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Fuel Rights Handbook 21st edition

Specific powers of disconnection
There are three specific meter offences under the Electricity and Gas Acts which are discussed on p907. If any of the offences are committed in respect of a gas meter or fitting, the supplier can only disconnect the supply of the person who has committed the offence. This is also the case with the offence of damaging an electricity meter or electrical line or plant.1Sch 2B para 10(2) GA 1986; Sch 6 para 4(3) EA 1986
However, if anyone tampers with an electricity meter so as to commit one of the other two offences, the supplier can disconnect the supply from the premises regardless of whether the person who committed the offence is the actual customer, and whether or not other users of electricity live there.2Sch 6 para 6 EA 1986
Suppliers’ rights to enter your home to disconnect are dealt with in Chapter 10. However, it is worth pointing out that gas suppliers and transporters do not have the right to enter to disconnect for theft or tampering unless they have given 24 hours’ notice3Sch 2B para 24(2) GA 1986 or have a warrant from a magistrate or, in Scotland, a sheriff or Justice of the Peace.
To get a criminal conviction, it must be proved beyond all reasonable doubt that an offence has been committed. The onus is on your supplier to prove that you have committed an offence. However, to exercise its power to disconnect the supply, the supplier needs only to be able to prove it (with evidence) on the balance of probabilities – ie, it is more likely than not.4Condition 12A.11(e) SLC This test is easier to satisfy than that required to prove a criminal offence. It is important to note that there does not have to be an actual conviction before the power to disconnect can be used.
The supplier can disconnect the supply (and has no obligation to reconnect) until the matter has been remedied.5Sch 4(6)(5) UA 2000 In the case of tampering with a meter, this includes paying for the cost of any damage to the meter and for any stolen fuel, but the two should be treated separately. Obviously tampering is normally carried out in order to reduce the fuel bill, which amounts to theft. However, if a meter has been damaged or tampered with, this does not necessarily mean any fuel has successfully been stolen and proof of damage or tampering is not proof that any money is owing in respect of fuel. (For example, tampering can inadvertently result in the meter actually registering a higher consumption.) Therefore, unless the supplier can show that, on the balance of probabilities, the damage in question caused financial loss other than the cost of replacing the meter, piping or equipment, the matter will be remedied once that cost has been met.
 
1     Sch 2B para 10(2) GA 1986; Sch 6 para 4(3) EA 1986 »
2     Sch 6 para 6 EA 1986 »
3     Sch 2B para 24(2) GA 1986 »
4     Condition 12A.11(e) SLC »
5     Sch 4(6)(5) UA 2000 »
Challenges to disconnection of stolen fuel
Where theft of gas or electricity has been established and the amount is not ‘genuinely in dispute’,1Ch 24 Sch 4(2)(2) UA 2000 no grounds exist to challenge the disconnection of fuel supply as a consequence of theft.
However, even when disconnecting fuel supply as a result of theft, the supplier must take into account whether any of the occupants of the premises are of pensionable age, disabled or chronically sick. If you fall into one of these categories, your supplier must use disconnection as a last resort for non-payment of charges arising from theft. A prepayment meter should be offered as a means of repayment and the supplier must not disconnect premises during the winter.2Condition 12A.11 SLC
Vulnerable customers facing disconnection should refer to Energy UK’s safety net policy and vulnerability commitment (see here) and SLC 28.
Save for an interlocutory injunction when a supplier behaves ultra vires, there is no further legal protection from disconnection, including entering into a breathing space scheme (see here). This scheme usually provides legal protection from supplier enforcement and recovery action (including disconnection) for either up to 60 days (or for the duration of time that you are receiving mental health crisis treatment, plus 30 days).3DRS Regs However, in cases of theft of fuel, the scheme provides no protection.
 
1     Ch 24 Sch 4(2)(2) UA 2000 »
2     Condition 12A.11 SLC »
3     DRS Regs »
Charges for stolen fuel
Before demanding payment for stolen fuel, the supplier needs to have evidence on the balance of probabilities (ie, it is more likely than not) of fuel theft by an intentional act or by culpable negligence.1Condition 12A.11(g) SLC
Often the supplier assesses an amount of fuel which it thinks has been stolen, and demands payment for that before it reconnects. It can only do this if it can prove that there was a theft, and that it was caused by the particular damage in question.2R v Director General of Gas Supply ex parte Smith [1989] (unreported); R v Minister of Energy ex parte Guildford [1998] (unreported)
If the supplier can prove that fuel has been stolen, and can justify its assessment of its value, then it can disconnect for non-payment. However, suppliers cannot use this power if the amount charged is ‘genuinely in dispute’. 3Sch 6 para 2 EA 1989; Sch 2B para 7 GA 1987
Even when charging for gas lost as a result of theft, the supplier must take into account whether any of the occupants of the premises are of pensionable age, disabled or chronically sick when deciding how to recover any sum owed.4Condition 12A.11 SLC If you fall into one of these categories, your supplier must use disconnection as a last resort for non-payment of charges arising from theft. An instalment plan or a prepayment meter should be offered as a means of repayment and the supplier must not disconnect premises during the winter.5Condition 12A.11 SLC The supplier must also take into account your ‘ability to pay’ all or part of the charges for gas lost as a result of theft, including when calculating instalments.6Condition 12A.11 SLC This includes giving due consideration to information provided by third parties and the value of all of the charges that are to be paid via the prepayment meter. The supplier must also take all reasonable steps to identify whether you will have difficulty in paying all or part of the charges arising from theft.7Condition 12A.11(b) SLC
Also check carefully any charges for disconnection and reconnection. Gas suppliers are limited by the Gas Act to recovering their ‘reasonable expenses’. Otherwise, there is nothing that says exactly what charges can be included, but they must be linked directly to the disconnection and the reasons for it. Typical charges include:
    meter replacement – it is possible for tampering to take place without the meter actually being damaged, so do not pay for a meter to be replaced that is capable of being re-used without repairs;
    gas fitting isolation, restoration and repair – check that gas fittings are not charged for in their entirety if they have not been tampered with;
    visits to your home – check that travel costs and the number of visits are reasonable;
    administration costs of investigation and calculating fuel used but not paid for – check that charges are reasonable;
    general administration – check that this is not wholly or partly double-counted within some other charge (such as debt recovery).
 
1     Condition 12A.11(g) SLC »
2     R v Director General of Gas Supply ex parte Smith [1989] (unreported); R v Minister of Energy ex parte Guildford [1998] (unreported) »
3     Sch 6 para 2 EA 1989; Sch 2B para 7 GA 1987 »
4     Condition 12A.11 SLC »
5     Condition 12A.11 SLC »
6     Condition 12A.11 SLC »
7     Condition 12A.11(b) SLC »