Recommendation 13: “Develop procedures and communication around requests for premiums in the context of energy efficiency certificates”
1. Customer observation
When customers have energy saving work done, they can benefit from premiums paid by suppliers that finance part of the work and this under certain conditions. In return, suppliers obtain Energy Savings Certificates provided by the State, so demonstrating their commitment to reducing their customers’ consumption, this system being generally controlled by the law. In the context of the handling of their mediation referral, some consumers fail to understand the reasons why ENGIE refuses to grant them the expected premium, even though they consider that they have complied with the eligibility conditions for obtaining them.
We have detected several situations where the Mediator has been able to find a solution that is acceptable to the parties and that gave rise to this recommendation.
We have, for example, the case of a customer who had energy saving work done and, in this context, initiated a request for a premium from ENGIE via the dedicated website for this purpose. When his work was finished, he asked for payment of the premium. ENGIE informed him that the quota of premiums to be paid for the year concerned had been reached and denied him the said payment. The client failed to understand because, nowhere, when creating the application file for a premium, was any mention made of a quota.
In addition, we have also had to deal with cases for which the conditions of eligibility or ineligibility of the consumer’s file (and therefore of the premium request) were not clear and not explicitly presented to the customer. The upshot was a whole series of exchanges between the customer/complainant and the ENGIE service in charge of the processing of the requests for premiums which could end, in some cases, at the conclusion of the process, with a refusal to pay the premium because the deadline for submission of the complete file had passed.
Other cases concerned the qualifications of the professional chosen by the consumer to carry out their work. In fact, henceforth the professional must be RGE certified (Grenelle Environment Roundtable). However, this information is not sufficiently specified and accurate on the ENGIE website dedicated to energy saving premiums. Some partners do not return the energy efficiency certificates files in time to ENGIE who cannot proceed with the payment because the deadline has not been respected.
Finally, the last type of dispute encountered by the mediation team concerning energy efficiency certificates was related to changes to premium scales. In fact, premium amounts for the same category of work may vary from one year to the next. Only when the customer opens his premium file in year Y, is he given an estimate of the premium which he can claim, based on the scale of this year Y, with the obligation to complete the work before the end of this year Y. If we are at the end of the year and the customer completes his file in year Y+1, he is surprised to receive an amount for the premium (especially if it is lower) which differs from the original estimate.
2. Mediation solution
As regards the “quota”, given that no prior notice had been given by ENGIE, the Mediator concluded, and the parties agreed, that the premium should be paid to the customer.
In the few cases of missing or non-compliant items in the 1st version of the file sent by the customer, leading to the refusal to pay the premium because the deadline had passed, the Mediator requested payment of the premium to the complainants. In fact, the Mediator considered that the rules governing eligibility of work for energy efficiency certificate premiums from ENGIE were not clearly expressed and that, instead of asking for all the additional items from the customer at once during its initial examination of the file received, its department multiplied the requests successively over time. This meant that the processing time was lengthened, to the point, in some cases, that the deadline for qualifying for this premium was exceeded.
In the case of professionals who did not possess all the required qualifications, to the extent that the customers had communicated the names of these professionals to ENGIE, prior to their work, during the establishment of their premium application file, the Mediator requested that the expected premiums be paid to the applicants. Indeed, ENGIE should have checked, from the outset, the professional’s compliance and, if necessary, alerted the customer before it signed a contract and had the work performed, and not at the end of the process as it had been doing until then.
In the case of changes in scales from one year to the next, to the extent that, as for the previous subjects, no specific information was provided to the customer in due time by ENGIE, the Mediator asked for the payment of the premium initially foreseen for the cases encountered.
3. Generic observation
When consumers have energy saving work carried out under the regulatory provisions of the energy efficiency certificates, they are aware of the premium system put in place by the suppliers and which, subject to certain conditions, allows part of the work to be financed. What some consumers do not understand when they complain to the Mediator, however, is why, despite the fact that they have complied with the said conditions or believe they have done so, ENGIE refuses to grant them the expected premium.
4. Recommendation / generic solutions.
The Mediator recommends that ENGIE communicate more clearly the eligibility rules related to the energy saving premiums, as early as the estimation phase. Three recommendations are proposed:
- Improve consumer information on the ENGIE site dedicated to energy efficiency certificates concerning eligibility rules and changes in scales;
- Be sure to propose on the website a simulation of the eligible premiums depending on the work to be done that can be edited or saved, constituting a trace facilitating the resolution of disputes at the same time;
- Remind the partners that deadlines for the submission of energy efficiency certificate files to ENGIE for the payment of premiums need to be respected.