From: johanna axisa1 <email@example.com>
Sent: 09 July 2018 17:32
To: firstname.lastname@example.org; email@example.com
Subject: Re Invoice Number 25655574
FAO Mr John Attard, Arms CEO
FAO Mr Joe Mizzi, Minister for Energy and Water Management
Re Invoice 25655574; €497.64
I am writing to you to put on record that - over the billing period 10th March 2017 to the 9th March 2018 - our household has been overcharged by the amount of €152.91, in contravention of the Electricity Supply Regulations.
I have attached an Excel spreadsheet which shows how I have come to this conclusion. I used the second page of the last 6 two monthly Arms bills to calculate the total number of units at each band charged. To my surprise, our annual consumption of 8868 units of electricity did not utilize all the quotas at the cheaper rates. We lost out on 341.22 units of electricity at €0.1298 per unit, 2005.48 units of electricity at €0.1607 per unit and we were also charged at €0.3420 per unit on 1215.01 units of electricity. We should never have paid at the €0.3420 per unit band because we did not breach the 10000 units per year, to be liable at this band, as stipulated by the Electricity Supply Regulations.
Additionally, I would like to say that the cost of our electricity over the last year has ranged from €1.60 per day to €8.00 per day and from €0.12 per unit of electricity to €0.20 per unit of electricity.
This is problematic - who wants to have to pay bills of €401.68 for November to January and €456.08 for January to March? These two bills - representing our electricity cost of 4 months - amount to 60% of the total annual cost of electricity for our household. We were billed for the remaining 40% of the total cost over 8 months. This is simply not tenable and will create huge problems for people with cash flow issues.
Unfortunately, Arms is the sole, state owned utility billing company. Therefore, under duress and without prejudice to any legal action I may consider in the future, I enclose two cheques – one for the amount of €344.73 and the other for the overcharge of €152.91. These total to the €497.64 we were billed for the billing period 12th January, 2018 to 9th March, 2018 (invoice 25655574).
I would like to think that you will carefully study the Excel spreadsheet and understand that we have indeed been overcharged. If that is the case, then please return the uncashed cheque in the amount of €152.91.
I would ask you to pass on this correspondence to any authority, responsible for the overseeing of the correctness of Arms bills. I have tried to ascertain which entity is responsible, to no avail.
I used the Arms online calculator to check my workings. As you no doubt know, the crux of the problem is that the billing period - in number of days - constitutes part of the algorithm for calculating the cost. So - simply put - to work out the cost of the bill, the algorithm will calculate the pro rata quota of allowances, according to this number of days. If the billing period is a year, then there would be no problem at all. But because the billing period is chopped up into 6 two monthly bills, then the pro rata quotas will not be at all sensitive to the peaks and troughs of consumption over the year.
In fact, this, of course, is the reason for the lengthy disclaimer that comes with the Arms online calculator. The cost depends very much on the length of the billing period.
I used the Arms online calculator to check my workings and the Arms online calculator, in fact, agrees with me, minus a discrepancy of €0.70. I have attached a screenshot of this Arms online calculation.
Edit - 13/7/2018: I've narrowed the discrepancy between the Arms online calculation and my workings from €0.70 to €0.06. The dates I entered in the first version were the 9th March, 2017 to the 9th March, 2018, when in fact they should have been the 10th March, 2017 to the 9th March, 2018. The remaining €0.06 discrepancy is likely due to rounding.
Finally, I would like to say that this analysis is the analysis of the cost for our household for this last year. Of course, it will differ from household to household and from year to year. The point is that it will be an exceptionally massive fluke if the cost with annual quotas were to match exactly the cost with pro rata quotas. Surely Arms needs to look at this situation urgently to ensure that consumers of electricity are not paying over the odds. Maybe a look at the UK will do the trick? When I lived in the UK, we paid a fixed amount by direct debit per month over the year (which also solves the issue of paying 60% of the annual cost over 4 months), with the understanding that there would be an adjustment at the end of the year, if needs be.
I hope to hear from you soon.
PS Letter with cheques sent by post