Consumer Protection

Consumer Protection

The Bureau of Consumer Services (BCS) within the PURC Secretariat has the responsibility of ensuring (in collaboration with other bureaux) that the regulated utilities deliver good quality of service to meet consumer expectations.
 
The bureau has been engaged in the following:
  • Providing responsive, efficient and accountable management of consumer complaints;
  • Protecting rights of consumers with regard to quality of service;
  • Advising consumers of their rights and responsibilities, and conducting public education to help customers make informed choices;
  • Investigating consumer complaints and resolving service related disputes.
The following specific activities were undertaken:
 
Consumer Complaints
 
Monitoring of consumer complaints is one of the feedback mechanisms that enable the Commission to respond to consumer demands and to correct lapses in service delivery. In this regard, the Commission has established, and continues to improve on, mutually acceptable channels of communication with consumers to facilitate the process of making, receiving and responding to consumer complaints and concerns.
 
During the period under review, 170 complaints were received and satisfactorily resolved. These complaints include among other things the following:
  • Wrongful disconnections 
  • Wrong billing 
  • Imposition of prepayment meters 
The most protracted complaint was brought by Holex (Eastwood) Timber Products Limited against the Electricity Company of Ghana Limited (ECG). This case, referred to the Commission by the High Court, involved wrong billing and wrongful disconnection. Unfortunately, the Commission was unable to secure an amicable resolution due to the uncooperative attitude of one of the parties.
 
The BCS, with the assistance of the Bureau of Legal Services (BLS), adopts the following steps in resolving complaints lodged with the Commission.
  1. Acknowledgement of receipt of complaint.
  2. Investigation by the BCS to examine the merit of the complaint.
  3. The Utility asked to investigate and submit report.
  4. Receipt and examination of the Utility's report.
  5. Further inquiry and mediation.
  6. Recommendations based on findings to the Commission.
  7. Parties informed about the decision of the Commission.
  8. Monitoring the enforcement of the Commission's decision.
The BCS also assisted in resolving some community complaints, which were not directly lodged with the Commission. These included an acute water shortage in parts of the Central and Ashanti Regions especially in Cape Coast, Mankessim and surrounding areas; and parts of Kumasi East.
 
In all cases, the Ghana Water Company Limited (GWCL) was reminded that any circumstances that result in interruption of water supply to their customers must be explained to them to avoid negative publicity. Moreover, the PURC ought to be apprised of interruption in supply and the steps taken to restore supply. The Commission also demanded that prior notification and explanation of any prolonged interruption in water supply in future must be given to the affected consumers. It must be stated that PURC has ensured the inclusion of these minimum requirements in the utilities' customer charters.
 
As part of PURC's objectives to ensure that consumers are not exploited, and that their rights are adequately and effectively protected, the Commission, in pursuance of Section 3(b) of Act 538, has requested the utilities to post copies of their Schedule of Charges for Services Rendered in front of their offices. This directive has been duly complied with and charges were found posted in most offices of the utilities. The objective was to avoid arbitrariness in pricing, price discrimination and to protect consumers from marketing practices that were unfair or abusive in nature.
 
PURC's Bureau of Consumer Services has prepared a comparative analysis of non-tariff charges of the Volta River Authority (VRA-NED) and Electricity Company of Ghana (ECG) Limited for the consideration of the Commission. The Commission is reviewing the recommendations made to ensure that there is some degree of standardization in the pricing of services rendered by the two sister utility companies. Standardization in pricing would reduce the disparity in the pricing of the same services by the VRA and ECG.
 
In response to some violations in disconnection procedures, the Commission has had to remind the utilities of their duty to comply with the provisions of L.I. 1651 on "Termination of Service".
 
Prepayment Metering 
 
Although the Commission appreciates the reasons given by the utilities for broadening the coverage for prepaid meters beyond their pilot schemes, it however cautioned that adequate preparation and care must be applied in implementing the wider scheme. Important issues such as sensitization of customers to embrace the concept through sustained education, determination of appropriate incentives in the nature of tariff discounts for affected customers, as well as the establishment and operation of a transparent pricing mechanism had to be appropriately addressed. Moreover, the Energy Commission, in collaboration with the PURC is in the process of promulgating the Code of Practice and Standards of Performance Regulations, which would provide the desired framework for prepayment metering by electricity utilities companies.
 
Prepayment Metering - Monitoring
 
Over the years, the VRA-NED, ECG and GWCL have used the conventional credit metering and billing system in their revenue collection efforts. Measures such as termination of service of defaulters, use of bonded cashiers, private debt collection companies, threat of prosecution and raffles did not result in a significant reduction in the debtors' position of the utility service providers. Rather, the debtors' position of these companies worsened. Prepayment metering was seen as a better option for improving the cash flow position and reducing the level of debts owed to these companies by customers.
 
Between 1994 and 1995 ECG ran the prepayment programme on a pilot basis in Accra, Tema and Kumasi for residential and non-residential customers with small loads. Areas where the meters were installed were Adenta SSNIT flats and surrounding areas, Sakumono Estates, some communities in Tema, Asuoyeboah SSNIT flats, Kwadaso, Patase and Danyame areas of Kumasi.
 
Discussions held with the officials of ECG have confirmed prepayment metering as a cost-effective solution for:
 
Improving revenue collection
 
Creating awareness on the need for customers to conserve energy and reduce wastage
Reducing costs associated with meter reading, billing errors, bill production and delivery of bills.
Interactions between the officials of the Bureau of Consumer Services and prepaid customers revealed that a large number of prepaid customers did not want to change to alternative payment methods because of the help prepayment meters provided with budgeting. Avoidance of billing errors, delay in bill delivery and crediting payments were some of the reasons cited for patronizing prepayments meters. Most customers who voluntarily opted for prepayment meters were satisfied with the service provided.
 
However, some of the prepaid customers suspected it was more expensive using the service from the prepayment meters than the conventional metering system. Most of these complainants were non-residential customers like hoteliers and furniture companies. There were also complaints about discrimination in the imposition of prepayment meters on customers. Some customers argued that prompt paying customers should be given the freedom to choose whatever metering system they wanted.
 
In the year 2002, the Bureau of Consumer Services would propose to management to appoint an independent agency to investigate the accuracy and the degree of conformity of the prepayment meters to the PURC approved tariffs. Based on the findings of the investigation appropriate recommendations would be made to the Commission.
 
GWCL and VRA-NED have started the prepayment metering system on a pilot basis.
 
Consumer Protection & Advocacy
 
In our interactions with the utility service providers, the BCS advocated the following changes in delivering improvements in the following specific areas:
  • Making it easier for customers who want to pay by cash or cheque.
  • Providing better information and services for prepayment meter customers.
  • Improved communications with customers in debt and an obligation to take into account the customers' ability to pay when negotiating debt payments.
  • Providing more energy efficiency advice, in particular for customers on low incomes or those with payment difficulties.
  • Improved provision of services and adhering to regulations on special protection for vulnerable customers such as the elderly, chronically ill or disabled. 
  • The following measures that would improve customer service were advocated:
  • Prompt response to billing errors.
  • Prompt response to complaints, faults and leaks.
  • Ensuring metered customers' bills were based on meter readings and ease of telephone contact.
Customer Charters 
 
To enable the PURC to perform some of its statutory obligations of monitoring utility service standards in Ghana, the Commission has requested each of the utility companies to prepare a comprehensive Customer Charter. The Customer Charters will set out the standards of service that customers should expect from the service providers. They will also spell out the obligations and responsibilities of consumers. It is envisaged that Ghana Water Company's (GWC) charter, which is currently going through a review process, will be finalized soon. The ECG and VRA have engaged consultants to assist them draw up performance standards for both technical and customer service areas.
 
Public Education (Public Relations)
 
During the year under review, the Commission, in its efforts to educate consumers and the general public on PURC's functions and activities, produced two consumer brochures that outline in simple language the contents of the two Legislative Instruments so far issued by the Commission. These are the Public Utilities (Termination of Service Regulations) 1999 L.I 1651, and the Public Utilities (Complaints Procedure Regulations) 2000 L.I. 1665.
 
The Commission was also represented on a number of radio programmes and participated in phone-in public education programme on various radio stations. PURC officials responded positively to the numerous enquiries from the media, the public and organizations and welcomes the opportunities offered by the media to discuss the Commission's work and some of the challenges of utility regulation.
 
Regional Offices 
 
Pursuant to the plan of action on the establishment of regional offices mentioned in the 1999 Annual Report, the Commission during the year opened its first regional office in Kumasi. Preparations are being made towards opening a second regional office in Tamale.
Utilities' 
 
Quality of Service
 
One of the Commission's most important tasks, as far as consumers are concerned, is to develop and operate a regulatory framework that requires the utilities to provide to the public, service that is safe, adequate, reliable, and efficient and also at reasonable cost and on a non-discriminatory basis. To that end, the Commission's Bureau of Consumer Services was instituted in the Secretariat with the primary responsibility of monitoring the performance of the utility companies in the delivery of good quality of service to meet consumer expectations. 
 
Some of the functions of the Bureau are to:
  • Provide responsive, efficient and accountable management of consumer complaints
  • Protect the right of Consumers with regard to quality of services
  • Advise consumers of their rights; responsibilities as well as educating the public to enable consumers make informed choices in respect of their services.