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Cynthia Gebert

"Disappointingly, cases about high bills, billing errors, concessions and grants, payment difficulties and poor customer service have increased in the July to September quarter"

Since March 2020, EWOV has been tracking 'pandemic-related' cases to help bring more clarity to what's going on for customers. We've used our case insights to contribute to consultation processes and inform the support initiatives of government and regulators.

In this space, high bills, billing errors, concessions and grants, payment difficulties and poor customer service have come up most commonly. Disappointingly, cases about each of these issues increased in the July to September quarter. Our feature article, Making life in lockdown even harder, looks at how these issues have been affecting customers.

Often, the customer's concerns were able to be addressed through our Assisted Referral of them back to a higher-level contact within their energy or water company. This highlights the importance of companies doing more to address these types of issues when they're first raised by customers.

Going forward, the additional targeted reforms for residential and small business customers recently introduced by the Essential Services Commission (ESC) will play a key role. ESC media release

Another important development is the ESC's new guide for embedded network operators. Launching the guide in mid-October, the ESC recognised EWOV's role in highlighting the gap in the level of guidance, support, and information available to embedded network operators. ESC media release

The big picture

  • From July to September 2020, EWOV received 5,954 cases, up 25% from the previous quarter.
  • The main driver was a 46% increase in billing cases.
  • Electricity billing cases were up 35%.
  • Gas billing cases were up 71%.

Relevant to trends we're seeing as we progress through COVID-19 lockdown:

  • High bill cases (898) were up 139%.
  • Billing error cases (593) were up 30%.
  • Billing cases related to concessions (330) were up 57%.
  • Credit cases about payment difficulties (346) were up 16%.
  • Customer service cases (222) were up 57%.

The increases contrast with the falls we reported in the last issue of Reflect. Under 'Issues Watch' we explore some of these case trends and the customer experiences driving them.

We're also watching a 54% increase in supply cases.

  • Cases about unplanned outages (135) were up 88%.
  • Cases about planned outages (132) were up 53%.


  • 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
  • This is an archive version of Reflect without data visualisations.

Issues watch

Making life in lockdown even harder

It continues to be a tough time financially and otherwise for many energy and water customers, and a challenging time for energy and water companies. From our tracking of 'pandemic-related' energy and water cases over the last six months, here are some of the issues that have been making life in lockdown even harder.

Life in lockdown is even harder when your billing doesn't add up

Comparing July to September 2020 with April to June 2020, high bill cases were up 139% and billing error cases were up 30%.

Billing has long been the most common issue of complaint to EWOV. Our experience is that many billing complaints can be resolved quickly on a customer's first contact. Swift action by energy and water retailers to work out what's happened goes a long way to preventing the more complex credit complaints of payment difficulties, debt collection, credit default listing and disconnection/restriction (imminent or actual). A better response by companies when customers first raise their billing complaint may avoid the need for them to contact EWOV at all. In the 2019-20 year, 71% of billing cases lodged with EWOV were resolved after we referred the customer back to a higher-level contact within their energy or water company.

Snapshots of the customer experience

  • After a $630 quarterly electricity bill, a customer switched to monthly billing. His first monthly bill of $313 seemed too high, even though he was working at home. His tariff rates had also changed. His retailer maintained the bill was correct. 2020/13649
  • A customer received a $1,144.56 gas bill backdated to October 2019. She couldn't make sense of it. Her gas retailer referred her to the gas distributor, who referred her back to the retailer. 2020/14291
  • A customer's electricity account was closed due to a cross-metering error. After being told he wouldn't be backbilled more than a month, he received a $600 bill. 2020/10928
  • After a customer wasn't billed for 12 months, she received two backbills ($951.05 and $586.49). She queried the billing. Her retailer maintained it was correct. 2020/13278

Life in lockdown is even harder when your circumstances aren't recognised

Comparing July to September 2020 with April to June 2020, credit cases about payment difficulties were up 16% and customer service cases were up 57%.

People who've never needed payment assistance before are increasingly in need. Some energy retailers have taken the view that relief by way of bill deferral sits outside the context of the Payment Difficulty Framework (PDF). We consider that any assistance provided to customers must be within or additional to the PDF — with customers made fully aware of their PDF entitlements, to ensure they're able to reach a suitable agreement with their retailer. More generally, as we've consistently stated, correct application of the PDF is critical to managing widespread customer payment difficulties now and into the future.

Snapshots of the customer experience

  • A customer whose first language isn't English and whose income had dropped 50% received disconnection notices for electricity arrears ($776) and gas arrears ($877). She wanted help to apply for a Utility Relief Grant and an affordable payment plan. 2020/14572 & 2020/14571
  • Out of work, a customer wanted a recent direct debit of $495.52 reversed and his electricity retailer to stop debiting his credit card, so he could manage his payments directly. 2020/14272
  • A financial counsellor was trying to help a non-English speaking customer resolve energy arrears. The retailer wouldn't accept verbal authority to act, insisting on signed authority despite lockdown. 2020/11829 & 2020/11830
  • A single parent had her work hours reduced. She'd made two requests for a payment plan of $100 a fortnight. After her work hours were cut again, she could afford only $60 a fortnight. 2020/13794

Life in lockdown is even harder when you can't get easy access to concessions and grants

Comparing July to September 2020 with April to June 2020, billing cases related to concessions were up 57%.

Applying concessions to the accounts of large numbers of customers who haven't previously received them has been administratively challenging for energy and water companies. Adding to this have been address and name mismatches between the information held by government departments and what's on customers' energy and water accounts. For many customers, ongoing energy and water affordability is linked to their new or recently acquired concessions entitlements. Following its 'Supporting energy customers through the coronavirus pandemic' consultation, the Essential Services Commission introduced an ongoing requirement around Utility Relief Grant (URG) applications from 1 October 2020. Retailers are now required to support residential customers in completing URG application forms, including by submitting forms online on behalf of the customer, where possible and the customer consents.

Snapshots of the customer experience

  • A customer's email requests to have concessions applied met with repeated automated replies advising the energy retailer was experiencing response delays. 2020/10374 and 2020/10375
  • A customer owed $1,432 for electricity. His retailer undertook to send forms for a Utility Relief Grant. No forms arrived despite two follow-ups by the customer. The retailer blamed Australia Post. 2020/13763
  • A customer and her husband had both lost their jobs. She asked about a Utility Relief Grant. Her electricity retailer told her she could apply online. Her application was declined because the forms weren't received. 2020/14252
  • Having lost her job, a customer faced imminent disconnection. Her energy retailer told her to apply for a Utility Relief Grant. She completed the forms and returned them. The retailer maintained it didn't receive them. It resumed disconnection action. 2020/13013 & 2020/13014

Life in lockdown is even harder when your small business can't do business

Comparing July to September 2020 with April to June 2020, billing cases from business customers were up 37%.

For small businesses, additional assistance measures introduced recently by the Essential Services Commission are particularly important. Under these measures -- which started on 1 October 2020 and will run for six months -- energy retailers are required to provide reasonable assistance to small businesses experiencing financial stress due to the pandemic. In addition, under the Energy Retail Code, small businesses adhering to a payment plan can't have supply disconnected for non-payment.

Snapshots of the customer experience

  • A customer's small business was operating as take-away only due to lockdown. Having switched retailer, she received a $4,198 final bill that she disputed. The retailer maintained it was correct, but it offered a $2,400 reduction. 2020/11203
  • A self-employed customer, whose income had dropped severely, received a quarterly electricity bill of $411.61. He was offered a one-month payment extension, but no other payment assistance. 2020/12883
  • A small business owner of 30 years had to close due to lockdown. He couldn't pay a $5,244 gas bill. He found it hard to talk to his retailer's customer service representatives. 2020/13110
  • With his business closed, a customer asked his electricity retailer for a payment plan. The retailer wanted $10,000 a week, then an up-front payment of 50% of the arrears and, finally, $15,000 a fortnight. The customer could afford only $1,000 a week. 2020/10155


Despite lockdown restrictions, we've continued EWOV's outreach work, adopting a mix of approaches.

After the lockdown of the housing towers in early July, we provided information on energy and water issues (including availability of interpreter services) to the cultural groups, financial counsellors and legal centres supporting the residents. Our aim was to raise awareness of how important it was for customers in those buildings to contact their energy and water companies, if they weren't going to be able to maintain their existing payment arrangements or pay their bills. More generally, we've also provided flyers for inclusion in emergency relief packages, and posters to be put up in St Vincent De Paul stores across Victoria as restrictions ease.

In the last three months, we've delivered virtual information sessions to over 450 people. These have been focused on complaint trends, customer rights and responsibilities, and EWOV's role. Local councils have been a particular focus because of their extensive involvement in programs that reach seniors, young families, people in need of emergency relief packages, and culturally and linguistically diverse communities. We've also delivered sessions to scheme participants. These have focused on emerging issues, the needs of vulnerable customers, and on raising awareness of the broader role EWOV plays in engaging with community and government stakeholders.

Customer stories

Solar panels working, but credits missing


Case number: 2020/9358

Mr P complained that, even though he'd installed solar panels in January 2019, his electricity bills were still high. He said his electricity retailer acknowledged a billing error, but he couldn't understand how the error was corrected, how much his account was in credit and why, if he was in credit, he still received bills. When Assisted Referral didn't resolve the complaint for Mr P, we opened an Investigation.

EWOV's Technical Consultant reviewed Mr P's accounts. He found that the meter at Mr P's property was configured for solar, that he was exporting more than he was drawing from the grid, and that his solar export been billed correctly.

The retailer confirmed the meter at Mr P's property was configured for solar in February 2019. It said his solar system had generated solar credits of $645.30 between February 2019 and May 2020, but these hadn't been applied to his account. It said the incorrect invoices had now been withdrawn and reissued, in line with the Energy Retail Code's nine-month limit on backbilling, and that Mr P's account was in credit for $377.09. Responding to further questions, the retailer advised that Mr P wasn't on its 'best offer' for his usage and circumstances. We explored with the retailer other tariff and payment options which may benefit him.

The retailer apologised to Mr P and credited his account with a customer service payment of $250. Following a further data review, it provided another credit of $41.30. This left his account $668.39 in credit. It offered him a better plan with estimated savings of $100 a year, based on his current usage. Mr P was satisfied with the outcome of our Investigation. The complaint was closed.

Surname mismatch affects application of concessions


Case numbers: 2020/9289 & 2020/9293

Having lost her job due to COVID-19, Ms W was on Centrelink benefits. She said that in early June 2020, she asked for her concession details to be applied to her energy accounts. She was told this could happen and her current bill would be amended. Two weeks later, she received a reminder notice and advice that she was at risk of debt collection action. She rang her energy retailer again. She was told her concessions would be backdated to March 2020. She was also promised an amended bill. She then received a letter from the retailer saying concessions couldn't be applied — because the spelling of her name in its system wasn't the same as it was in the Department of Health and Human Services' records. When Assisted Referral didn't resolve the complaint for Ms W, we opened an Investigation.

The retailer confirmed that its attempt to apply concessions to Ms W's accounts failed the validation process, due to 'surname mismatch'. It said that, until it tried to help Ms W with this, it was unaware of the misspelling. Once this was resolved, the retailer applied concessions to both accounts, backdated them and re-billed her.

After rejecting several customer service payment offers from the retailer, Ms W accepted two credits —$200 to her electricity account and $150 to her gas account. The retailer apologised that Ms W had received the reminder notice when her account was supposed to be on hold. It confirmed that she was now receiving both the Annual Concession (electricity) and the Winter Energy Concession (gas) backdated to March 2020. The complaint was closed.

Disputing the health implications of Smart Meters


Case number: 2020/9967

Mr E, a public housing tenant, complained about the placement of five Smart Meters on the external wall next to his bedroom. He said the meters were constantly communicating with the 5G towers, affecting his health. He wanted a shield around the meters, or the meter box relocated. When Assisted Referral didn't resolve the complaint for Mr E, we opened an Investigation.

Mr E's retailer acknowledged his concerns, but said that the meters weren't 5G-compatible, so they couldn't communicate with 5G towers. It explained that a request for meter relocation would have to come from the Office of Housing (OOH) as the owner of the property. The work would need to be carried out by the local electricity distributor at OOH's expense.

Alternatively, the local distributor could remove the communications module from the meter for Mr E's unit only, preventing it from communicating remotely, but leaving the other meters unchanged. However, that would mean the meter would have to be read manually, and a fee would apply. Mr E could contact the local distributor directly to discuss this option, but he'd need to provide a medical certificate to support that the removal was for health reasons. The retailer wouldn't agree to install electromagnetic shielding around the meters.

We explained to Mr E that, as he wasn't the owner of the property, the meters couldn't be relocated at his request — the request would have to come from OOH. We advised that, based on EWOV's experience, it would be unlikely that a distributor would install shielding around a meter or metering panel, especially where EMF is within the allowable limits. We shared with Mr E information about the requirements for Smart Meters in Victoria set out by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).

Mr E maintained that the scientific evidence was outdated, and the advent of Smart Meters had changed things. He sought a range of technical information about meter communications. We suggested that he contact the local distributor with these questions. The complaint was closed.

Elderly customer puts up with loss of heating


Case number: 2020/10192

Ms B's daughter contacted EWOV on behalf of her 91-year-old mother, saying her mother was often without gas (and therefore heating). She understood this was due to problems with water entering the gas pipes. She said other residents in the same block of units were similarly affected. When Assisted Referral didn't resolve the complaint, we opened an Investigation.

The local gas distributor acknowledged the outages, saying a high-pressure mains upgrade scheduled for 2022 in Ms B's area would permanently resolve the water issue. Recently, several leaks had been found nearby and fixed the same day. In addition, over the past month it had undertaken significant repair works nearby, including fixing a broken service tee which was likely the cause of recent water in the pipes. It was confident that these works had resolved the latest issues. It said Ms B's gas line had passed recent pressure testing.

We explained to Ms B's daughter that gas supply in Victoria is not guaranteed. However, gas distributors are required to make Guaranteed Service Level (GSL) payments to their customers as follows — $150 for an outage of more than 12 hours; $300 for an outage of more than 18 hours; $150 for the fifth outage in a calendar year; and $150 for the tenth outage in a calendar year. The payment is made through the gas retailer. We reviewed the property's fault report, finding seven supply disruptions so far in 2020. This meant Ms B was eligible for a GSL payment of $150 (fifth disruption).

We advised Ms B's daughter that $150 would be credited to her mother's account. We confirmed the gas distributor's advice that the scheduled 2022 upgrade would provide a more stable high-pressure gas supply and fix the water issue. We also explained that, because the works were of such a large scale, we couldn't request that her property be upgraded to high-pressure sooner.

The gas distributor apologised to Ms B. To ensure priority for her during any future outages, it flagged her account as 'vulnerable'. Ms B's daughter accepted the outcome of our independent Investigation. The complaint was closed.

We advised Ms B's daughter that $150 would be credited to her mother's account. We confirmed the gas distributor's advice that the scheduled 2022 upgrade would provide a more stable high-pressure gas supply and fix the water issue. We also explained that, because the works were of such a large scale, we couldn't request that her property be upgraded to high-pressure sooner.

The gas distributor apologised to Ms B. To ensure priority for her during any future outages, it flagged her account as 'vulnerable'. Ms B's daughter accepted the outcome of our independent Investigation. 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

From July to September 2020, we closed four systemic issues (all energy) identified through our case handling.

Disconnection notices missing information about reconnection

An energy retailer's disconnection notices for 'unknown deemed contract' customers didn't outline reconnection procedures, as required under the Energy Retail Code. The retailer didn't consider the issue was systemic. But, in February 2019, it changed its wording to include reconnection procedures and agreed to compensate affected customers where they could be identified. SI/2019/16

Problems with bulk billing of hot water customers

An energy retailer trying to fix hot water faults said it faced infrastructure access issues, requiring multiple contacts with building management and individual owners. On top of this, its billing system wouldn't recognise addresses with alpha-numeric values. The retailer undertook not to bill customers for bulk hot water until the access issues were resolved, and then to comply with the current nine-month limit on backbilling. It said a system update scheduled for September 2020 would fix the address issue. SI/2019/5

Customer referred to financial counselling without other assistance

An energy retailer was referring customers with payment difficulties to financial counselling, without providing them with assistance. Under clause 91 of the Energy Retail Code, a retailer must not impose any condition on the provision of payment difficulties assistance. The Essential Services Commission is investigating. SI/2020/18

Customers wrongly informed meter readings would be estimated

An energy retailer had been telling customers their meter readings would be estimated because meters weren't being read due to COVID-19. Customers could provide a self-read if they wished. The retailer told us it had received conflicting information about meter readings, so thought it best to warn customers. Once it became clear that distributors were still reading meters, it stopped doing this. SI/2020/26

Public submissions

Draft Decision – Supporting energy customers through the coronavirus pandemic

Essential Services Commission (ESC)

In EWOV's response to the ESC's Draft Decision, we drew on our close tracking of 'pandemic-related' cases. We supported the proposed residential customer measures as moderate and sensible proposals that complement the existing Payment Difficulty Framework. We supported the proposed approach for small business customers, as combining flexibility and engagement, and encouraging positive retailer-customer dialogue to arrive at the most suitable arrangement for the customer's circumstances.

EWOV's submission online

ESC's Final Decision

Consultation Paper – Consumer Data Right – Energy Rules Framework

Australian Competition and Consumer Commission (ACCC)

Our submission to this consultation paper broadly supported the proposals outlined by the ACCC as thorough and sensible. We made a number of specific comments including about eligible consumers, internal dispute resolution, phased implementation and accreditation.

EWOV's submission online

ACCC's consultation paper


Visit the Data Hub for a full glossary of terms.