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
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