We are reviewing our urban and rural water customer service codes to ensure they continue to meet the needs of Victorian water consumers.
Water codes review 2021
Launch of review21 December 2021
Stakeholder engagementFebruary - March 2022
Draft decisionJune 2022
Final decisionSeptember 2022
In recent years, significant events including the coronavirus pandemic have created new challenges and exacerbated existing issues for consumers, We note over the past two years, water businesses have substantially increased their support for customers, often going beyond the minimum requirements set out in our codes. Therefore we continued the review of the water customer service codes to ensure they meet the contemporary needs of Victorian water consumers.
Over the last year we have:
- reviewed new and existing issues for consumers, and how the intent of mechanisms like the National Cabinet approved policies and principles for coronavirus support are reflected in our current codes
- updated both the urban and rural water customer service codes to reflect the new processes and best practice that has evolved over the last two years.
Read our draft decision
We are proposing amendments to customer protections, with a focus on:
- strengthening code requirements relating to customer communication, to help ensure water businesses communicate appropriately and sensitively with their customers
- refining the minimum standards regarding support for customers experiencing payment difficulty, and mandating certain support for small businesses
- reflecting changes in technology and communication channels since we last review our codes
- clarifying the application of interest and debt management activities by water businesses.
There are also some administrative amendments proposed throughout the paper and in the accompanying annexures.
To inform our proposed amendments we consulted with industry and community stakeholders. We hosted stakeholder forums and established a community panel to help ensure our works is informed by the voice of customers.
We propose for the amendments to take effect from 1 January 2023.
We are seeking feedback on our proposals via Engage Victoria before we finalise our views.
See the 'Resources' tab for draft versions of the water industry standards.
How we engaged with our stakeholders
From February to April 2022, we undertook a public engagement process to ensure that the views of interested stakeholders were considered in the proposed amendments to the customer service codes. This built on initial engagement undertaken in 2019.
Our activities included a range of different methods, including stakeholder forums, a community panel and targeted discussions.
We held three online public forums in February and March 2022. Over the course of the three forums, we covered a variety of different topics under the following themes:
- reflection of the National Principles
- communication assistance
- actions for non-payment
We convened a community panel of 27 Victorian consumers, from a range of demographics to seek their views on issues related the customer service codes.
The topics the community panel discussed included:
- supporting customer experiencing financial stress
- communication assistance
- reminder and warning notices
- actions before restricting water supply or legal action
- which types of small businesses should be covered by the codes.
You can read the report summarising our customer panel process and outcomes in the 'Resources' tab.
Small business organisations
To explore key considerations when including support for small businesses in the draft water industry standards, we spoke directly to organisations that represent or work with small businesses.
Rural water businesses
To ensure we captured rural specific issues, we consulted with representatives from each of the water businesses providing rural services in Victoria. We wanted to further understand the payment support that rural water businesses provide to their customers
Stakeholders are invited to provide feedback on this draft decision. Consultation opens on 14 June 2022 and closes on 26 July 2022.
A forum will be held in July 2022, where stakeholders will be invited to discuss the draft decision.
To make a submission on this paper please go to Engage Victoria's website Engage Victoria.
Alternatively, email the commission at firstname.lastname@example.org to discuss other submission options.
Draft water industry standards
Community panel report on the engagement process
Documents we reviewed
Overview of our third workshop: Actions for non-payment
We held our third workshop for our review of the water customer service codes on 17 March 2022. In this workshop, 46 participants from the water and community sectors focused on actions for non-payment.
Restriction limitations and interest on unrecovered amounts
Participants discussed how the National Principles could be best reflected in the codes in relation to limits on restrictions and charging interest on unrecovered amounts.
Participants from water businesses noted that due to the pandemic there is more debt across the water industry, however if customers remain engaged, restrictions should be avoided. There was broad agreement that customers experiencing payment difficulties should not have their services restricted and should not be charged interest or additional fees.
Reasonable endeavours before restriction or legal action
Participants then discussed what actions a water business should take before it restricts or takes legal action against a customer (Hardship related Guaranteed Service Level ‘reasonable endeavours’ checklist). Participants highlighted some issues with the use of registered post, particularly in rural areas. As a result of this, sending registered post notices may no longer be ideal. Some water businesses noted that they were transitioning to monthly billing cycles and that this should be considered in an updated checklist. Participants agreed that water businesses should be allowed to choose the best possible communication methods for customers to allow maximum chance of engagement.
We will now be reviewing the feedback received at all three workshops and drafting the amendments to the codes, with a draft decision to be released in early June.
The team is also available for one-on-one discussions throughout this process. Please contact email@example.com.
Overview of our second workshop: Communications and proactive engagement
We held our second workshop, in a series of three, for our review of the water customer service codes. In this workshop, 42 participants from the water and community sectors focused on communications assistance and appropriate communication.
We invited participants to discuss how water businesses have changed their approach to communicating with their customers since the coronavirus pandemic and the introduction of the National Principles. We also asked how the current requirements in the codes can be improved to ensure water businesses communicate more effectively with their customers.
Participants highlighted that there was a need for balancing flexibility in communicating with customers and ensuring minimum standards are met. They were also supportive of broadening the current requirements and ensuring that water businesses, as much as possible, met the communication needs of their customers.
Participants discussed what communication channels water businesses use to provide information about payment difficulties and the communications options customers might prefer when speaking with water businesses. There was a diverse mix of communication channels that water businesses are already using to communicate with customers. Each channel has unique benefits and challenges for us all to consider.
Appropriate communication, summary bills (eBill) and notices
Participants were then split into four groups. Each group discussed a different topic related to the contents of eBills and notices whilst considering all communication relating to collection is appropriate and focused on the support available to customers.
eBills are usually sent by email, containing a summary of the water business’ bill and a link to the full bill. Participants discussed what information should be included in eBills but agreed that it should be brief and to the point. Some participants highlighted that issuing eBills may not be cost effective for all businesses, based on the sophistication of their current systems.
Notices to customers
Groups considered whether notices to customers such as reminder notices and notices warning of restriction could be personalised or whether water businesses would find it difficult to tailor notices to individual circumstances. Participants agreed that both reminder and warning notices should have options for customer support clearly set out.
Participants agreed that changes to warning notices may help improve customer engagement and reduce debt levels.
Overview of our first workshop: Reflection of National Principles in the codes
We held our first workshop, in a series of three, for our review of the water customer service codes. Thirty seven participants from the water and community sectors focused on how we could incorporate the National Principles in the codes and the types of support the codes could offer for small businesses.
Reflecting the National Principles in the codes
After some background information about the water customer service code review, participants were split into three groups to discuss one of three proposed draft clauses: proactive customer engagement, payment difficulty assistance and customer support policy.
Proactive customer engagement
Participants discussed what was meant by proactive customer engagement and agreed with the concept in principle but stated that it may be difficult to execute in practice. Several participants highlighted that the policies and procedures water businesses currently have in place to help customers experiencing payment difficulties are mainly reactive. It relies on customers to contact the business before being able to access assistance.
Participants were interested in hearing examples of what best practice proactive engagement can look like.
Payment difficulty assistance
The focus of this discussion was a draft clause about support for residential customers experiencing payment difficulty. Participants agreed the balance between what water business ‘must’ offer to customers and what they ‘may’ offer to customers was right.
There was a discussion about the importance of providing support early on for customers to reduce their usage.
Customer support policy
There was support for the change of wording from ‘hardship policy’ to ‘customer support policy’ and a move away from hardship as the focal point.
The group highlighted that support for customers is broader than financial support and access to information should also be a focus.
Support for small businesses
To discuss support for small businesses, the participants were split into three groups.
The groups first covered whether the codes need to define a small business. There was agreement that there should be a definition of a small business in the codes to ensure consistency amongst the approaches of water businesses.
Currently, many water businesses rely on self-identification by the business customer. Some identify based on consumption (e.g. consumption levels similar to residential customers) and others distinguish industrial business from other non-industrial businesses (small businesses).
Participants mostly agreed that the balance between what a water business ‘must’ offer small business customers and what they ‘may’ offer was right. However, it was noted that it is important to include non-financial assistance, particularly about water efficiency.