings.

EWOV's submission online

ESC's Draft Decision

An EWOV research report

Charging ahead (June 2020)

New energy technology and the future of energy complaints in Victoria

This research project, published in June 2020, was undertaken as part of EWOV's ongoing commitment to ensuring our scheme remains accessible to all Victorian energy users. It was designed to help us understand the customer experience outside traditional energy systems, and the growth of new residential energy technology in Victoria. The research considers customer dispute resolution in the context of residential solar PV, residential batteries, electric vehicles, microgrids, virtual power plants, peer-to-peer trading, and home energy management systems.

As the research report was prepared just before the onset of COVID-19, it doesn't consider the impact the pandemic may have on the short to medium-term growth of new energy technologies. Despite this limitation, the issues raised remain relevant and provide a useful roadmap to the future of energy complaints in Victoria.


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