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Cynthia Gebert

"We believe that the ongoing COVID-19 pandemic and the associated restrictions, and stable electricity prices, are having an effect on our case numbers."

Case numbers rose in the July-September quarter of 2021, up 9% compared to the previous quarter but down when compared to the same time last year. We typically see a rise in billing cases in the third quarter of the year, coinciding with the time when customers usually receive their winter bills. Billing cases still accounted for 49% of our cases received in the July-September quarter but overall billing cases were down 25% when compared with the same time last year. We believe that the ongoing COVID-19 pandemic and the associated restrictions, and stable electricity prices, are having an effect on our case numbers. Our cases have been trending down since the 2017-18 financial year but the steepest declines have taken place in the COVID years of 2019-20 and 2020-21.

Speaking of the financial year, we released our Annual Report on 28 September 2021, looking back on a full year of COVID-19 and the significant effects this has had on the Victorian community. We reported that case numbers were 18% lower in the 2020-21 financial year compared with the previous year but a closer look suggests that there are significant issues in the Victorian community, particularly around affordability, and many of these issues are evident in our case studies. I encourage you to visit our dedicated Annual Report 2021 page, featuring interactive data visualisations, where you can access more information and read the full report.

Issues watch

Planned outage cases (Off supply – Planned) rose 58% in July-September 2021, when compared to the previous quarter, increasing from 72 cases to 114 cases. This comes after planned outage cases jumped 140% in the April-June 2021 quarter when compared to the first quarter of 2021, an increase from 30 to 72 cases. These rises in planned outage complaints coincided with reintroduced stay-at-home restrictions in Victoria for a significant part of each affected quarter, particularly the July-September 2021 quarter.

The July-September 2020 quarter, when Victoria was in the midst of the second wave lockdown, was another period of high planned outage cases. We received 132 cases in that period.

We’ve also experienced increases in unplanned outage complaints in periods of lockdown. In the April-June 2021 and July-September 2021 quarters, we received 191 and 167 unplanned outage cases respectively, up from the 83 cases we received in the January-March 2021 quarter, when Victoria was largely free of COVID-19 restrictions – the impact of the storms in June 2021 continued to drive complaints over the last quarter with a number related to compensation.

There is clearly a correlation between periods of stay-at-home restrictions and complaints about outages. We believe this is due to residents being forced to spend more time at home and customers being more aware of and impacted by outages when under stay at home restrictions.

It is prudent for energy and water companies to communicate early and often with affected customers, in advance of the minimum notice period requirements under relevant codes. Positively, we have seen some improvement in this area. However, there remains an opportunity for distribution and water businesses to further consider the impact of planned outages on customers and share learnings across the sector to drive further improvement. It may also be important to determine any additional needs of customers and work to meet these needs, including reducing the periods of outage at this time.

Out of 338 billing tariff complaints we received in July-September 2021, a significant proportion of these (29%) relate to solar feed-in tariff complaints.

Solar tariffs and credits can be confusing for customers and this confusion can be exacerbated by errors and opaque processes. In our solar customer story in this edition of Reflect, we highlight a case where a customer missed out on solar credits due to an error during the contract renewal process. The customer was concerned about the amount of credits they were entitled to and our Investigation included our technical and data expert reviewing bills and meter data to ensure that the customer had been billed correctly.

We also continue to receive complaints about customers being moved from the premium feed-in tariff to the market rate, at or above the minimum feed-in tariff, when they make changes to their solar system. The new tariff these customers receive is typically well below the premium feed-in tariff. In many cases, customers were unaware that upgrading their solar system would lead to a change in their feed-in tariff, creating further confusion and complexity in the energy market.

We typically receive a lot of high bill complaints in the July-September quarter, due to the timing of winter bills. We received fewer high bill complaints in July-September 2021 than we did at the same time last year, down from 890 to 662 cases. As a proportion of all billing complaints, however, high bills made up 28% in both July-September 2021 and July-September 2020, suggesting that it is the overall drop in billing cases that is responsible for a quiet high billing quarter. As with all complaints, there may be a lag in billing cases and we may experience an increase in the last quarter of 2021, as lockdown restrictions start to ease and customers have more time and capacity to deal with their complaints.

The big picture

  • From July to September 2021, we received 4,874 cases, up 9% from the previous quarter but down 18% from the same quarter in 2020.
  • Billing cases rose 29% compared to the previous quarter but were down 25% compared to the July to September 2020 quarter.
  • We received 662 high billing cases from July to September 2021, down from 890 high bill cases from the same time last year.
  • Credit cases dropped 6% in the quarter, compared to the previous quarter. Credit cases were also 6% down on the same time last year.
  • Credit-related disconnection/restriction cases dropped 24% compared to the previous quarter, as Victoria remained under strict COVID-19 restrictions for the majority of the period.
  • Planned off-supply cases rose 58% compared to the previous quarter (from 72 cases to 114 cases).


  • 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.

Customer stories

Payment difficulties lead to disconnection and incorrect debt collection


Case number: 2021/10756 & 2021/10758

Isabel* called us with a complaint about their electricity and gas retailer in July 2021. They said that their electricity and gas were disconnected on 14 December 2020. At the time, they said, their business was struggling and their partner had lost their job. Upon contacting their retailer, Isabel said it told them to sign with another major retailer, because it would not accept them as a customer, and in return it would waive the debt. Isabel did not receive written confirmation. They contacted another retailer and had the electricity and gas connected that afternoon. Isabel told us the original retailer subsequently sold the debt of over $7,000 (gas) and $9,000 (electricity) to a third-party debt collector. Isabel was seeking an end to the debt collection activity and for the original retailer to waive the debts.

We started an Investigation, using our discretion to bypass the usual Assisted Referral stage due to the amount of arrears and our concerns that the complaint couldn’t be resolved quickly. The original retailer confirmed that on 14 December 2020, Isabel was offered a waiver of their debt if they transferred their electricity and gas away from the retailer. It confirmed that an error occurred and their electricity and gas accounts were incorrectly sold to a third-party collection agency. During our Investigation, the retailer told us they had now sent a request to the third-party agency to return the debts to the retailer and that, once that had taken place, it would waive the debt. It confirmed that Isabel had not been credit default listed and offered a $100 customer service payment.

The retailer apologised for any inconvenience caused. Isabel told us they were satisfied with the outcome of the complaint and we closed our Investigation.

* Name has been changed

Planned outage notice leads to self-harm check


Case number: 2021/10513

Clive* lodged a complaint with us via our online complaint form. They indicated that their electricity distributor had informed them of a power outage from 7.30 am to 3.30 pm. After contacting the distributor, Clive said that it changed the outage to 8.00 am to 12.30 pm but that they were still dissatisfied as there were two family members working from home and they would not have access to heating or lights. They wanted the outage deferred until after the COVID-19 lockdown was lifted. They indicated that they had emailed the Premier of Victoria and would attempt to contact the media about the issue.

We initially raised the request as an Assisted Referral to the provider but Clive’s distributor subsequently asked us to investigate the complaint. We raised an Investigation and asked the distributor to review the customer’s contact history and provide a summary of how it complied with codes and laws, among other requests. Clive’s distributor responded with call logs from Clive’s initial contact about the issue indicating that they were yelling on the phone, demanding the works to be cancelled and that they intended to contact the police and Premier of Victoria about the issue. The case was escalated to a manager who tried to contact Clive without success. A call log showing subsequent contact with Clive recorded that, despite being notified that the outage period had reduced, Clive argued that the works should be rescheduled and that they threatened self-harm/suicide. The distributor subsequently called the police to conduct a welfare check. The distributor informed us that the power interruption was necessary and that they informed Clive of the outage in advance of the minimum four days’ notice required by the Electricity Distribution Code. It indicated that it is undertaking regular reviews of all planned work to ensure it minimises the impact to customers either by reducing the number of impacted customers or the duration of work as much as practicable.

We wrote to Clive indicating that, while we understood that lockdowns are stressful and why they would be requesting a change to the outage, we did not find any laws, codes or rulings that would support the request. We asked Clive to contact us by a set date with any information that could change the outcome of our Investigation. As we did not receive that contact from Clive, we closed our Investigation, noting that their distributor had met its requirements under the Electricity Distribution Code.

We recognise the mental health issues some customers experience, which may arise or be exacerbated by the COVID-19 pandemic. This may lead to behaviours not seen before from some customers.

* Name has been changed

Delay for missing solar feed-in credits leads to confusion


Case number: 2021/9934

Anniyah* contacted us on our 1800 number about missing solar feed-in credits. They told us they had solar on their property for around two years and had not been receiving the solar feed-in tariff. They said they contacted the retailer and it advised the issue was due to it being winter and there not being enough sun to generate credits. After more contact with the retailer, Anniyah’s retailer said that it would investigate and apply two years’ worth of missing credit but Anniyah was still waiting.

We initially raised an Assisted Referral to the retailer. Anniyah contacted us again to let us know that the retailer had said it would reimburse them $166.05 but they do not think this is enough. As Anniyah was not satisfied with the outcome of the Assisted Referral, we opened an Investigation.

As part of our Investigation, we looked at the national meter database to confirm that Anniyah’s meter was upgraded to solar on 16 September 2019. but the system was not switched on until 14 October 2019, which was the responsibility of Anniyah and their solar installer. We confirmed that solar feed-in credits were applied to Anniyah’s account from 14 October 2019 until 11 June 2020, when an agent at the retailer incorrectly processed a contract renewal without feed-in credits. We confirmed that, after Anniyah’s complaint to the retailer, it reissued the bill from 12 June 2020 to 13 June 2021 with solar credits applied, putting the account in credit of $296.90. The retailer then issued a bill from 13 June 2021 to 19 August 2021, leaving a credit of $76.54 after pay-on-time discounts were applied. The retailer advised that all future bills would have solar credits applied.

Our technical and data expert reviewed Anniyah’s bills against the meter data and confirmed that they had now been billed correctly. Anniyah told us they were satisfied with our investigation and we closed the case.

* Name has been changed

Payment difficulties with solar


Case number: 2021/8430 & 2021/8439

Bilan* attended an outreach event in Melbourne in July. They required an interpreter and were experiencing payment difficulties. We discovered that Bilan owed more than $2,000 for electricity and $500 for gas. They were paying $65 for electricity and $52 for gas per fortnight but their bills stated that they needed to pay $325 and $98 per fortnight, which they could not afford. Their recent electricity bill shows a saving of $600 per year for the best offer. Bilan stated that they had solar but didn’t believe they were receiving the correct rate. We took Bilan’s complaint at the event and raised the case as a discretionary Investigation without an Assisted Referral, due to the special circumstances of communication and payment difficulties.

As part of our Investigation, Bilan’s retailer confirmed they were on its payment difficulties program and were being assisted by its team for payment difficulties. The retailer advised that Bilan’s usage was high, especially in winter. The retailer confirmed that Bilan was receiving solar benefits and had received Utility Relief Grant Scheme (URGS) payments in 2020, however, the payments had not reached the limit for URGS and Bilan may be eligible for further URGS payments. It also confirmed that Bilan was receiving the Annual Electricity Concession and the Winter Gas Concession. The retailer confirmed that Bilan was on the best plan for gas. It advised that, while Bilan was on the best plan for solar electricity buy back, another plan may be better overall as it had cheaper rates and Bilan’s solar system was getting older and less efficient. To help with the usage and arrears, the retailer advised that it will continue to regularly inform Bilan of usage with the aim of reducing consumption. The team agreed to contact Bilan to discuss how it can further assist them. Bilan told us they were satisfied with the resolution and we closed the case.

* Name has been changed


Our focus on community outreach and engagement supports our goal of increasing accessibility and awareness of EWOV while building relationships with organisations that work with Victorian energy and water consumers who may be at the greatest risk of experiencing financial vulnerability.

In July, just prior to this round of lockdowns, we participated in two face-to-face Power Savings Bonus Outreach days presented by Wyndham Community and Education Centre together with Consumer Policy and Research Centre. EWOV participated in this event alongside AGL. We lodged 32 cases from 16 community members, featuring 22 energy cases and 10 water cases. All but one case related to a billing error issue that we raised in the last edition of Reflect, where some community members are not registered correctly in billing systems and this results in trouble accessing the relevant concessions and support from retailers.

In August, our Ombudsman, Cynthia Gebert, hosted a roundtable with a focus on identifying barriers to accessing support. We brought together staff from water businesses and representatives from the Victorian Pride Lobby, Community Information & Support Victoria (CISVic) and the Victorian Aboriginal Legal Service in order to highlight barriers in accessing support and the impact they can have on future engagement with businesses. Our aim with these sessions is to give retailers the chance to understand the experiences of their diverse customer base and offer practical advice to enhance their approach to case handling.

Cynthia also participated in a higher education provider and international student webinar where she spoke about some of the issues impacting international students, many of whom reside in embedded networks, with little or no income, facing disconnection and are unaware of their entitlements or the importance of maintaining contact with their retailer. She also participated in sessions with Aboriginal Housing Victoria, and the Financial Counselling Victoria Gippsland and East Gippsland Region Meeting. Our Head of Operations and Experience, James Lawson presented to the Services Australia South East CALD Network. The focus of these events is on sharing insights and trends identified in our casework and systemic issues investigations, and also drawing on the expertise of community agencies and the experience of their constituents, to inform our own approach to case handling.

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 2021, we closed nine energy systemic issues and one water systemic issue identified through our case handling.

Concession issue in housing complex

At one of our outreach events, we identified a systemic issue related to a public housing complex. The complex had an incorrect postcode recorded on the National Electricity Market (NEM) retail system, Market Settlement and Transfer Solutions (MSATS), which resulted in customers not being able to validate their concession. The network rectified the issue for customers who complained. We informed the network of the systemic issue and it corrected the inaccurate information recorded on MSATS for all affected properties. SI/2021/32

Discrepancy in index reads

Through our casework, we identified a discrepancy between meter reads and usage registered with one retailer, specifically the index reads included in customer bills. The retailer advised us that on all customer bills the date range selected for the index meter read did not match the actual billing period, adding approximately one additional day, and could affect in excess of 40,000 customers. The retailer initially accepted that there was an issue but subsequently changed its view, noting it did not rely on index reads to calculate customer bills. It did not accept that there was a regulatory breach and did not offer a solution. We referred the matter to the Essential Services Commission (ESC) as a potential compliance breach. SI/2021/1

Price structure mismatch

We identified an increase in complaints related to one retailer’s new customers. The retailer confirmed a price structure mismatch between the billing system and the invoicing system, resulting in new customers not being issued their first invoice. After we informed the retailer, it corrected the issue and invoiced all affected customers. All EWOV complaints related to the issue have been resolved and we have referred the matter to the ESC as a potential compliance breach. SI/2020/48

Missing information on payment assistance letters

As part of our casework, we found that an electricity retailer’s payment assistance letters did not have a commencement date or amount and frequency of instalments. The retailer stopped using the letters after we notified them and we noted that any applicable compensation was best dealt with on a case-by-case basis given the time passed and subsequent changes to the regulatory obligations. We notified the ESC through regular reporting. SI/2018/49

Another discrepancy in index reads

We identified another retailer that had a discrepancy between meter reads and usage registered, reflected in the index reads included in customer bills. The retailer suggested that this may have occurred when it received data files prior to midnight from a particular energy network. The retailer advised that it was in the process of developing and implementing a new bill platform that would resolve the issue and that its bills included a ‘guide note’ accompanying the index reads. While we were satisfied that the issue has been resolved, we referred the matter to the ESC as a potential compliance breach. SI/2021/46

Postcard leads to potential privacy breach

We identified a potential privacy breach, following the use of an open-faced postcard threatening disconnection to a ‘dear occupier’ account. The retailer noted that the method was used to obtain the unknown customer’s attention and prompt action, and that it does not consider the matter a privacy breach. Given the unique circumstances of a potential privacy breach, we didn’t consider the issues systemic. However, we will include the matter in our regular reporting to the Office of the Australian Information Commissioner (OAIC). SI/2020/46

Credit card payments processed twice

We identified, via case handling, that a retailer had processed credit card payments twice for some customers. The retailer advised that the issue lies with a third party it used to send automated communications like SMS and email, with embedded capability regarding payments. It found a total of 394 instances where credit card payments had been processed twice. The issue was resolved via a credit note to customers and a lesser amount payable. All other customers were notified of the issue, awarded a credit and advised they could contact the retailer should they want a refund. We were satisfied with the proposed resolution. SI/2021/37

Disconnections during pandemic

A retailer pursued a disconnection using a bill issued in September 2020, against the written advice from the ESC, which said that retailers should use bills issued after 1 November 2020. The retailer implemented a series of changes including ceasing disconnections based on invoices issued prior to 1 November, and changing the COVID-19 assistance information provided to customers. We were satisfied with the action taken and notified the ESC for its consideration. SI/2021/43

Privacy measure and concessions

After the Department of Families, Fairness and Housing (DFFH) introduced a privacy measure to people who have experienced family violence, hiding their postcode from systems accessing customer information, the three-monthly electronic validation of concessions was impacted. A retailer was then asking customers to obtain a written form every three months in order to maintain a valid concession card status and would not offer an extension on the frequency. The retailer agreed that, where a customer advises that they are unable to complete the quarterly form, the retailer would approach DFFH and ask for a greater frequency. SI/2020/43

Less communication before debt collection

We received several complaints between May and June 2021 about a water corporation and third-party debt collection. Across the cases, customers had not received final bills or payment reminders following closure of their accounts and were then contacted by third-party lawyers requesting payments, often for amounts less than $150. The water corporation advised that, due to COVID-19, it paused issuing bill reminder notices and other billing collection activities. It confirmed that it had referred to a third party debt collector when customers were no longer receiving invoices, finalised account holders and customers with outstanding amounts of more than two bills. The water corporation has ceased this practice, resumed normal communication and no longer refers debt to a third party. SI/2021/48


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