To the Ombudsman of Malta
Dear Ombudsman,
In the past years and especially months, the situation
with water and electricity billing in Malta has raised concerns about unfair
billing practices, abuse of dominance, state-aid, discrimination among
consumers and business, and more recently links with offshore business.
Individual queries to State bodies such as ARMS, Enemalta, Water Services Corporation, the Malta Competition and Consumer Affairs Authority, the Competitions Officer, the Consumers’ Office, and the Regulator for Energy and Water Services are sending customers and journalists in circles. I am therefore asking you to provide answers to the following queries related to the matter:
Billing:
Is it legal for ARMS ltd to reduce the annual quotas
foreseen in the legal notice
by bulking prior period consumption into shorter billing periods or by
rationing the annual quota into discreet short-period quantities?
Is the ARMS billing procedure clear and
understandable to Maltese households?
How many billing queries have ARMS ltd received
annually since operation?
Threats
of cut off:
Do
customers have the right to contest a bill without paying interest or risk of
cut-off?
How are they to do this?
Loans, interest rates and ad hoc fees:
At what
rate is ARMS entitled to charge interest on loan facilities?
Is Arms
entitled to create and impose ad hoc fees that are not foreseen in the law
(e.g. 13% to revise a bulking error)
Discrimination:
Discrimination:
Is ARMS
entitled to discriminate between residents on the basis of the type of
accommodation they live in (Domestic vs Resident)?
Why do
non-residents pay less per unit at higher
consumption while residents pay more per unit?
Can ARMS
cross-subsidise one group of users by another?
Is it
acceptable that residents are put on different billing periods (2 month vs 6
month) when these result in material differences to the rate applicable?
Ownership and regulation:
Who do
Enemalta, the Water Services Corporation belong to?
Who does
Arms ltd belong
to?
Which
entity regulates EneMalta, WSC and ARMS?
Looking forward to your reply,
Dr Michael Briguglio
