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CCWater response to: A Water
Strategy for Wales
A Welsh Government Consultation
Consumer Council for Water Response
1
July 2014
Consultation on: A Water Strategy for Wales.
1
Introduction
1.1
The Consumer Council for Water (CCWater) is the statutory body representing the
interests of water and sewerage consumers across Wales and England. CCWater has
a committee in Wales and four regional committees in England.
1.2
We welcome the opportunity to comment on Welsh Government’s consultation on a
Water Strategy for Wales (the strategy). Given our particular remit, we have
focussed on those questions and issues that directly relate to the customers of water
and sewerage companies operating in Wales. The response builds on our earlier
submissions to Welsh and UK governments’ on related consultations and the input we
have provided to discussions at the Wales Water Forum.
1.3
Summary
We welcome the approach set out by Welsh Government which seeks to manage
water resources in a more integrated way, to maximise the social and economic
benefits of a healthy water resource system while protecting the environment and
providing business opportunities. The proposed strategy encompasses the key aspects
of water management that CCWater has encouraged, including:
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emphasis on catchment management and addressing diffuse pollution;
the need for sustainable, resilient and cost beneficial solutions;
the need for community engagement and partnership working;
the importance of effective consumer representation; and,
for affordability to customers to be a prime consideration.
1.4
We particularly welcome the importance placed on effective consumer
representation in the strategy. As the statutory water consumer representative in
Wales and England we can help drive the implementation of the strategy for water
customers. In fulfilling our role we can continue to contribute evidence of
customers’ views and evidence on how the performance of water companies in Wales
compares to those in England. This should help drive improvements for services for
customer in Wales.
1.5
More specifically we support:
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The alignment of water resources and drought management planning processes,
provided that customer engagement and priorities remain central;
Encouraging water customers to play their part in water efficiency;
A costs and benefits investigation on transferring private water supply pipes to
the water suppliers;
Addressing health risks associated with the historic use of lead in plumbing;
Emphasis on sustainable drainage solutions in Wales;
The introduction of strategic sewerage plans provided their purpose and
customer focus are clear;
A review of the operation on mandatory sewerage adoption process and the
2
effectiveness of the Minister’s Build standards.
1.6
We are keen to continue working closely with the Welsh Government on many areas
of proposed activity and further study, including the examination of the future role
of water metering and the strategy for addressing affordability issues. We think it is
very important to ensure that more is done to promote optional metering and that
appropriate safeguards are in place to protect low income customers before
extended metering is considered in Wales.
1.7
Affordability issues in Wales and elsewhere tend to result from the cumulative effect
of rising household costs such as increased energy prices and transport, and living
costs, and we think the strategy should acknowledge this. We suggest that the
strategy reflects on some possible ways of making water bills more affordable in
Wales, such as for example phasing infrastructure investment to reduce impacts on
household bills; the removal of highway drainage charges from sewerage bills and
raising awareness of assistance schemes and unclaimed benefits.
1.8
We would welcome further discussion on the regulatory and constitutional changes
relating to water currently being considered by the two Governments in response to
the Silk Commission recommendations - we are interested in a further assessment of
any implications for household and non-household customers.
1.9
We would also like to understand how evidence from the Welsh Government’s
research on business (non-household) customers and regulatory reform will be
incorporated in the final strategy. In due course, Welsh Government could also seek
evidence from (cross-border) companies and customers on the implementation of the
provision for market reform in England to ensure customers in Wales are getting the
best deal.
1.10
Finally, we think the final strategy should:
 Clarify proposals on the new resources efficiency body;
 Set out the Welsh Government’s position on abstraction reform;
 Seek to coordinate action in Wales to prevent drainage misconnections;
 Commit to the production of a simplified action plan and timeline that sets out
priorities and key actions for delivery;
 Commit to inclusive and accessible engagement on policy development and a
transparent reporting mechanism that facilitates public engagement.
2
Response to specific questions
Question 2. Do you have any suggestions for improving and extending community
involvement in integrated catchment management?
and
Question 3. We have highlighted the close link between land management and the
water environment. Are you aware of examples of good practice which could be
reproduced elsewhere?
3
2.1
We agree with the principle of improving and extending community involvement in
integrated catchment management. We think that the Welsh Government could play a
coordinating role in joining up community and citizen engagement. Our Local
Consumer Advocates will continue to represent water consumers’ views in local
discussions, e.g. River Basin Liaison Panels. We would be pleased to help drive
customer engagement in integrated catchment management processes and to be
involved on specific initiatives as they develop.
2.2
We support linking land management to tackling problems in the water environment.
We think that Dŵr Cymru Welsh Water is one of the pioneers in surface water
management and have supported their proposals in the last and current price reviews.
There are a number of catchment management schemes already operating in England
which we feel are worth considering in Wales, some of these include:
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United Utilities’ Sustainable Catchment Management Programme1.
South West Water has a number of schemes as part of its Upstream Thinking
programme2. For example, by blocking up drainage ditches in uplands areas, the
company expects to reduce the rate of water flow from peat bogs and a
consequent reduction in flooding.
Wessex Water works with local farmers and landowners in the catchment areas of
water sources to safeguard the quality of ground and surface waters3.
Severn Trent Water has worked with local stakeholders in the catchment to help
tackle water pollution at Tittesworth Reservoir4.
It is clearly in the interest of customers to employ catchment management initiatives
where these are more (cost) effective in addressing environmental concerns than ‘end
of pipe’ treatments such as building water treatment works or flood defences.
Question 4. What opportunities do you see for developing payment for ecosystem
services (PES) schemes in relation to water management in Wales? What should be
the role of the Government in developing these schemes?
2.3
It will be important to ensure that in developing any PES schemes associated costs are
in proportion to the potential benefits which will accrue. Trialling schemes would
allow arrangements to be tested, helping identify the benefits which would be
delivered. These case studies could also be used to promote the PES schemes and
encourage take up.
Question 6. Do you agree with our focus on diffuse pollution? If not, please explain
why.
2.4
We agree with the Welsh Government’s focus on diffuse pollution and on encouraging
other sectors, such as agriculture, to address water pollution problems that they are
responsible for causing or to which they contribute. Water customers also have a role
1
http://corporate.unitedutilities.com/The%20SCaMP%20solution.aspx;
https://www.southwestwater.co.uk/index.cfm?articleid=8329;
3
http://www.wessexwater.co.uk/environment/threecol.aspx?id=7199&linkidentifier=id&itemid=7199;
4
http://www.stwater.co.uk/leisure-and-learning/reservoir-locations/tittesworth-water/ and
http://www.catchis.com/overview/casestudies.cfm;
2
4
to play in ensuring that their actions and the maintenance of their private pipes and
sewerage do not contribute to diffuse pollution. Together with the companies we
have a role to play in informing customers on the steps they can take to help
minimise the risk of pollution.
2.5
Water customers currently bear a disproportionate share of the cost of dealing with
the results of diffuse pollution on the water environment. During the first round of
river basin planning Dŵr Cymru Welsh Water customers bore the majority of the costs
of tackling water pollution in the Western Wales River Basin District, even though
other sectors shared responsibility for many of the problems5. Evidence suggests that
the agriculture sector in Wales is responsible for 40-45% of phosphorous pollution6.
However, during the first round of river basin planning, the agriculture sector
contributed less than 1% of costs towards tackling phosphorous pollution. We would
therefore welcome a more equitable sharing of these costs.
Question 7. Are there any additional pollution problems which you believe we
should identify? If so, what actions do you believe are required?
2.6
As the consultation identifies, many pollution problems have multiple causes. For this
reason, we feel there could be more emphasis on the opportunities for ‘partnership
working’ to tackle pollution. This could increase both the finance available to carry
out work and the potential benefits of that work. Welsh Government is ideally placed
to encourage different sectors to work together on the delivery of its strategy.
Question 10. Do you agree with the principle behind aligning the Water Resource
Management Plan and Drought Plan with the Asset Management Planning Cycle?
2.7
Aligning these currently separate, but interdependent, planning processes could
produce a number of benefits. It would help water companies to frame their business
plans in the longer term context of managing water resources, and make it easier for
them to engage with their customers and other stakeholders when setting out their
strategies for managing and investing in water and sewerage services.
2.8
Any proposals for aligning the processes should be developed in a way which avoids a
significant increase in the administrative cost burden to water companies, and their
customers. Customer engagement should remain a central plank of any future
planning arrangements. The risk of losing focus on customer priorities and securing
customer legitimacy, a central part of the current price setting process, should also
be avoided.
Question 11. Do you agree that there is a need to improve our long term planning
for waste water and sewerage management?
2.9
5
6
We support the introduction of long term waste water and sewerage management
plans as part of the proposed development and integration of planning processesparticularly if they help inform realistic proposals for asset investment in the long
Defra (2009) – Impact Assessment accompanying the River Basin Planning Guidance volume 2.
http://www.geostore.com/environmentagency/Phosphorus_Evidence_Base_v2_1_external.pdf
5
run. However, we feel that the strategy needs to clarify the intended purpose of
these plans. It is not clear to us whether the plans would be used to improve coordination of water, wastewater and drainage systems across Wales; or whether they
would focus on the management of the public sewerage service and assets.
2.10
There is a risk that the sewerage service provider will be expected to duplicate work
which it already undertakes in the course of developing its business plan. This
duplication of effort could create a significant additional cost, which would then be
passed on to sewerage customers for little, if any, additional benefit or improvement
in service. There could, however, be significant benefits in incorporating the
management of surface water and highway drainage as part of a comprehensive waste
water management strategy for Wales.
2.11
The approach proposed seems to be in line with Ofwat’s drainage Strategy and we
feel that the proposed plans could be most useful if they focus on the following:
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Identifying, with the input of different stakeholders, where the pressure points in
the sewerage, surface water and other drainage systems are, or are likely to be in
the short, medium and longer term;
Identify key long term risks that can help inform asset investment plans;
Identify sustainable and resilient options for tackling sewer flooding problems;
Identify and encourage collaborative joint working between sectors at national
and local level.
We would expect Welsh Government to specify which organisations and/or public
bodies would be subject to these plans, and involve them in their development.
Question 12. How can we ensure that Water Companies’ plans link with wider
natural resource management plans? Do you have any views about how this should
be implemented?
2.12
We would expect to see the water companies continuing to engage with all key
stakeholders when reviewing their plans and taking account of related planning
policies. Government guidance could also direct companies to consider wider
environmental policy. Natural Resources Wales would clearly have a key part to play
in ensuring that water companies’ plans were appropriately linked with wider natural
resource management plans.
Question 13. Do you agree with the proposals to encourage more efficient water
use? Are there any further actions that can be taken?
2.13
We believe the approach that the Welsh Government is proposing strikes the right
balance by encouraging the water industry to do more but also encouraging water
consumers to play their part.
6
2.14
CCWater research on customers’ views on saving water suggests that customer
awareness on why water should be valued or saved is low7. The strategy would benefit
from up to date information about consumers’ views and preferences in Wales so we
support the Welsh Government’s plans to investigate public attitudes to the use and
value of water. We would be happy to work with the government and other
stakeholders on this.
2.15
CCWater research also suggests that, in general, the public is less aware of water
efficiency issues in Wales than in England. Our most recent tracking survey reveals
that in Wales around 59% of water customers have taken action to reduce their water
usage over the last year. This compares unfavourably to the figure of 69% of
customers in England who say they have taken action8.
2.16
Our research on saving water also suggests that customers’ perception of companies
wasting water through leakage acts as a barrier to taking action to save water 9.
Performance on leakage for the water companies in Wales has improved in the past
two years. But we agree that leakage should be addressed provided that this is done
at an economic pace so that impacts on water bills are contained.
2.17
Bearing all this in mind, we welcome the proposal to encourage both household and
non-household consumers to reduce their water use by promoting behavioural change
and replacing inefficient water devices. We agree that there is scope for water
companies to do more to raise awareness and encourage public engagement with
water conservation issues. People tend to respond to different motivations but
through schools programmes and local campaigns communities can be encouraged to
act differently when they are helped to consider their water use and its impact on the
local water environment. On the basis of our research findings we think targeting
groups with the most appropriate and easily digestible information as well as practical
support and incentives would help them save water10.
2.18
We think that the Welsh Government should consider setting an overarching policy to
help deliver water efficiency consistently and in a streamlined manner through the
work of different organisations both independently and collaboratively. There are a
number of water saving initiatives taking place in the UK that involve water
companies, NGOs, wildlife charities and local interest groups. Our research shows that
when customers hear a consistent message from different sources they are more
likely to respond positively to it11.
2.19
We support the proposal to work with the managers of the Welsh Government Fuel
Poverty schemes to encourage them to provide water saving measures as part of their
support packages.
2.20
We would like to understand what plans there are to set up a new resources advice
7
CCWater(2013),’Research on saving water, the experience and perceptions of customers and their household’, a report prepared
by DJS, http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-into-customer-water-saving.pdf;
8
CCWater (2014), ‘Annual household tracking survey 2013 2014’, a report prepared by SPA, http://www.ccwater.org.uk/wpcontent/uploads/2013/12/Research-into-customer-water-saving.pdf;
9
CCWater (2013),’Research on saving water, the experience and perceptions of customers and their household’, a report
prepared by DJS, http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-into-customer-water-saving.pdf;
11
Opt. cit.;
7
service mentioned in the strategy, and what form this will take.
Question 14. Do you agree with our approach to metering? What other factors do
we need to consider?
2.21
Our 2012-13 tracking research12 suggests that unmetered customers are significantly
less likely to take water saving action in comparison to metered customers. With this
in mind, we agree that metering might potentially contribute towards improving
general water efficiency. However, the wider impacts of a wholesale move to
metered charging need to be considered and taken into account before decisions on
metering are made.
2.22
Currently it is for individual water companies to make the case for metering using a
full cost benefit analysis; whether this relates to optional, selective or compulsory
metering programmes, and also in determining the type of meter to be deployed.
Water companies’ policies need to reflect local circumstances and should also take
account of their customers’ preferences, potential affordability issues and general
acceptability of the approach.
2.23
A move to widespread compulsory metering would result in some customers initially
paying less and some, usually larger households with children, significantly more. It is
therefore essential that appropriate safeguards are in place before compulsory
metering is undertaken to ensure that low income customers are protected and their
water and sewerage services remain affordable. Providing advice and support with
water efficiency is a key element of any metering strategy and can help with some
affordability issues, but not all. We have worked closely with the water companies
that have embarked on compulsory metering programmes in England, so we would
welcome the opportunity to work with the Welsh Government on assessing the options
for metering supplies in Wales.
2.24
In the meantime, and as long as metering remains optional, companies should ensure
customers are well informed about the opportunity to ask for a meter and their right
to revert to their previous bill arrangements within a year. In Wales uptake of meters
is high in Dee Valley Water’s area (over 50% of total customers) and our annual
tracking survey suggests above average awareness of this option in the company’s
area at 80%. By contrast Dŵr Cymru Welsh Water has a much lower meter uptake
(over 35% of total customers).There is more potential to promote this option and
encourage take up.
Question 15. Do you agree with this approach to managing leakage? Are there
ways we can ensure leakage is sustainably reduced?
2.25
Leakage needs to be maintained at the point where the environmental, economic and
social cost of reducing leakage is less or equal to the cost of getting water from other
sources. We would be concerned if water companies were instructed to reduce the
level of leakage to below the sustainable economic level since this would be likely to
result in significant increases in costs to water customers without any equivalent
12
CCWater Research,(2013), ‘CCWater annual household tracking survey 2012 – 2013’, a report prepared by Accent,
http://www.ccwater.org.uk/blog/2013/07/25/consumer-council-for-water-annual-household-tracking-survey-2012-to-2013/;
8
benefits being delivered.
2.26
CCWater research confirms that addressing leakage is important to customers. They
expect their water company to be addressing leakage effectively at no additional cost
or by diverting resources from other areas of investment13. Customers have even
higher expectations if they are subject to compulsory water metering. Water
companies undertaking compulsory metering in England have provided extensive
“free” help with customer supply pipe leakage and some internal plumbing issues in
order to help customers adapt to, and accept the transition to metered charging. Any
future metering strategy for Wales should consider the opportunities for customer
side leakage management.
2.27
There has already been some consultation on potential supply pipe adoption which
also includes a discussion on leakage. CCWater is participating in an UKWIR study to
ascertain customers’ views on the various options for this.
Question 16. How can we ensure best practice is shared across the water industry,
to ensure that innovative solutions to address water poverty issues are shared
with others?
2.28
CCWater works closely with all water companies on their water affordability
strategies and assistance schemes. This includes working with companies on the
development of customer funded social tariffs in line with guidance from the Welsh
and UK Governments. In doing so we will continue to share ideas and examples of
good practice across the industry.
2.29
We are very pleased that Welsh Government guidance has identified customer
engagement and broad customer support as essential for the introduction of social
tariffs in Wales.
2.30
We are pleased that both water companies in Wales have now committed to the
introduction of a new social tariff in the period of 2015-2020 with specific start up
dates - a big win for our local committee and office in Wales. We are working closely
with the companies to fulfil our role in the process of developing tariffs supported by
their customers.
2.31
We have also worked with the water companies in England who are currently
compulsorily metering their customers and offer a range of support packages during
the transitional arrangements, such as clear communications and assistance for low
income customers, and the repair of leaks. We are facilitating the exchange of
experience and good practice between water companies and would be happy to share
this learning with Welsh Government.
Question 17. Have we identified the key issues and actions in relation to water
affordability issues?
2.32
We are pleased to see emphasis on affordability in various sections of the strategy
13
CCWater (2013), ‘CCWater research on customers perceptions of leakage’, A report prepared by SPA Future,
http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-into-customer-perceptions-of-leakage.pdf;
9
and think that this should be retained.
2.33
We support the provision in the Flood and Water Management Act 2010 for regulations
to make landlords jointly and severally liable for water and sewerage bills on failure
to provide specified tenancy details within a timeframe. We responded to the Welsh
Government’s 2013 consultation on the draft Regulations that would require landlords
to provide these details14. When implemented, this has the potential to make a useful
contribution to addressing both the problem of debt and the associated cost impact
on bills.
2.34
We have a number of suggestions about what Welsh Government might consider
further, in relation to water affordability issues and would be happy to discuss these
points further.
Costs of infrastructure:
2.35
The National Audit Office (NAO) recently published a report into the rising costs of
infrastructure and how this affects customers’ financial circumstances15. The key
points of the report were that the cost of infrastructure will rise; this will affect
utility bills, which generally rise faster than income; and rising bills are a particular
concern for those in the lowest 10% of income distribution.
2.36
Customers have repeatedly said that whilst they accept the need to upgrade water
and sewerage networks and meet environmental requirements, they do not want this
to result in sudden spikes in bills. CCWater has, therefore, argued for water industry
investment to be paced so that customers can value what they are getting for their
money.
2.37
We feel that it is important, therefore, that the cumulative effects of rising water
bills, increased energy prices, and increased transport costs on customers are
acknowledged by Welsh Government.
2.38
We share the NAO’s view that there would be benefit in ensuring strengthened
coordination across government on the impact of current and future policies on
household bills. In addition to setting out its overall objectives for any given policy
area, it would be useful for Welsh Government to also set out the relative priorities
within the policy area, and how they interact with other policies across government.
There would also be benefit in setting out how investment could be phased to
minimise the impact on household bills.
Customer funded social tariffs:
2.39
The number of people who find bills unaffordable in Wales has increased significantly
to 18% from 10% since 201216. According to an Office of National Statistics report
14
CCWater (2013), ‘Response to: Consultation on tackling 'bad debt' within the water industry in Wales, a Welsh Government
publication’;
15
National Audit Office (2013), ‘Infrastructure investment: the impact on consumer bills’;
16
CCWater (2014), ‘Annual Tracking Survey 2013/14’, http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-intocustomer-water-saving.pdf;
10
issued in June 201417, disposable income in Wales is the lowest in the UK at £14,623.
Customer funded social tariffs can play a role in helping to address the issue of water
affordability. However, the current approach has limitations and we think Welsh
Government should consider what can be done centrally to directly assist low income
and vulnerable customers in Wales.
2.40
Companies decide whether to bring forward tariff proposals and, subject to
consultation, what form these should take. This could lead to some disparities in the
help which is available to customers depending on where they live - a problem that
we may be faced with as the two companies mainly in Wales are developing separate
social tariffs. There is also a question of whether, in all cases, social tariffs funded
solely through the transfer of costs between customers can fully address the scale of
the problem facing low income households.
2.41
In 2010 CCWater research on social tariffs pointed to strong customer support for
action to help ensure water charges are affordable for low income households18. It
also found support for social tariffs as an effective means of delivering this help and
ensuring that assistance reaches the intended target. However, customers tended to
favour a universal approach to such tariffs as this would ensure customers had access
to the same help wherever they live.
2.42
Customers also indicated that they would be more willing to pay towards the cost of
funding a social tariff through water bills if this was part of a partnership approach
where government and water companies also contribute. In Wales more customers are
supportive of using profits to provide financial help to those on low incomes than in
England, 47%W compared with 41%E19. This evidence should be taken into account
when considering how a social tariff can be subsidised in Wales.
Highway drainage:
2.43
We have previously highlighted that one way to help reduce the level of water bills
could be to transfer the highway drainage portion of charges from water customers’
bills to council tax charges. The service benefits communities, rather than individual
households, and mechanisms are already in place to help support low income
households in paying their council tax charges. This approach would also have the
advantage of giving councils greater incentives to develop and implement more
sustainable drainage solutions.
Raising awareness of assistance and unclaimed benefits:
2.44
CCWater promotional activity and work with water companies have all helped to
significantly increase the take-up of water bill assistance schemes in Wales in recent
years.
17
Office of National Statistics report on Regional Gross Disposable Household Income (GDHI),
http://www.ons.gov.uk/ons/rel/regional-accounts/regional-household-income/spring-2014/stb-regional-gdhi-2012.html
18
CCWater Research (2010) “Cross Subsidies and Social Tariffs – the consumer perspective” A report by Creative Research.,
http://www.ccwater.org.uk/wp-content/uploads/2013/12/Cross-subsidies-and-social-tariffs-June-2010.pdf;
19
CCWater (2014), ‘Annual Tracking Survey 2013/14’, http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-intocustomer-water-saving.pdf;
11
2.45
In implementing its Tackling Poverty agenda Welsh Government is well placed to help
further coordinate action by different organisations across Wales and to help raise
awareness of the assistance that is available to low income customers. This will be
particularly important as new assistance measures are launched.
2.46
More specifically, Welsh Government coordinated action to increase the take-up of
welfare benefits and credits could have a major impact on low-income household
ability to manage their household budgets, including water charges. Research from
Age Cymru shows that unclaimed pension credit is worth £168 million each year in
Wales and that 70% of pensioner households in poverty do not receive any major state
benefits. 20
Question 18. Are there any other approaches we could adopt to support the needs
of both domestic and business customers?
2.47
We support Welsh Government’s aims to ensure that domestic (household) customers
receive high quality services; and that businesses in Wales benefit from a ‘responsive
and flexible’ water industry. In particular, we welcome the expectation that water
companies in Wales should be more proactive and supportive of the needs of business
(non-household) customers. This will be especially important in the move to the open
market for all non-household customers in England from 1 April 2017.
2.48
We welcome the recognition of the importance effective consumer representation
and the role that CCWater has to play in this. As well as placing emphasis on customer
engagement, in fulfilling our statutory role, we can help drive the delivery of this
strategy for customers. We will continue to collect evidence of customer views on a
wide range of important issues which can be used to inform the implementation of
actions or further development of policies. We will continue to provide evidence on
how the performance of water companies in Wales compares to those in England to
ensure that customer in Wales are getting the best deal. This industry wide
comparative element of our work can help drive best practice and is enabled by our
regional structure and our regular information gathering activity locally. For example,
our information collection on written complaints will provide an essential comparator
on non-household customer services across England and Wales as part of the future
regulatory service measure (SIM) with an aim protect and improve the services
provided to non-household customers.
Indicators of good water and sewerage services:
2.49
20
It is important for Welsh Government and CCWater to continue to press water
companies in Wales to deliver high quality services, and to monitor their delivery. We
think that trust in companies, satisfaction with services and value for money, as well
as a narrowing gap between the latter two, should be explicitly mentioned in the
strategy as outcomes that companies should strive for. CCWater’s Annual Tracking
survey has been on-going for seven years and provides a good baseline and
comparator for measuring those indicators for good services but also helps identify
specific areas on which services could be improved.
Age Cymru (2014) - Life on a low income report.
12
2.50
It is important that the companies achieve high levels of satisfaction in Wales in the
face of forthcoming and likely policy and regulatory changes. Our annual tracking
research for household customers shows 94% satisfaction with water services and 89%
satisfaction with sewerage services in Wales. And our small and medium enterprise
(SME) research shows that more non-household customers in Wales are satisfied with
their water supply from Dŵr Cymru Welsh Water (94%) than in England (87%).
2.51
It is also important for companies to continue to reduce the gap between satisfaction
with services and satisfaction with the value for money of those services. Our
research shows that, in 2013, 78% of household customers in Wales were satisfied with
the value for money of their water services and 79% with the value for money of their
sewerage services.
Trust and sharing gains with customers:
2.52
Trust of water companies amongst household customers in Wales, at 7.6 out of 10, is
higher than in England (7.3). Our non-household customer research also shows higher
trust for companies in Wales than in England, with an average trust score of 7.9
compared to 7.3. Similarly, more non-household customers in Wales agree that their
company cares more about them as a customer than those in England.
2.53
To maintain and further increase trust companies in Wales should be even more
transparent and open about their investment priorities and their commitment to share
gains with their customers. Where companies in Wales outperform regulatory
expectations and achieve unexpected financial benefits we believe these should be
shared with customers. The views of customers and their representatives on how
gains should be shared should be sought. In doing so, companies should build on the
customer engagement work undertaken as part of the customer challenge process for
2014 price review.
Market reform in England- communication and post implementation review:
2.54
One way to maintain high levels of satisfaction will be to communicate with
businesses in Wales to ensure that they are aware of their eligibility in relation
switching suppliers in Wales and England and the move towards market reform in
England. CCWater will ensure that it engages with these customers on these issues
and would welcome support from Welsh Government.
2.55
In due course, Welsh Government could also seek evidence from (cross-border)
companies and customers on the implementation of the provisions on market reform
in England. This assessment and its conclusions should help ensure that market reform
implementation is not to the detriment of ineligible water customers and that
customers in Wales are getting the best deal.
Communication of assistance measures:
2.56
Good communication of assistance available to vulnerable and low income customers,
entitlement to rebates (e.g. surface water rebates) and availability of different
charging options might also increase and maintain levels of satisfaction in Wales, and
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also help address the trend of an increasing number of people who find their bills
unaffordable21.
Question 19. Are there any additional drinking water quality matters that we
should consider? Do you agree with our proposal to investigate the transfer of
water supply pipes to the water companies?
2.57
In our response to the consultation on proposals to transfer responsibility for water
supply pipes in England and Wales to water companies22 we raised concerns that the
cost and customer service aspects had not been given adequate consideration. We
therefore welcome the proposal to investigate the costs and benefits of transferring
these pipes to company ownership.
2.58
If responsibility for supply pipes is transferred to water companies, this would
undoubtedly have an impact on water customers’ bills, so the final proposals must be
both affordable and acceptable to water customers. This can be achieved by ensuring
that any changes in water companies’ practices and policies are driven by customers’
views on, and preferences for, the level and pace of any company expenditure arising
from the transfer.
2.59
Furthermore, any change from the current responsibilities is likely to increase the
level of cross-subsidy. Since the cost of the transfer would be passed on to water
customers, this could mean that, in the rented sector, property owners could benefit
at bill payers’ expense.
2.60
We support collaborative working on water quality issues through the Water Health
Partnership in Wales because it can deliver effective coordination of consistent
communication on drinking water quality issues affecting customers in Wales.
Question 20. Should we develop and consult on a long term strategy to remove the
health risks associated with the historic use of lead in plumbing?
2.61
This proposal seems sensible. As the consultation notes, there may be a need to
investigate alternatives to the use of phosphate for controlling the presence of lead in
plumbing (phosphate dosing). The strategy mentions that phosphate resources are
limited and treatment by this method does not remove the long term risk from lead
pipes and fittings. A long term strategy should cover and consider all of these issues,
with the aim of developing the best and most sustainable solutions that will keep the
final costs to water companies, and, hence, to their customers, as low as possible.
2.62
It is worth noting that introducing phosphate dosing can also contribute towards
pollution problems in the water environment. Phosphorous pollution is one of the
reasons why water bodies fail to meet the requirements of the Water Framework
Directive[1] across England and Wales. Hence, the benefits to water companies of
reducing the risks from lead are offset by the costs of removing that phosphorus
21
These are the areas of low awareness which CCWater’s tracking survey 2013/14 identifies for customers in Wales;
CCWater Response (2013) –‘Defra and Welsh Government Consultation on the future management of water supply pipes, a Defra
consultation.
[1]
CCWater (2014), ‘Annual Tracking Survey 2013/14’, http://www.ccwater.org.uk/wp-content/uploads/2013/12/Research-intocustomer-water-saving.pdf;
22
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during water and sewage treatment processes. These costs will be incurred in
addition to the costs of phosphorus dosing.
Question 21. Do you agree with our priorities for drainage matters?
Question 22. This section has focused on built infrastructure, which mostly serves
developing areas. Is there anything more we should consider for rural areas?
2.63
We broadly support the Welsh Government’s approach on drainage matterssustainable drainage systems are an important element of this. We are interested in
the outcome of identifying how water sensitive urban design principles can be used in
Wales.
2.64
We welcome the commitment to review of the operation of the mandatory sewer
adoption process and the effectiveness of the 2012 Minister’s Build Standards.
2.65
We note Welsh Government’s aim of reducing the amount of solid waste that is
disposed of via the sewerage network. In our response to Welsh Government’s
Environment White Paper, we identified a number of barriers that we consider would
make an outright prohibition on the disposal of food waste to sewers unviable23. We
look forward to further discussion on this issue.
2.66
Welsh Government has also stated that it will review the legislation and practices
relating to various aspects of the drainage network, including highway drainage. We
set out our views on highway drainage charges in response to question 17.
2.67
We have already shared our views on the review of guidance on first time public
sewers in the consultation issues by Welsh Government earlier this year. This mainly
focussed on proactive and clearer communications with the public likely to connect to
a new sewer during the process to ensure they accurately understand likely
connection costs.
Question 23. Are there any other significant issues which you believe we should
have included?
2.68
We would like Welsh Government to consider how it might play a useful role in
helping reduce drainage misconnections, which can cause pollution and flooding
problems. Although the responsibility for tackling these lies mainly with local
authorities, Natural Resources Wales and water companies, we think the Welsh
Government may wish to review opportunities to address the issue and to encourage
others, including property owners and developers, to play their part.
2.69
For example, Natural Resources Wales supports the Connect Right campaign24,
launched earlier in 2014. There is an opportunity to promote this campaign in Wales
so as to increase awareness of steps that can be taken to prevent problems arising
from misconnections.
23
CCWater Response (2014) ‘ Welsh Government consultation: Towards the Sustainable Management of Wales’ Natural Resources’,
http://www.ccwater.org.uk/wp-content/uploads/2014/02/CCWater-response-Towards-the-Sustainable-Management-ofWales%E2%80%99-Natural-Resources.pdf;
24
http://www.connectright.org.uk/
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Question 24. Do you agree with our approach to ensuring that regulation is
focussed on the Welsh Government’s priorities? Do you have any other views or
suggestions regarding the regulatory framework and whether it is fit for purpose?
2.70
We agree that Welsh Government’s priorities should drive regulation and that those
priorities should be based on evidence of water consumers’ views. It is important that
this is done in a manner that maintains the regulator’s independence so as not to
affect investor perceptions and consequently the cost of capital for the industry.
2.71
In terms of the Wales Water Forum, we agree this type of stakeholder body is useful
and allows the Welsh Government to understand the range of views from different
sectors. However, it is also essential that the water consumers’ voice is not lost
among other environmental and stakeholder interests.
2.72
On regulatory reform, we would welcome further discussion and consultation on the
regulatory changes that Welsh Government is considering to further understand how
these could benefit household and non-household customers in Wales. CCWater has
contributed its initial views to the business customer and regulatory reform Welsh
Government research referred to in the consultation. We would welcome a discussion
on how the results of this might be incorporated into the final strategy.
2.73
In considering the realignment of regulatory boundaries with geographical ones25 it
will be important for the Welsh and UK Governments to have clear information on any
likely implications for water and sewerage customers, including a detailed analysis of
the costs and likely impact on customer bills. In the absence of evidence of specific
customer views on this issue further citizen engagement, or customer research,
exploring the principle of a realignment of boundaries might help inform further
discussions. We have shared our initial views on the Silk Review recommendation on
water in response to the Welsh Select Affairs Committee evidence session26.
Question 26. What more could the Welsh Government do to effectively support
businesses in the water sector to grow and prosper?
2.74
We support the Welsh Government’s aim to provide tailored support for businesses in
the sectors of energy, environmental goods and services.
Question 27. Are there other actions that the Welsh Government needs to
undertake to support the delivery of this Strategy?
2.75
It is important that citizens remain at the heart of Welsh Government policy. As
Welsh Government wishes to engage with the general public on the delivery of this
strategy we think it would be helpful to produce a simplified action plan and timeline
25
Commission on Devolution for Wales (2014), ‘ Empowerment and responsibility: Legislative powers to strengthen Wales’, Report
II, http://commissionondevolutioninwales.independent.gov.uk/files/2014/03/Empowerment-Responsibility-Legislative-Powers-tostrengthen-Wales.pdf;
26
CCWater (2014), ‘Written evidence to Welsh Affairs Select Committee: One Off Evidence Session on Silk Review Part II:
devolving legislative powers to Wales’ , http://www.ccwater.org.uk/wp-content/uploads/2014/04/CCWater-Written-Evidenceto-Welsh-Committee-Affairs-Select-Committee-on-Silk-Review-April-2014.pdf;
16
that sets out the key milestones for delivery. This would enable reporting progress
clearly and effectively to demonstrate the delivery of the strategy.
2.76
Given the wide scope and ambition of this strategy we would suggest that
consideration is given to producing a summary document on the key priority areas
that are most relevant to water consumers.
Question 28. What information would you find useful to assess how the Welsh
Government has progressed against key outcomes and actions in the Strategy?
2.77
CCWater looks forward to the development of the proposed evidence and evaluation
framework. A clear and effective reporting mechanism that facilitates engagement
with the public would satisfy the requirements of democratic accountability.
2.78
We note that this consultation material is only available through the Welsh
Government website and this might limit inclusivity for those who do not have access
to the internet. We therefore hope that in the future Welsh Government uses a
variety of different methods to increase opportunities for water customers to have a
say in shaping policy that might affect the management of their water resources and
water and sewerage services.
Question 29. We have asked a number of specific questions. If you have any
related issues which we have not specifically addressed, please use this space to
report them.
2.79
CCWater’s remit is to represent customers who receive services from water and
sewerage companies operating in Wales. Whilst we don’t represent those with private
water supplies and sewerage arrangements we keep a watching brief on anything that
could affect drinking and environmental water quality, affect public health and
increase water quality treatment costs for all.
2.80
We think that encouraging good private water supplies and sewerage practices could
help prevent potentially costly contamination incidents which could subsequently
affect public health and environmental water quality in Wales. We therefore support
Welsh Government leadership on initiatives which could help improve water quality in
Wales cost effectively, such as for example the registration of septic tanks and
improvements on the first time public sewers process in Wales. We would also
welcome a further increase in the number of private water supplies for which quality
is recorded by Welsh Local Authorities through the collaborative work of Water Health
Partnership for Wales.
Enquiries
Enquiries about this consultation response and requests for further information should be
addressed to:
Lia Moutselou
Policy Manager
Consumer Council for Water
Caradog House
1-6 St Andrew’s Place
Cardiff
CF10 3BE
Tel: (029) 20 379856/07554405859
Email: [email protected]
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