To
The CEO ARMS
The CEO EneMalta
The CEO Water
Services Corporation
The Malta Competition and Consumer Affairs Authority
The Competitions Officer,
The Consumers’ Office,
The Regulator for Energy and Water Services,
The European Commission Representation in Malta
The Consumers’ Office,
The Regulator for Energy and Water Services,
The European Commission Representation in Malta
The European Commissioner for Competition
The European Commissioner for Energy
Dear Sirs, Madams,
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 seem to be sending customers and journalists in circles. I
am therefore writing to you all together and publicly in the hope of
understanding the status and the regulation of the sector. I will be
sharing this letter publicly, as I will be sharing any answers you would care
to provide, when and if you would care to provide them.
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
