CM016, Appeal to ERSE against EDP Following the Complaint on Red Book

Please see the Latest Update of the Page via the New Link: https://www.rozen-bakher.com/iccg-announcements/cm016

https://www.rozen-bakher.com/iccg-announcements/24/04/2023-0545

ICCG Announcement: 24 April 2023, 05:45. Latest Update: 01 June 2023


Entidade Reguladora dos Serviços Energéticos (ERSE)

EDP - Red Book - ROR00000000044763251

ERSE - Appeal 1/10677/2023

22 April 2023, Appeal to ERSE

15 May 2023-EDP responded to the Appeal via Letter

17 May 2023-ReAppeal to ERSE following EDP Letter

29 May 2023-Request to ERSE to get the Account Number/IBAN/NIB of EDP to transfer the Payments via Bank Transfer

01 June 2023-Request to EDP to get the Account Number/IBAN/NIB of EDP to transfer the Payments via Bank Transfer


See Related Pages:


Timeline of the Appeal to ERSE including EDP Letters via ERSE

  • On 05 April 2023, a complaint about EDP was given to the Portuguese Red Book via the Online Red Book about EDP Operation (see A Complaint to Portuguese Red Book about EDP Operation (05/04/2023) and A Request for Intervention of ERSE (22/04/2023) https://www.rozen-bakher.com/iccg-announcements/08/04/2023-1344)

  • On 05 April 2023, a direct complaint was also given to the CEO of EDP about EDP Operation (see A Complaint to the CEO of EDP amid EDP Operation by ICCG https://www.rozen-bakher.com/iccg-announcements/05/04/2023-1831)

  • On 21 April 2023, a response was given by EDP regarding the Complaint to the Red Book-ROR00000000044763251 (see below), still, the response did not refer to all parts of the complaint as described in EDP Operation (see below or via the link EDP Operation https://www.rozen-bakher.com/iccg-announcements/07/03/2023-1239), as follows:

    • EDP in their response ignored the vanished Electricity Meter-Reading from the system of EDP.

    • EDP in their response did not provide an answer for the ‘Taking Money’ instead of Direct Debit.

    • EDP in their response did not provide an answer for the gap regarding the insurance of EDP - what was said by the representative of EDP (8 Euro per month) compared to the price in the contract (14 Euro per month).

    • EDP in their response ignored the suspected SMS from 15 November 2022 that mentioned that the contract with EDP voids. Is EDP sent the SMS - YES or NO? And if YES, then Why?

  • On 22 April 2023, an appeal was given to the Energy Services Regulatory Authority (ERSE) amid the lack of EDP to respond to all parts of the complaint about EDP Operation https://www.rozen-bakher.com/iccg-announcements/07/03/2023-1239 (see below). Cyber-Blocking carried out by ICCG during the submitted Appeal to ERES (see Obstruction of Justice: Cyber-Blocking during the Online Appeal to ERSE about the Complaint against EDP in Portuguese Red Book https://www.rozen-bakher.com/iccg-announcements/22/04/2023-1253)

  • On 24 April 2023, a day after giving the appeal, on Sunday evening at 21:37, ERSE gave its first response (see below). More specifically, the Appeal to ERSE was given on Saturday morning (22 April 2023), while the first response answer from ERSE was given a day after that, on Sunday Evening (24 April 2023). Portuguese governmental authorities don’t work during the weekend, so unclear who handled the appeal.

  • On 27 April 2023 at 21:49, a second response from ERSE. The Second response from ERSE was given 3 days later, on 27 April at 21:49, and it includes an answer that EDP was given to ERSE following the appeal, still, the response from EDP to ERSE was given in SCAN PDF (Carta_71_2023_C-CMS) rather than in regular PDF, so it’s impossible to translate the file to English.

  • On 30 April 2023, Dr. Rozen-Bakher sent a request to ERSE to get the answer from EDP (Carta_71_2023_C-CMS) in regular PDF that can be translated to English, rather than in SCAN PDF. ICCG carried out cyber manipulation during sending this request. First, ICCG blocked the ability of Dr. Rozen-Bakher to add a signature, so the signature was added in a way of Copy and Paste. Second, ICCG blocked the ability to send the email as an Urgent email.

  • On 09 May 2023, Dr. Rozen-Bakher sent a reminder to ERSE to get the answer from EDP (Carta_71_2023_C-CMS) in regular PDF that can be translated to English.

  • On 15 May 2023 at 14:34, after 2 weeks of delay from the first request to get a regular PDF, EDP finally provided its answer (see below).

  • On 17 May 2023, Dr. Rozen-Bakher gave a ReAppeal to ERSE following the Cover-up arguments that were provided by EDP in its letter (see below).

  • On 29 May 2023, Dr. Rozen-Bakher sent a request to ERSE to get the Account Number/IBAN/NIB of EDP in order to transfer the Payments via Bank Transfer. Please see the full details below.

  • On 01 June 2023, Dr. Rozen-Bakher sent a request to EDP via EDP Website to get the Account Number/IBAN/NIB of EDP in order to transfer the Payments via Bank Transfer. Please see the full details below.


On 01 June 2023, Dr. Rozen-Bakher sent a request to EDP to get the Account Number/IBAN/NIB of EDP in order to transfer the Payments via Bank Transfer.


On 29 May 2023, Dr. Rozen-Bakher sent a request to ERSE to get the Account Number/IBAN/NIB of EDP in order to transfer the Payments via Bank Transfer

TO: ERSE 

Following my appeal against EDP (see corresponding below), and regardless of the other issues that I raised in the appeal, I would like to pay to EDP via bank transfer, rather than via Direct Debit because of the problems presented in my appeal.

The payment should be according to my current contract yet based on what the representatives of EDP told me during the sale of the contract and even after that. Please see the table below.

Note, we generated number of Entity and number of Reference via the website of EDP to make the payments, but when I tried to make the payments via the MB of my bank account, then I got a notice that it’s not possible. 

Hence, please provide me the account number/IBAN/NIB of EDP to transfer the payments presented in the table below.

 Thanks, Dr. Ziva Rozen-Bakher


On 17 May 2023, Dr. Rozen-Bakher gave a ReAppeal to ERSE following the Cover-up arguments that were provided by EDP in its letter .

TO: ERSE

 Following the response of EDP that was provided by email on 15 May 2023 (see below), here is the Appeal against the COVER-UP arguments provided by EDP in its letter: 

  • A contradiction was revealed regarding the collection payment bills of EDP between the Direct Debit Page and Bank Reports (see EDP Operation https://www.rozen-bakher.com/iccg-announcements/07/03/2023-1239). In spite of that, EDP argued that the bills were collected via ‘Direct Account’ (certain account) and ‘Direct Debit’, despite that there is no such thing a 'Direct Account'. Dr. Rozen-Bakher authorized EDP to collect money only via Direct Debit and not via any other form of payment.

  • EDP gave a cover-up argument regarding the fabricated SMS that was received on 15 November 2022 about Contract Cancelation. EDP argued that this SMS related to the cancellation of the Gas test on 14 October 2022, which reflects a gap of a Month between the gas test cancellation and the notice about it via SMS.

  • In spite of what the representative of EDP explained about the monthly payment, namely that the monthly payment will be 72 Euro each month based on the current contract, while at the end of the year, a calculation will be made including getting a discount for unemployed persons. Despite it, EDP as REVENGE to the complaint, decided in contradiction to the current contract, to increase the monthly bill from 72 Euro to 188 Euro. This increase is not accepted by Dr. Rozen-Bakher, so she is going to continue to pay 72 Euro per month as told her by the representative of EDP, while at the end of the year, EDP should calculate a discount for unemployed persons. ERSE should demand from EDP to avoid any increase in the monthly payment that contradicts the current contract. Besides, ERSE should keep in mind, that EDP in its letter ignored the vanished meter-reading from the EDP system, so ERSE should demand from EDP an answer WHY the meter-reading vanished from the EDP system   

  • EDP ignored again the vanished of the Meter-Reading from the EDP System, Likely because of the Meter-Manipulation by ICCG.

  • EDP argued that the cancellation of the bills from the 'Force Contract' occurred before the complaint on Red Book, despite that it was after the complaint.

To summarize, unfortunately, EDP gave again Cover-up arguments, which increase the suspicion that EDP is acting as a conspirator of ICCG.

For more information, please see the following links:

 Thanks, Dr. Ziva Rozen-Bakher


On 15 May 2023 at 14:34, Following the Appeal to ERSE, A Letter was received from EDP in Regular PDF.

Translation to English.


09 May 2023, A Reminder to ERSE to get the answer from EDP (Carta_71_2023_C-CMS) in Regular PDF, rather than in SCAN PDF to allow translation to English


30 April 2023, A request to ERSE to get the answer from EDP (Carta_71_2023_C-CMS) in Regular PDF, rather than in SCAN PDF to allow translation to English


Second Response from ERSE, 27 April 2023. The Second response from ERSE was given 3 days later, on 27 April at 21:49, and it includes an answer that EDP was given to ERSE following the appeal, still, the response from EDP to ERSE was given in SCAN PDF (Carta_71_2023_C-CMS) rather than in regular PDF, so it’s impossible to translate the file to English.

Translation to English (see Orginal Email below)

Order 1/10677/2023

Dear Ziva Rozen-Bakher,

In relation to the complaint process identified above, we send a copy of the response of the respondent.

According to the same, the matter complained of will have been clarified with regard to the contractual conditions agreed.

If you do not agree with the response of the entity complained of, you can send us elements that justify your position, within 20 working days. In the absence of new information we will conclude the complaint process.

For better information on the sectors regulated by ERSE we suggest consulting the Consumer Area on the ERSE portal.

Yours sincerely,

Eugénia Alves Energy
Consumer Support Coordinator Energy
Consumers Directorate


First Response from ERSE, 24/04/2023. The response was given a day after giving the appeal on Sunday at 21:37, despite that Portuguese governmental authorities don’t work during the weekend, so unclear who handled the appeal.

Translation to English (see Orginal Email below)

Order 1/10677/2023

Dear Ziva Rozen-Bakher,

Their communication was registered with Application No. 1/10677/2023.

In concrete commercial and contractual matters involving businesses and energy consumers, ERSE's intervention is limited to information or, if a dispute already exists, to the recommendation of its resolution, and ERSE may not impose a solution to it.

We will return to your contact, after analyzing the concrete situation and obtaining the necessary information for this purpose.

Whenever you need to contact us on the same subject, please provide us with the request number referred to in the first paragraph and use the email consumidores@erse.pt.

For better information on the sectors regulated by ERSE we suggest consulting the Consumer Area on the ERSE portal.

Yours sincerely,
Eugénia Alves Energy
Consumer Support Coordinator Energy
Consumers Directorate


A Request for Intervention of ERSE amid the Lack of EDP to Respond to All Parts of the Complaint


On 21 April 2023, a response was given by EDP regarding the Complaint to the Red Book-ROR00000000044763251

Translation of the EDP Response in English

Customer Face,

We have received your communication in which you show us your displeasure with the cancellation of the Conta Certa Agreement in force in the electricity supply contract that you title to the installation located at Praça de Londres 12 1 ESQ in Lisbon and ask us for clarification regarding the contracting of the EDP Full Pack and Secure Invoice services.

The payment method chosen is the Right Account
Analyzed the situation, we begin by confirming that the payment mode chosen for the invoices related to the electricity supply contract identified above, is the Right Account.

This option allows you to pay by direct debit the same amount for 11 months regardless of your consumption. In the 12th monthly payment, we send you the invoice, via email, for the whole year and pay or receive the amount of the adjustment between what you have already paid and the total amount of the invoice.

It should be noted that, following your trip to the EDP Lisboa Store, on February 24, 2023, you will have requested the change of this payment method to monthly, having been given due treatment to your request.

We also clarify that, due to an automatism of our commercial management system, whenever a change is made to the contract, a new contractual policy is generated with the new contractual conditions, which you must sign, information that was transmitted in the store before making the desired change.

Thus, according to the clarifications provided by our EDP Lisboa Store, at the end of the change, you will have refused to sign the documentation, so the Right Account payment method should have been restored.

Your monthly fee is automatically calculated, considering the history of readings of the installation
To that extent, I understand your exposure now under analysis, we proceed to the activation of the payment mode Conta Certa, with a monthly installment of € 181.00, and the monthly fee was automatically calculated, Understanding the readings of the history of the installation, being certain that the client can request our services, if he so wishes, to change the monthly amount to be debited.

The EDP Full Pack was hired on October 11, 2022 On this subject,
we inform you that following your trip to the aforementioned store, on October 11, 2022, the EDP Full Pack was contracted, with all the benefits associated with this service, with a cost of 14,90 €, information that appears in the respective contractual policy.

It should be noted that, with the contracting of the EDP Full Pack, a commercial offer was attributed to its electricity supply contract, on the billed consumption and the contracted power.

We also inform you that the contract in question has a duration of 12 months, being automatically and successively renewed for equal periods, if it is not terminated through written communication until the day before the end / renewal of the contract, as indicated in the general conditions.

The certification of your natural gas installation was carried out under the EDP Full Pack
More we inform you that the inspection and certification of your gas installation, carried out on October 18, 2022, was carried out under the EDP Full Pack contract.

Under this service the customer can choose to enjoy the certification of the natural gas installation, thus being free of the payment of the inspection, whose usual value is € 60.00.

Thus, even if the service is within the contractual period, we can cancel the EDP Full Pack, however, we will have to charge the value of the certification of the natural gas installation, so we request that, at an appropriate time, contact us, through the usual channels, so that we can follow up on your claim.

Clarifications on the activation of the Secure Invoice service
Finally, and given the issue complained of, specifically about the process of contracting the Secure Invoice service, we inform you that for the necessary clarifications on this matter it will be necessary to address the matter directly to EDP Mediadora.

We are available to clarify your doubts
You can clarify your doubts at any time in the customer support area in edp.pt. For any additional questions, please contact us through the customer area, the EDP Zero app, the service line 213 53 53 53 (weekdays from 9am to 8pm | call to the national fixed network), or our stores.

With our regards,

Pedro Galvão Pires
Commercial Director


05 April 2023, Complaint to Red Book about EDP Operation https://www.rozen-bakher.com/iccg-announcements/07/03/2023-1239


For more such kind of operations, please see Electricity & Gas Bills Operation https://www.rozen-bakher.com/iccg-announcements/05/04/2023-1532

EDP Operation - Highlights

  • The System of EDP Falls Down when the contract was made by Dr. Rozen-Bakher. Following the rental apartment in Lisbon, in mid-October 2022, Dr. Rozen-Bakher made a contract with EDP for electricity and gas (the gas used only for showers). When the contract was made, the system of EDP falls down, so Dr. Rozen-Bakher was not able to sign the contract or get it, so EDP sent her by email the contract after that (see below). Importantly, for Dr. Rozen-Bakher it was no surprise that the system of EDP fell down during the contract because it’s happened too many to count when Dr. Rozen-Bakher made a contract or get a service, such as the case of the fall down of the system of ING when Dr. Rozen-Bakher opened a bank account in Netherlands in 01/2020 (see ING Operation https://www.rozen-bakher.com/iccg-announcements/02/04/2023-1851), so the bank account did not open at the same day, but a three days later, which likely allows ICCG to manipulate somehow the Dutch bank account of Dr. Rozen-Bakher, or as the case of the fall down of the system of the ‘citizens store’ in Lisbon in mid-2018 when Dr. Rozen-Bakher and her son got the EU health insurance cards, which was likely done by ICCG in trying to prevent the getting of the health cards, two days before the travelling of Dr. Rozen-Bakher and her son from Portugal to England.

  • EDP did not mention the amount of the FIX payment when the contract was made. When the current contract was made with EDP in mid-October 2022, the representative lady of EDP did not mention the amount of the fixed price of EDP but only that it will be under the plan of 6.9KV, so unclear if the amount that was charged after that by EDP indeed reflect the original contract amid the suspected SMS in 11/2022 that mentioned that the contract with EDP voids (for more information, see below), as well as due to the ‘Taking Money’ from the bank account instead of via ‘Direct Debit’ for EDP payment (see below), regardless of the vanished second meter reading from EDP system (see below).

  • Contradiction information regarding the insurance of EDP. When the current contract was made in mid-October 2022, the representative lady of EDP argued that we will pay 8 Euro per month for the insurance with the ability to cancel it at any time, but EDP charged 14 Euro per month instead of 8 Euro per month. Note, the current contract indeed mentioned 14 Euro, but the contract was sent after that by email due to the fall down of the EDP system, so Dr. Rozen-Bakher has no opportunity to see this contradiction in the EDP office when she made the contract in mid-October 2022. Only two months later, she noticed the gap in the amount of EDP insurance, but when she informed EDP in 02/2023 about it, then the representative of EDP ignored the complaint about the gap and he even argued that it’s not possible to cancel the insurance, despite that the email of EDP mentioning that it’s possible (see below).

  • EDP replaced the old Meter Reading of the electricity with a new Smart meter-reading when Dr. Rozen-Bakher entered the Apartment. When EDP connected the apartment of Dr. Rozen-Bakher to the electricity, the old meter-reading (see below) did not work, so the technician of EDP replaced it with a new smart meter-reading, so the meter-reading at the beginning was 000000. However, unfortunately, ICCG can easily manipulate smart-meter-reading via cyber, rather than an old one, regardless of the ability to change the meter-reading on the system of the electricity provider or even to vanish meter-reading if it’s too low for ICCG to increase the costs of the electricity & gas bills, as likely done by ICCG when the second meter-reading vanished from EDP system (see below), as well as what done by ICCG since 2019 (see above Electricity & Gas Bills Operation).

  • Starting Using the gas at the start of November 2022 instead of in mid-October 2022 amid 3 times approval of gas tests by EDP. The gas in the apartment is used only for showers for 2 persons. However, amid 3 times approval of gas tests by EDP (1 test on the EDP insurance and two tests by paying 50 Euro cash for each test), then the using of the gas began at the start of November 2022, namely around 3 weeks after the entry to the apartment.

  • Suspected SMS that mentioned that the contract with EDP voids. On 15 November 2022, Dr. Rozen-Bakher received a suspected SMS that her contract with EDP Voids, despite that she did not make any change to the contract. Likely that ICCG cancelled the original contract and made instead ICCG-Contract on behalf of Dr. Rozen-Bakher and without her permission. (see below the SMS in Portuguese and its translation to English.). This manipulation likely explained why after the first payment via the direct debit, the other payments were not via the direct debit but via ‘taking money’ from the bank account without permission for that. Besides, this manipulation likely explained why the second-meter reading vanished from the system of EDP.

  • Bank Payments to EDP - ‘Taking Money’ instead of via ‘Direct Debit’. Only one time, on 28 November 2022, EDP charged via the direct debit that Dr. Rozen-Bakher authorised when she made the contract (see below), while after that, it was done via ‘Taking Money’ from the bank account (see below), despite that Dr. Rozen-Bakher gave authorization to EDP only to collect money via Direct Debit. To clarify, Dr. Rozen-Bakher did not authorize EDP to make any payment, rather than Direct Debit, so all the ‘Taking Money’ by EDP during the months 12/2022-02/2023 were done without the authorization of Dr. Rozen-Bakher. Nevertheless, on 07 March 2023, Dr. Rozen-Bakher cancelled the direct debit to EDP when EDP sent a bill based on a ‘Forced non-fixed contract’ that Dr. Rozen-Bakher refused to sign with EDP (For more information, see below).

  • Vanished Second-Meter from the System of EDP. A Meter Reading was done twice after replacing the old electricity meter-reading with a new smart meter-reading when Dr. Rozen-Bakher entered the apartment in mid-October 2022. Despite it, at the end of 02/2022, only one single meter reading appears on the system of EDP, according to the representative man of EDP. More specifically, the meter reading from 11/2022 showed on the system of EDP, while the meter reading from 02/2023 vanished from the system of EDP, which is likely related to the manipulation of payments not via the Direct Debit since 12/2022, as well as to suspected SMS from 11/2022 about that the contract with EDP voids.

  • Forced Not-Fixed Contract by EDP. At the end of 02/2023, Dr. Rozen-Bakher and her son came to the EDP in Lisbon in order to clarify several issues, such as the insurance of EDP and the options of payments to EDP including comparing between a fixed contract versus a non-fix contract. At the start of the conversation, Dr. Rozen-Bakher said that she was interested in a non-fixed contract, but when she found out about the vanished second-meter reading and about that the discount for an unemployed person is given at the end of the year, then she informed the representative of EDP that she decided not to sign the new contract and to stay with the current one. However, the representative man of EDP tried to FORCE the change by arguing that he already changed it on his computer, despite that Dr. Rozen-Bakher did not sign the new contract yet. Even after when Dr. Rozen-Bakher insisted that she is not going to sign the new contract, then the representative of EDP continued to FORCE the change by arguing that he made the change on the computer. The meeting at EDP ended without an agreement - the representative of EDP continued to FORCE the new contract, while Dr. Rozen-Bakher insisted that she is not going to sign the new contract. Based on the behaviour of the representative of EDP, then EDP does not need contracts nor to ask customers to sign them, because the representatives of EDP act upon what they put on the computer, regardless of if the customers agree to sign the contract, yes or no. Worse, a few days after that, Dr. Rozen-Bakher got a High Bill of 800 Euro (see below) based on a FORCED non-fix contract, while after that, a second bill of 237 Euro (see below), regardless of the fact that these bills are based on the ‘Vanished Second Meter Reading’.

  • Differences between the two invoices of the FORCED non-fixed contract regarding the financial details. First, unclear how the bank account of Dr. Rozen-Bakher appears on the invoice without mentioning ‘Direct Debit’ because Dr. Rozen-Bakher never authorised EDP to ‘Taking Money’ from her bank account but only via a ‘Direct Debit’. Even worse, there are differences between the two invoices of the FORCED non-fix contract regarding the financial details of Dr. Rozen-Bakher. (see below).

  • Cancellation of the ‘Direct Debit’ with EDP. Following the FORCED non-fixed contract and its bills, on 07 March 2023, Dr. Rozen-Bakher cancelled the ‘direct debit’ to EDP, yet only to find out the manipulation with the ‘direct debit’, as mentioned above.


Bank Payments to EDP - ‘Taking Money’ instead of via ‘Direct Debit’


Bills Under the Current Fixed-Contract, yet the first bill was collected via direct debit, while after via ‘Taking Money’ from the bank account of Dr. Rozen-Bakher

Differences in financial details between the two bills of the Forced Not-Fixed Contract

(see the full bills below)

Forced Not-Fixed Contract by EDP - Bills that are NOT Under the Current Contract

Suspected SMS that the contract with EDP Voids

Current Fixed Contract with EDP - Electricity and GAS

An email from EDP that mentioned that it’s possible to cancel the Insurance of EDP


Not Working old Meter-Reading of Electricity that was replaced by the technician of EDP with a new smart meter-reading when Dr. Rozen-Bakher entered the apartment, so in the check-in, the electricity meter reading was 000000

Gas Meter Reading when Dr. Rozen-Bakher entered the apartment and made the check-in.

The gas is used only for showers, still, the using of the gas began at the start of November 2022 instead of in mid-October 2022 amid 3 times approval of gas tests by EDP.


Dr. Ziva Rozen-Bakher

Dr. Ziva Rozen-Bakher - A Researcher in International Relations with a Focus on Security, Political and Economic Risks for Foreign Direct Investment (FDI) and International Trade

https://www.rozen-bakher.com/
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OP122, EDP Operation in Pre-Cutting of Electricity & Gas: Obstruction of Justice - Blocking Appeal to ERSE about the Complaint against EDP in Red Book