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The New Zealand Association of Citizens Advice Bureaux welcomes
the opportunity to comment on the Electricity Complaints Commission
Code of Practice.
Our
submission provides a brief overview of electricity-related enquiries
bureaux deal with, we make some observations about companies’
obligations under the Code, and we make a comment on the submission
time period.
Citizens
Advice Bureau and electricity enquiries
Our
87 Citizens Advice Bureaux dealt with 9,393 electricity-related
enquiries between July 2001 and June 2002; a 42 percent increase
over the previous year. Table 1 below details the number of electricity-related
enquiries bureaux have dealt with since 1998. Over the four years
since the electricity reforms our electricity-related enquiries
have increased by a massive 400%. Many of these enquiries involve
customer problems and complaints in areas of switching, billing,
credit policy and disconnections.
|
Year
|
Number
of electricity-related enquiries |
|
1998-1999
|
1,887
|
|
1999-2000
|
3,316
|
|
2000-2001
|
6,640
|
|
2001-2002
|
9,393
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Observations
on the Code of Practice
While
the increase in these enquiries is dramatic, bureaux are reporting
anecdotal evidence that the Electricity Complaints Commissioner
scheme is beginning to have some impact on the way electricity retailers
deal with their customers. The scheme has two key elements. The
first is the Electricity Customer Code of Practice, which binds
members to a minimum set of standards for dealing with customers.
The second is the complaints and disputes resolution process, involving
the requirement for members to have their own effective procedures
for dealing with customer complaints and the Commissioner’s
own process to deal with complaints that are not satisfactorily
resolved by the company. The results of these two elements are being
demonstrated in two ways.
The
Code of Practice has seen members put effort and resources into
improving the way they deal with customers across of a range of
issues, including standards of service, bill payments, bonds, meter
reading and disconnections & reconnections. Early evidence suggests
that the Code has lead to initial improvements in customer service
from those companies that are members of the scheme.
Further,
in those cases where customer service has been poor or when the
Code has been breached, customers have been able to use their company’s
internal complaints processes. And for customers where the outcome
to their complaint has not been satisfactory they have been able
to have their complaint heard by the Commissioner.
Citizens
Advice Bureaux have welcomed this scheme, as it has provided a useful
and effective avenue for customers. In the past bureaux have often
needed to advocate between retailers and customers, and some companies
had not been open to this. The Commissioner is in a strong position
to take this role with member companies.
We
still hold major concern about those companies who have failed to
become members of the scheme; therefore denying their customers
that avenue to seek resolution.
The
Association is generally happy with the current Code. Indeed, the
Association was intensively involved in the drafting of the Code,
and we consider that it is a good code of practice. However, we
remain concerned with how the industry is currently operating in
terms of meeting their obligations under the Code. Our statistics
demonstrate customers are still clearly having difficulties with
their company, but with time we hope that companies will increasingly
meet their obligations under the Code.
Consultation
period
The
Association would like to make a final point about the period allowed
for submissions. The Association has a policy of inviting bureaux
input, in terms of feedback based on client evidence, into our submissions.
For that to work effectively we require adequate time. We consider
that a 3 week consultation period does not provide adequate time
for us to provide extensive comments, or seek additional feedback
from bureaux.
We
were fortunate in this case that we already had a wealth of client
evidence provided by bureaux, simply because electricity enquiries
have been a major area of work for bureaux over the past four years.
We cannot always rely on this being the case.
Therefore
we strongly recommend that the Commission provide a longer time
period for any subsequent consultations.
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