Embedded network complaints and case studies


This quarter EWON opened 106 complaints from embedded network customers.

Table 7 – Embedded network customer complaints by service provider, January to March 2023

Service provider

Complaints by embedded network customers

Electricity > network > exempt 

Electricity > retail > authorised 


Electricity > retail > exempt 


Gas > retail > authorised 

Gas > retail > exempt 

Non energy / non water > not allocated 

Water > retail > WICA 

EWON closed 96 complaints from customers whose electricity or gas (including hot water) is supplied through an embedded network. 

Table 8 - Top 10 core issues for embedded network complaints closed, January to March 2023

Core complaint issues


Billing > high > disputed 


Billing > account closing > error 

Billing > backbill 

Billing > estimation > meter access / not read 

General > energy / water 

Billing > contract terms > other 

Billing > contract terms > variation in price / terms 

Transfer > site ownership > other 

Credit > payment difficulties > current / arrears 

Credit > disconnection / restriction > impending 

Table 9 – Top 10 issues for embedded network complaints closed, January to March 2023

All complaint issues


Billing > high > disputed 


Customer service > poor service 


Billing > backbill 

Billing > estimation > meter access / not read 

Billing > account closing > error 

Customer service > failure to respond 

Credit > disconnection / restriction > impending 

Billing > contract terms > other 

Billing > fees & charges > late fees / interest 

Transfer > site ownership > other 

Through our customer complaints data and insights EWON has a unique perspective on the issues faced by residents in embedded networks, including lack of access to consumer protections.  

EWON strongly supports customers living in embedded networks receiving consumer protections that are equivalent and aligned with on-market customers. Energy, hot water and chilled water are essential services and customers of embedded networks should benefit from the same consumer protections that other retail energy customers are entitled to.  

EWON welcomed the NSW Government’s NSW Embedded Network Action Plan and Draft Ministerial Statement of Expectations as it works towards aligning consumer protections for customers living in embedded networks, with that of other energy residential and small business customers.  

Complaints that we receive highlight the complexity of issues that customers living in embedded networks deal with and any protections need to be future proofed, to adapt to innovation and the changing energy market. 

 Emerging business models for billing thermal energy

A customer moved into a newly built property in August 2022 which required him to establish accounts with a retailer as part of an embedded network. He received a bill for a period of eight weeks for $270. The bill for hot water reflected ‘gas and thermal’ charges and an unmetered daily usage charge for his gas cooktop.

He contacted the retailer to ask about the charges, as he was charged $15 per kilolitre, which he considered to be too high. It advised him that the hot water came from a centralised hot water system; the customer understood the system was not centralised and was metered individually.

We requested information from the retailer, and it advised us that the property was the first to have a separate gas supply for the hot water and was not centralised. The retailer advised that the thermal energy rates are the same for a centralised and non-centralised system as the product and process was the same and associated costs does do not differ much. It also advised that the gas was provided to an instantaneous hot water tank, with an individual unit for each town house. It then calculated the cost to heat the water that was used by the customer, which was reflected in the cost per kilolitre outlined in the contract agreed by the Owners Corporation.

 EWON reviewed the billing of the account and found that it was in line with the meter data and the rates and the contracted rates. EWON told the customer that our review was limited to reviewing the billing in line with his current contract, however we also provided him with information about bulk hot water and thermal water charges and provided him with information about the NSW Government’s Action Plan that aims to address gaps in consumer protections for customers living in embedded networks.

 Cross metering causes high bills for embedded network customer

The customer moved into the retirement village established as an embedded network in April 2020. New electricity meters were installed at the village in April 2021. The customer contacted EWON to dispute high electricity bills from his retirement village operator, received after the new meter was installed.

The customer had complained to the village operator, who investigated the bills, his hot water system and the metering, but the dispute remained unresolved.

EWON contacted the village operator to clarify what had been done to investigate. The operator said the meter had been investigated by their metering provider, and he considered that the meter replacements in April 2021 coincided with a cold winter, causing the high bills. EWON requested billing information and meter data from the operator. We reviewed the information provided and our technical consultant reviewed the metering arrangements for the residents. EWON noted that while the billing had been calculated correctly according to the meter data, the customer was concerned about cross metering between the three villas which were serviced by the same three phase electricity meter.

During EWON’s investigation, the customer engaged an electrician to install a third-party electricity meter at his own villa to cross check his usage against the embedded network’s electricity meter. The electrician also identified that the customers and the neighbour’s air conditioning units were cross wired. This indicated that the customer was being charged for the energy consumption of his neighbour’s air conditioner.

 EWON presented the electrician’s findings to the village operator, and they arranged for a technician to confirm that the air conditioning units on the two villas were cross wired. EWON asked to be present for the site visit and also arranged for a Senior Electrical Inspector from Fair Trading NSW to attend. The site visit confirmed that the air conditioning units were cross wired and that the customer had been paying for the energy consumed by the neighbour’s air conditioner.

The village operator rectified the cross-wiring issue but could not determine the exact date that the cross wiring occurred, as the air conditioning units had been moved since the customer moved into the village. The village operator offered to resolve the customer’s complaint by offering: 

  • a credit of $3,000 (which encompasses $2,466 in payments made between 1 June 2021 and present and the electrician’s invoice of $440) 
  • to waive the current balance of the customer’s account, approximately $1,500. 

The customer accepted the village operators offered as resolution to the matter.