inclusive policy, social development

Strengthening & streamlining energy advice & redress

An independent review of the adequacy of energy advice and redress –

consumer journeys (June 2015)

Georgia Klein 07939 541 807

georgia@georgiaklein.co.uk

Introduction

The following four flowcharts attempt to convey the journey an informed consumer would theoretically take to gain relevant and comprehensive energy

advice or redress for four typical presenting issues. They illustrate the degree of integration of the schemes and the complexity of the consumer journey

and helpfully provide an oversight of how Government policies have shaped the potential consumer experience. However, these journeys should not be

presumed to reflect the reality of consumer experiences. Real consumer experiences will be shaped by their level of understanding of the support available,

willingness to engage with it and the degree to which consumers receive poor quality advice from other organisations which have no Government mandate

or regulatory oversight as well as those that do.

The journeys have been built using information on advice and redress scheme remits (see Chapter 5, figure 5 and Chapter 6, Figure 9 in the full report) and

information the scheme providers gave on referrals both into and out of the scheme (see Appendix 8) as well as further references where needed. They are

intended to be illustrative and therefore will not convey the detailed processes of each individual scheme.

Four consumer issues are presented to illustrate a range of engagement with advice and redress providers:

1. A domestic consumer seeks advice because the central heating (in the home they own) is not working and they are concerned their boiler is broken.

It is winter and they are worried about the costs of fixing this.

2. A micro-business consumer seeks advice because the energy bills for their lighting shop are very high. How can they get them as low as possible?

3. A domestic consumer seeks redress because their energy bills are higher than they anticipated after having photovoltaic solar panels installed. They

are not sure if this is because they were mis-sold to, they are not being billed correctly or there is something wrong with the installation.

4. A micro-business consumer seeks redress because their energy bill is higher than they anticipated based on past bills. They have moved to new

premises a few months back and have a new supplier but their energy use has not changed.

References used in addition to scheme provider submissions:

Ombudsman Services - how we work

Ombudsman Services - terms of reference

Feed-in-tariffs dispute resolution processes

Green Deal Code of Practice

Ombudsman services - Green Deal

Microgeneration Certification Scheme complaint guidelines

Renewable Energy Consumer Code complaint guidelines

Ofgem's Consumer Confidence Code

Key

Scheme X

Referral to another organisation

Start of engagement with new

organisation

Action X

Action taken by scheme/provider

? Decision point

Journey ends either because this option

is not applicable to the presenting

issue/consumer or further support is

not available

ECO AW Energy Company Obligation Affordable Warmth

GDHIF Green Deal Home Improvement Fund

FIT Feed-in-tariff

Flowchart relating to this scheme continue

on page in direction indicated

A domestic consumer seeks advice because the central heating (in the home they own) is not working and

they are concerned their boiler is broken. It is winter and they are worried about the costs of fixing this.

The flowchart below illustrates the degree of integration between advice schemes but also how frequently a consumer needs to start

engagement with a new organisation in order to secure complete advice. In reality, unless handled well, these represent a threat to the receipt

of full advice. Some of this complexity is also created through overlapping remits/activities. Depending on their point of entry into the journey,

advice provision can be skewed either towards practical support (i.e. a new boiler or reconnection of gas supply) or financial support although

more holistic support is available from some providers. This journey is for a home owner. A tenant would experience a different journey.

Citizens Advice Consumer

Service (GB) Energy Saving Advice Service

(England &Wales) Home Heat

Helpline (GB) Nest (Wales)

Vulnerable?

No

Gas

disconnected?

Yes No

Extra Help Unit

(GB)

EHU work with

supplier to reinstate

gas supply

Advice on benefits, money

management, payment

methods/plans, securing

best deal and reducing

energy use

Eligible for ECO AW,

local authority scheme

and/or Green Deal

communities’ scheme?

Yes

Yes

Advice on possible support

for boiler replacements/

repairs and reducing

energy use, benefits,

money management,

payment methods/ plans,

securing best deal

Energy Best Deal

Extra (GB)

Advice on energy saving

technologies including ECO,

Green Deal, local area-based

schemes and fuel bills

No

Install new boiler/reinstate

supply/ agree payment

plan/change tariff

Home Energy

Scotland

Local authority/ Green

Deal communities’

scheme

Advice on Green Deal,

energy efficiency and low

cost energy tariffs, check

benefit entitlement

Advice on energy saving,

bill reduction, income

maximisation and

renewable technologies

Eligible for Nest?

No Yes

Eligible for

ECO/ECO

AW/WHD?

Further support

needed?

No Yes

Money Advice Trust

/ local services

Assess home & install

efficiency measures

including boiler

Eligible for

benefits?

No Yes

British Gas

Further support

needed?

benefits?

Yes

No

s

Further support

needed?

benefits? No Yes

Local advice

centre/support/ Resource

Efficient Scotland

Advice on securing

best deal, reducing

energy use and debt

Advice on grants, benefits,

payment schemes and

basic energy efficiency

Vulnerable

/Further support

needed?

benefits?

Yes

No

Energy supplier

(GB)

Yes

No

Green Deal

providers

Assess home & install

boiler and possibly

other measures, support

access to GDHIF

N/A

N/A N/A

N/A

N/A

A micro-business consumer seeks advice because the energy bills for their lighting shop are very high. How

can they get them as low as possible?

The flowchart below shows potential weaknesses in the referral mechanisms for advice provision on energy efficiency and micro-generation

measures which may lead to incomplete advice depending on which advice provider the consumer approaches first. For example, the full

referral possibilities between Citizens Advice Consumer Service and Energy Savings Advice Service, Resource Efficient Wales, Resource Efficient

Scotland and Home Energy Scotland are not illustrated as these referrals were not disclosed in submissions (although signposting may occur).

Similarly no evidence was provided that the Energy Saving Advice Service referred to the Renewable Energy Consumer Code although it is

logical that they would do so as RECC approve installers of micro-generation products that may or may not be captured under the Green Deal

licencing approach. The consumer journey becomes considerably more complex from the point at which the consumer wishes to seek tailored

advice on micro-generation products with multiple assessors, installers, licensing arrangements and funding options to consider. Incomplete

prior advice will add to any difficulties consumers have navigating this. It is also noteworthy that whilst Home Energy Scotland’s remit does

include micro-business for the Green Deal, its name does not convey this so a business consumer would have to be highly informed to

approach them outright for advice.

Citizens Advice Consumer

Service (GB)

Energy Saving Advice Service

(England &Wales) Home Energy

Scotland

Resource Efficient Scotland

Advice and Support Service

Business

Wales Resource Efficient

Wales

Advice on Green Deal,

energy efficiency and low

cost energy tariffs

Advice on energy

efficiency

Further support

needed?

benefits?

Yes No

Carbon Trust/ Natural

Resources Wales Stop

Advice and support on

energy efficiency and

micro-generation

Further support

needed?

benefits?

Stop

No Yes

Advice on energy saving

technologies and Government

energy saving and micro-

generation policies and

financial incentives, fuel bills

and smart meters

Further support

needed?

benefits?

Local schemes

Green Deal assessor

Yes

Energy assessment of business

premises completed.

Recommendations made for

efficiency and micro-generation

measures

Select Green

Deal assessor

Select Green Deal

provider/installer

Stop

No

Take out Green Deal

finance plan/hybrid?

Measures installed Ofgem FIT helpline

Eligible for FIT?

Apply for FIT

Stop

Advice on bill accuracy

and securing a better

tariff

Further support

needed?

benefits? No Yes

Stop

Further support

needed?

benefits?

Yes No

Stop

Advice and support to

implement energy

efficiency measures

Further support

needed?

benefits?

Stop

No Yes

Yes

No

Yes No

Yes No

Microgeneration Certification

Scheme

Advice on FIT product and

installers

Proceed with

installation? No

Yes

Stop

Green Deal

Provider/installer

A domestic consumer seeks redress because their energy bills are higher than they anticipated after having

photovoltaic solar panels installed. They are not sure if this is because they were mis-sold to, they are not

being billed correctly or there is something wrong with the installation.

There was little in the way of evidence of referrals between redress schemes shared by providers so signposting included in the flowchart is

based on what would be logical connections between the schemes but this may not happen in practice.

Restrictions on scheme remits and the possibility of more than one reason for this common micro-generation complaint means that this

consumer will need to have detailed engagement with a number of suppliers and then redress schemes in order to identify the reason(s) for

their problem and be assured that it is completely resolved. This demands not only tenacity but a higher degree of understanding of provision

than has been indicated in reality, making the alternative dispute resolution referral remit of the Citizens Advice Consumer Service an

important component of redress provision. However, this is not a substitute for better integration of redress provision through signposting and

referrals and streamlining provision.

The timescales for the stages in the resolution processes are given where made available. They indicate some schemes going beyond the 90

day to resolution time limits set out in legislation either because of the length of their own in-house procedure or because they will only

engage with a consumer once another provider has completed their procedure. Proposed changes to the Microgeneration Certification

Scheme’s procedure (not shown here) will add to resolution timescales.

Energy supplier

Stop

Yes No

Green Deal provider

(only if solar panels purchased

through Green Deal)

Citizens Advice Consumer Service

(if support needed to pursue

complaint)

Billing issue?

Seek advice on complaining about service which

seems incorrectly described /unfair

OK?

Billing error complaint

made (includes FIT)

Decision

(8 weeks)

Yes No

Ombudsman Services

Energy

Complaint made about possible misleading

advice, panel performance resulting from

Green Deal assessor / installer

Complaint investigated

Complaint investigated with assessors and

installer. Their certification bodies are notified.

Decision

(8 weeks)

OK?

Yes No

Stop Green Deal

Ombudsman

Issues arising before

plan agreed?

Yes

No

Green Deal

assessor

Response with proposed

actions to complainant and

certification body

OK?

Yes No

Stop

Certification body or Microgeneration

Certification Scheme Administrator

Solar panel supplier and installer

(only if solar panels not purchased

with Green Deal finance)

Complaint made about possible

misleading advice and panel

performance

Complaint investigated

Supplier response

(7 days if RECC member)

OK?

Member of

certification body?

No Yes

Yes

No

Trading standards /

Court

Stop

Renewable Energy

Consumer Code

Ombudsman

Complaint made about possible

misleading advice

Supplier’s/ installer’s

complaint process

worked through?

Yes No

Green Deal?

Certified

product/assessor

/ installer ?

Financial Ombudsman

Service (if complaint

relates to loan)

Repayment issue?

Yes

Yes

Yes Yes

No

No

No

Acknowledgement

(7 days)

Green Deal assessor

(if no Green deal

finance arranged)

Advice error

complaint made

Response

OK?

Yes No

Trading standards/

Court

Stop

Ombudsman Services

Energy

Certification body or Microgeneration

Certification Scheme Administrator

Green Deal

Ombudsman Renewable Energy

Consumer Code

Ombudsman

OK?

Yes

No

Complaint about billing issue (including

Green Deal charge and FIT)

Complaint investigated (if in remit)

Decision

(6- 8 weeks)

Pursue

redress for

same issue?

Yes No

Complaint made about panel

performance

Complaint investigated (if in remit)

Binding decision

OK?

Yes

Yes

No

No

Complaint made about technical

aspects of MCS product or installation

Complaint investigated (if in remit)

Microgeneration Certification Scheme

Administrator

Pursue redress

for other

issues?

Stop

Stop

Complaint made about MCS scheme,

administration or documentation

?installer

Complaint investigated (if in remit)

Acknowledgement

(3 days) Acknowledgement

(7 days)

Non-binding decision Non-binding decision

OK? OK?

Pursue redress

for other

issues?

Pursue

redress for

other issues?

Complaint made about sales / post-

sales practices of RECC member using

form

Investigations by

OSE, FOS, MCS

concluded?

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

Acknowledgement

(7 days)

Complaint investigated (if in remit)

(as soon as is reasonably possible)

OK?

Yes No

Submit form requesting

independent conciliation (N.B.

consent for arbitration without

prior conciliation is rare)

Continue

with RECC

procedure? Stop

Stop

Yes

Yes No

No

Arbitration/Court

Stop

Conclude other

investigations then

revisit RECC

Pursue

redress for

other issues?

RECC conciliation

Accept decision making it

binding (up to 28 days)

and remedy given

(14 days, 28 days for FIT)

Pursue redress

for other

issues?

Yes No

Arbitration/Court

RECC conciliation

Conciliators non-binding report

agreed (45 days)

RECC arbitration

OK?

Arbitrators binding report and

remedy given

(approx. 6 weeks)

Yes No

Stop

Yes No

Pursue further

redress for

other issues?

Yes No

MCS/Arbitration/Court

Continue

with RECC

procedure?

Submit form requesting independent

arbitration and pay £100+VAT

Stop

Arbitration/Court

A micro-business consumer seeks redress because their energy bill is higher than they anticipated based on

past bills. They have moved to new premises a few months back and have a new supplier but their energy use

has not changed.

The flowchart shows a relatively straightforward consumer journey for a common complaint – billing errors. There is one key redress scheme–

Ombudsman Services Energy. However, if billing issues arise because of problematic price comparison websites or metering arrangements, the

consumer needs to engage with other parties to have the complaint resolved. In the case of referrals to Ofgem, how these complaints are

handled should they arrive there have yet to be determined. It is unusual for micro-business to use a broker. Should the energy be purchased

and paid for through a broker, it is procedurally clear that the consumer should seek support from the Financial Ombudsman Service.

However, a micro-business is more likely to use a broker for switching advice only. The Ombudsman may well also consider such complaints

but this is untested.

Energy supplier

Stop

OK?

Billing error complaint

made

Decision

(8 weeks)

Yes No

Complaint investigated

Ombudsman Services

Energy

Financial Ombudsman Service

(if complaint relates to

switching through broker)

OK?

Yes No

Complaint about billing issue

Complaint investigated (if in remit)

Decision – supplier issue (e.g. applied wrong tariff or meter

reading, faulty meter, back-billing) or no error found

(6- 8 weeks)

Pursue complaint

against supplier?

Yes

No

Stop

Accept decision making it

binding (up to 28 days) and

remedy given (if applicable)

(14 days)

Pursue redress for

other billing issues

(if applicable)?

Yes

No

Arbitration/Court/

Citizens Advice

Consumer Service

Excessive consumption level unaccounted

for. Shared supply with other tenants?

Landlord

Wrong tariff as a result of switching through

price comparison website.

Ofgem’s Confidence

Code approved

website?

Price comparison

website

Complaint about poor advice

/incorrect switch

Complaint investigated

OK?

No No Yes

Ofgem

Stop

Yes