Summary of responses and government response
Updated 17 December 2024
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Introduction
The Department for Environment, Food and Rural Affairs (Defra) published a consultation on proposed changes and updates to the Guaranteed Standards Scheme (GSS) in the water sector. This was open for responses from 12 August to 7 October 2024. The consultation was conducted primarily through the Citizen Space online consultation tool and was supplemented with some email communications and engagement with stakeholders.
This publication includes:
- a summary of responses received, with basic analysis of responses and themes of note
- a government response and planned next steps
- a full breakdown of responses by question in Annex A
- a summary of organisations who responded to the consultation in Annex B
The analysis presented in the summary of responses is mostly based on the formal responses received through Citizen Space and by email. Additional themes brought out through the informal engagement processes alongside the consultation have been taken into consideration in the production of the government response.
Background
The Water Supply and Sewerage Services (Customer Service Standards) Regulations 2008 are commonly referred to in the water and sewerage sector as the GSS. The GSS sets a baseline level of service below which companies must not fall by setting out certain standards and mandating payments to be made to affected customers for contravening these standards.
Since the original legislation was introduced in 1989, several amendments have added additional standards, clarified existing standards and increased payment values. However, the values of payments have not been altered since 2000, and the standards included in the scheme have not been altered since 2008.
Presently, all water and sewerage companies offer tailored versions of the GSS, enhanced to varying degrees. These are often based on recommendations published by Ofwat in 2018, following the ‘Beast from the East’ freeze-thaw event, which caused widescale supply interruptions and disruptions nationally. However, companies have also tailored their schemes independently, by including different combinations of voluntarily increased payment values, standard requirements and additional standards.
The statutory GSS standards are generally packaged into these offers, and so there can be significant variation in the customer protection measures between companies or regions. This lack of consistency, and regular need for companies to go beyond existing payment rates, demonstrates industry recognition the statutory GSS needs improvement.
Additionally, incidents in May 2024 in Hastings, East Sussex and Brixham, Devon highlighted the need for change to provide the protection from water and sewerage service incidents customers expect.
The Consumer Council for Water (CCW), the statutory consumer representative body in the water sector, conducted a review of the GSS, which concluded with recommendations for improvements. Government considered these recommendations and incorporated them into the proposals that were consulted on between 12 August and 7 October 2024.
The proposed changes to provide more comprehensive protection from service disruption for customers in England included:
- roughly doubling payment values for service failures
- improving and clarifying existing standards within the scheme
- broadening the set of standards which warrant payments
The proposed changes included in this consultation are expected to apply to England only. Welsh Government has indicated that it will pursue amendments to the GSS in due course. Welsh Government will work with Ofwat and CCW to ensure any changes to the scheme take into account the Welsh regulatory context and apply to undertakers in Wales effectively. It will refer to the change made in England to avoid conflict or difficulty.
Summary of responses
Number of responses
251 responses were received in total. 215 were via Citizen Space (Defra’s online consultation tool, referred to as ‘Online responses’) and the remaining 36 were via email.
Of the respondents:
- 218 were categorised as ‘a customer or individual’
- 33 were categorised as ‘a representative of an organisation or company’, of which 22 were representatives of water companies and retailers, and 11 were representatives of sector stakeholder groups and regulatory bodies
| Format of response | Customer or individual | Representative of water company or retailer | Representative of stakeholder group or regulatory body | Total responses |
|---|---|---|---|---|
| Citizen Space (online) | 195 | 11 | 9 | 215 |
| 23 | 11 | 2 | 36 | |
| All formats | 218 | 22 | 11 | 251 |
A list of all organisations who responded to this consultation is included in Annex B.
Customer or individual – Online responses
195 respondents initially categorised themselves on Citizen Space as ‘a customer or individual’. These respondents were asked to provide further context to the way they pay water or sewerage bills:
- 179 respondents indicated they ‘pay for water and sewerage for primarily domestic purposes’
- 0 respondents indicated they ‘pay for water and sewerage for primarily business purposes’
- 4 respondents indicated they ‘pay for both domestic and business purposes’
- 10 respondents indicated they ‘have a different arrangement’
- 2 respondents were ‘unsure’
| Primary purpose of payment for water bills | Number of respondents | Percentage of respondents |
|---|---|---|
| Domestic | 179 | 92% |
| Business | 0 | 0% |
| Both domestic and business | 4 | 2% |
| Different arrangement | 10 | 5% |
| Unsure | 2 | 1% |
Of the online respondents identified as customers, 5 categorised their business as a ‘micro-entity (under 10 employees full time equivalent (FTE))’. Of those who have a different arrangement for paying their water and sewerage bills, most explained that they either:
- pay only for water bills
- do not have mains drainage provided by a water or sewerage company (septic tank or private sewage disposal arrangement)
All 195 online respondents who categorised themselves as ‘a customer or individual’ were asked if, prior to the consultation, they were aware of the GSS:
- 52 responded ‘Yes’
- 125 responded ‘No’
- 18 responded ‘Unsure’
| Aware of GSS before consultation | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 52 | 27% |
| No | 125 | 64% |
| Unsure | 18 | 9% |
All 195 online respondents who categorised themselves as ‘a customer or individual’ were asked if, prior to the consultation, their household or business had been eligible for a GSS payment in the past year:
- 6 responded ‘Yes, my household’
- 0 responded ‘Yes, my business’
- 0 responded ‘Yes, both’
- 119 responded ‘No’
- 68 responded ‘Unsure’
- 2 responded ‘Other’ and provided individual context to eligibility for GSS payments and other support
| Eligibility for GSS payment in past year | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes, my household | 6 | 3% |
| Yes, my business | 0 | 0% |
| Yes, both | 0 | 0% |
| No | 119 | 61% |
| Unsure | 68 | 35% |
| Other | 2 | 1% |
All 195 online respondents who categorised themselves as ‘a customer or individual’ were asked if, prior to the consultation, their household or business had received a GSS payment in the past year:
- 5 responded ‘Yes, my household’
- 0 responded ‘Yes, my business’
- 1 responded ‘Yes, both’
- 177 responded ‘No’
- 11 responded ‘Unsure’
- 1 responded ‘Other’ and provided individual context to eligibility for GSS payments and other support
| Received a GSS payment in the past year | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes, my household | 5 | 4% |
| Yes, my business | 0 | 0% |
| Yes, both | 1 | 1% |
| No | 177 | 91% |
| Unsure | 11 | 6% |
| Other | 1 | 1% |
Representative of an organisation or company – Online responses
20 online respondents initially categorised themselves as ‘a representative of an organisation or company’ and were asked to provide further context to its nature:
- 11 responded ‘Water company or retailer’
- 1 responded ‘Consumer group’
- 1 responded ‘Regulatory body’
- 0 responded ‘Activist or advocacy group’
- 7 responded ‘Other’ and provided individual details of their organisation or company’s nature
| Nature of organisation or company | Number of respondents | Percentage of respondents |
|---|---|---|
| Water company or retailer | 11 | 55% |
| Consumer group | 1 | 5% |
| Regulatory body | 1 | 5% |
| Activist or advocacy group | 0 | 0% |
| Other | 7 | 35% |
These 20 online respondents were also asked to provide further context to the size of their organisation or company:
- 4 responded ‘Micro-entity (under 10 employees FTE)’
- 1 responded ‘Small (10 to 49 employees FTE)’
- 4 responded ‘Medium (50 to 250 employees FTE)’
- 11 responded ‘Large (over 250 employees FTE)’
| Size of organisation or company | Number of respondents | Percentage of respondents |
|---|---|---|
| Micro-entity (under 10 employees FTE) | 4 | 20% |
| Small (10 to 49 employees FTE) | 1 | 5% |
| Medium (50 to 250 employees FTE) | 4 | 20% |
| Large (over 250 employees FTE) | 11 | 55% |
Analysis of responses
Methodology
Questions were posed to respondents on proposals to:
- increase payment values for existing standards
- update wording and details of existing standards
- introduce new standards
For each standard, respondents were asked if they support:
- the proposal overall
- the specific value of payments in the proposal (split between household and non-household customers where appropriate)
This was intended to help distinguish general support for updates to standards from support for specific proposed values. For each of these questions, respondents could answer ‘Yes’, ‘No’ or ‘Unsure’. If ‘No’ was selected, then respondents were asked to explain their answer.
The ‘Yes’, ‘No’ and ‘Unsure’ responses received online via Citizen Space have been quantified. Defra has carried out a thematic analysis of the qualitative comments from respondents who responded ‘No’ to individual questions. Defra has also considered each individual standard to analyse responses to specific proposals. A summary of analysis is included in the following section, and a full breakdown of analysis question by question is included in Annex A.
Defra has thematically analysed responses received by email, and has considered them in the context of specific standard proposals where appropriate. Otherwise, responses are considered more broadly as applying to the proposals. This is included in the following summary of analysis.
Summary of analysis – Online responses
Annex A contains a full breakdown of analysis of the online responses to every question posed in the consultation. The support for general standards ranged from 62% to 93% agreement. Most of the proposals had over 80% agreement (the median of these questions was 82%), showing the response was generally favourable and support was high. However, the specific payment values questions had a support range of 45% to 69% (with a median of 62%), which suggests some proposed payments need further review.
This suggests broad support for the proposed updates to the statutory GSS to improve the baseline level of customer protection in the sector. However, the relative values of proposed payments are less broadly supported.
Groups who responded online indicated support for the general proposals:
- 195 online respondents identified themselves as customers, expressing agreement with the general proposals ranging between 54% to 93%, with a median of 84%
- 20 companies or businesses expressed agreement with the general proposals ranging between 45% to 95%, with a median of 70%
Groups who responded online indicated less strong support for the specific payment values:
- 195 online respondents identified themselves as customers, expressing agreement with the proposed specific values ranging between 46% to 71%, with a median of 64%
- 20 companies or businesses expressed support for the proposed specific values ranging between 30% to 65%, with a median of 50%, showing that further consideration needs to be given to these measures
Notably, there are varying levels of opposition to the proposals from groups with similar levels of support. Some groups submitted more ‘Unsure’ responses, while others tended to submit more ‘No’ responses. This resulted in nominal support levels that appear similar, but in fact mask varying levels of real opposition from different groups. As a result, Defra has used simple support figures to provide a picture of absolute support and reduce ambiguity around opposition vs uncertainty in responses to the proposals.
For example, the general proposals received very similar support levels from ‘Water companies and retailers’ and ‘Sector organisations and bodies’. However, they had significantly different levels of opposition due to variation in the levels of uncertainty. Additionally, the average level of support from ‘Customers’ for the general proposals was 82.3%, while the support for specific payment values was lower, at 61.7%. However, the level of opposition to the payment values was only 15% higher than that to the general proposals. This is because more customers responded ‘Unsure’ to the specific payment values than the general proposals. The breakdown of ‘Yes’, ‘No’ and ‘Unsure’ responses is detailed further in Annex A.
While there was generally clear support for the proposals, those expressing concern or opposition to the proposals consistently raised certain themes, including:
- payment values being insufficient to provide an incentive to companies to change behaviour or to remedy the impact of service failures on customers
- the risk of uprated payments being passed on into higher bills for customers
- concerns regarding how standards are implemented fairly and reasonably
Consultation part 2.1: increasing payment values
On average, across all the proposed changes to existing standards in this part:
- 82.4% of online respondents supported increasing the payment values
- 66.0% supported the specific values proposed to double the payments in line with inflation since 2000
- 24.1% opposed the specific payment values
- 9.8% were unsure
Comments of those who did not support the increases focused on:
- the increase in payment amounts being insufficient to incentivise change or remedy the impact on customers
- the cost of the changes impacting bills and reducing investment elsewhere
- the rationale and methodology for applying increases
Consultation part 2.2: updating existing standards
On average across all proposed changes to existing standards in this part, 81.5% of respondents supported the updates to the wording.
Those who did not support the updates focused on concerns about:
- the specific wording of standards to ensure responsibility is fairly distributed
- the need to ensure there are no easy ‘get out’ clauses for companies to avoid payments
Consultation part 2.3: proposed new standards
On average across all the proposed new standards in this part:
- 82.9% of respondents supported the introduction of the proposed new standards
- 53.5% supported the respective payment values
- 29.9% opposed the proposed payment values
- 16.7% were unsure, representing the highest average uncertainty of each section of responses
The key concerns of those who did not support the proposed standards and their respective payment values focused on:
- the payment values being too low to sufficiently remedy the impact of service failures on customers
- the interaction between the standards and other duties (particularly regarding the Drinking Water Quality (DWQ) notice standard)
- the specific time periods mandated by the meter reading and installation and DWQ standards, which some responses indicated were too long and others too short
Summary of analysis – Email responses
The responses submitted via email were thematically and qualitatively analysed to bring out key themes.
Customers and individuals
Defra received 23 email responses from the public, which they analysed in terms of support, opposition and concerns regarding the proposals.
Out of the 23 emails, 7 expressed support for some or all of the proposals, while 6 opposed them. Notably, 8 of the responses did not directly reference the consultation topic. Of these, 4 conveyed frustrations towards existing regulation of water companies, and 3 indicated general support for holding water companies financially accountable. However, these responses did not address payments for service standard failures.
The most common concern, raised in 8 out of the 23 responses, was the issue of costs. This included:
- 4 responses expressing apprehension that increased compensation could lead to higher customer bills
- 5 responses suggesting funds could be better used to address underlying industry problems rather than compensating customers
Of the responses highlighting these concerns over cost, 5 still supported some or all of the proposals.
Overall, while email responses slightly leaned toward supporting the proposals, there were concerns about financial implications for customers and misuse of funds that could instead be invested to improve industry infrastructure. This concern spanned across both supportive and opposing viewpoints.
Companies and sector bodies
Company respondents provided 11 email responses and 3 submissions of supplementary information from companies who responded primarily on Citizen Space. Defra also received email responses from CCW and Ofwat.
Defra carried out thematic analysis of the 14 email responses from companies, including the submissions adding additional details to online responses. 12 of these responses expressed general support for most of the proposals, while 2 expressed opposition to most with some support for specific aspects of the proposals. No response was entirely opposed to all proposals.
The most common theme in these responses was a lack of clarity in the proposals. All 14 requested some degree of further clarity and detail as to how the proposals would be implemented.
Otherwise, themes focused on:
- the need to avoid unreasonable business costs, included in 7 responses
- liability for faults caused by third parties, included in 8 responses
- suggestions that the payment values are too high in 5 responses
- suggestions that the relative payment values should be readjusted in 6 responses
- the need to further consider the impacts of changes in the context of retail companies, new appointments and variations (NAVs), water only companies and non-household customers, included in 5 responses
In addition, responses from 2 large water and sewerage companies expressed that certain payment values should be uprated further, and certain standards should be taken further than proposed.
Overall, all company responses showed support for the proposals in principle but expressed various degrees of concern about:
- the details of the changes
- the impacts on companies of implementing the changes
CCW responded positively to all proposals, expressing support for all changes. However, they expressed specific concern around the 24-month period included in the proposed meter reading standard, which CCW argues is too long. Instead, CCW expressed that an achievable and reasonable standard that would ensure good customer outcomes is to set this period at 13 months.
Ofwat also responded positively to the proposals in principle and agreed the changes are positive for customer protection in the sector. However, the response included concerns that the relative payment values in the standards should be developed further to more accurately reflect the impact on customers. In particular, they highlighted that the payment values for Sewer Flooding and Drinking Water Quality standards need further consideration.
Government response
Responses to this consultation were predominantly supportive of the changes proposed. In general, most responses that did not support the changes tended to object to the specific payment values proposed, expressing that they were too low to be meaningful. Therefore, while considering industry stakeholder suggestions and wider sector issues, government will account for these responses by:
- retaining all proposals at minimum
- uprating certain payment values and tightening the proposals in the consultation document for specific standards that had significant opposition and sufficient accompanying evidence
Defra will therefore proceed to implement updates to the Guaranteed Standards Scheme by bringing forward secondary legislation. This will come under the powers set out in Sections 38/39 and 95/96 of The Water Industry Act 1991.
This secondary legislation will seek to amend The Water Supply and Sewerage Services (Customer Service Standards) Regulations 2008. The legislation will amend the existing standards to:
- at least double all payment values
- improve existing standards
- introduce new standards to the scheme
These changes will be made based on the positive response to proposals on which Defra consulted.
The legislation will apply only to England. Welsh Government will pursue similar changes independently, with the intention of making updates tailored to Welsh customers in collaboration with Ofwat. It will be down to the discretion of individual companies who operate primarily in Wales whether to implement the changes:
- at the same time as English companies
- when Welsh Government has brought its own legislative changes
The updated scheme will serve the same purpose as the existing one: setting the minimum level of service standards water and sewerage companies must provide to customers. It will ensure that a stronger level of customer protection is guaranteed.
Companies should endeavour to consider where their customers may expect higher standards of service than those outlines within this scheme. They should provide additional guarantees of service and payments for failing these standards on a discretionary basis.
The amendments brought forward will take responses to the consultation into consideration, with reasoning for changes to the original proposals detailed below.
Changes to proposals
In general, responses to every proposal were more positive than negative.
In addition, every proposal for general standard changes received greater than 65% support. All specific payments that received below 65% support were objected to predominantly by respondents who expected payment values to be higher. As a result, the proposals on which Defra consulted will be retained in full. Further steps to go beyond these proposals will be considered where respondents expressed significant opposition to certain proposals and provided sufficient accompanying evidence.
Defra will consider how the original proposals can be improved upon in these cases, accounting for both the concerns of respondents who:
- expect the standards to go further
- expressed concerns that the changes may bring additional burden and cost, particularly for companies and suppliers
For the purpose of assessing changes, Defra has used indicative boundaries of 65% and 50% to provide a structured approach to analysis of the responses. This enables differentiation of proposals with particularly low support (under 50%) and slightly low support (50% to 65%) in the wider analysis.
However, it is vital to ensure all views are taken into account. Consultation responses are not a representative sample of the sector. Therefore, in addition to this structured approach, Defra will consider and factor further comments and responses into changes where possible. In particular, this will include responses from key sector stakeholders such as Ofwat, DWI, CCW, and companies and retailers. This will ensure that as many stakeholders as possible are satisfied with the legislative changes.
Importantly, customer responses and further research from Ofwat and CCW reveal both awareness of the GSS is low and perception of the scheme is consistently inaccurate. This is revealed in the tendency for customers to have responded expressing concern that payment amounts are insufficient to compensate customers for the harm caused by service failures. This is not the intention of the GSS. These concerns are helpful in that they express the wider situation in the sector that customer service and trust in companies is at an all-time low. This means such channels for customer service protection should be strengthened. However, this specific argument is not directly applicable.
Customers can seek compensation for damages or harm through alternative channels. The GSS is intended to establish guaranteed standards of service that all companies must provide, alongside reconciliatory payments to customers where these standards are contravened.
The updates proposed within this consultation strengthen the guaranteed standards of service provided for in the scheme, and at least double the payments to which customers are entitled.
Following the responses to this consultation, Defra will consider options for taking further steps, including uprating payments beyond the proposed values. These changes intend to improve levels of customer trust in the sector and help shift companies’ focus onto ensuring high standards of service for their customers.
The key areas for potential changes to the proposals contained in the consultation are laid out in the following sections.
Uprating payment values further
A significant proportion of responses focused on the relative payment values for different standards. In particular, a large proportion of customers who responded negatively to proposals expressed that payment values are insufficient to either:
- act as a strong incentive for companies to improve their service
- provide sufficient remedy for the poor service experienced
In addition, Ofwat expressed in response to the consultation that while it supports the changes generally, the relative payment values should be “further refined”. This is to ensure they fairly represent the relative impact of different service failures on the end customer. This is supported by separate Ofwat research. The research found that customers expect payments for different standards to reflect the relative severity, impact and inconvenience caused by the corresponding company service failure.
As discussed, payments are not intended to compensate customers for harm. However, this degree of customer opposition expecting higher payment values motivated by an expected reflection of the severity of an incident indicates the need for change. While the GSS does not compensate for damages, the payment levels should rightly be higher where customer impact is particularly severe.
To address these concerns, Defra will consider further uprating payment values proposed in the consultation that received low support rates (below 65% support). These include the proposed payment values for the following standards:
- failure to restore supply standard – non-household proposed value increase (61.9% support)
- sewer flooding – minimum and maximum proposed value increases (62.3% support)
- new incorrect debt action standard – proposed values (54.9% support)
- new drinking water quality (DWQ) notice standard – proposed household value (50.7% support)
- new DWQ notice standard – proposed non-household values (49.8% support)
- new Priority Services Register (PSR) standard – proposed values (45.1% support)
These payment values will be reviewed and reconsidered in light of the responses. In particular, those that received below 50% support will be increased further.
However, all responses will be taken into account. Responses from companies, which tend to express acceptability of the proposed payment values or less, will be balanced against these wider concerns in the final decisions.
In addition, the alterations to the proposals will not be limited to these standards. Where other stakeholder concerns have been raised regarding different standards, Defra will consider further amendments. This will ensure a broadly acceptable outcome for the legislative updates to the scheme.
Amendments to existing standards and new standards
As well as the broader concerns in responses relating to the proposed payment values for standard breaches, some respondents raised specific concerns about certain standards.
In particular, the proposal to introduce a force majeure clause to replace the weather exemptions in the existing sewer flooding standard only received 62.3% support. This standard was proposed to replace the weather exemptions that will be removed from several standards based on CCW’s recommendations. This is because customers perceive these exemptions to provide companies with an easy ‘get out’ clause from making payments for service failures. Instead, a less lenient clause that made allowance for genuinely exceptional circumstances but prevented regular avoidance of liability was proposed. This was supported in consultation responses from multiple companies. These companies indicated they voluntarily and regularly disapply the existing exemptions in practice to ensure that customers do not feel let down.
Qualitative analysis of responses indicated concerns that the new ‘force majeure’ clause may be an ineffective measure. Responses suggested that companies could use this clause to avoid making payments in the event of service failures. Most responses focused on the possibility of creating a new ‘get out’ clause. Others requested more clarity and emphasised the importance that the clause is worded carefully to ensure it does not render the standards to which it applies obsolete.
As a result, Defra will work to clarify the requirements for such a clause. It is vital to recognise that customers expect companies to acknowledge when failures take place and to fulfil their responsibilities under the GSS.
However, it is also important to appreciate it would be unreasonable to require companies to make payments to all affected customers in some genuinely extreme circumstances. These are circumstances a company could not have predicted or possibly mitigated against, such as national-scale natural disasters. Defra will work to ensure the force majeure clause included in the final policy will find the necessary balance between these perspectives. Defra will also engage stakeholders to consider views on what might provide the best outcome for customers.
Next steps
Following the publication of this response document, Defra will:
- continue to engage with sector stakeholders and partners
- seek to pursue secondary legislation to implement these changes in law
This will involve the drafting and laying of a statutory instrument (SI). The SI will set out in detail the changes to existing standards and proposed new standards that this consultation was launched to gather views on.
Defra will ensure that this process remains collaborative and will engage throughout with key sector stakeholders, including regulators, industry bodies, companies and representative organisations.
The final SI will be laid in Parliament. It will seek to implement the changes outlined in the consultation, which were supported in the main. It will also include some amendments to further strengthen consumer protection measures in the sector where opposition has been expressed.
Annex A: analysis of online responses, by question
Part 2.1 of the consultation asked for respondent views on the proposed updates to the statutory payment levels within the existing standards. This section posed questions regarding these proposals as they applied to groups of similar standards. Respondents were asked for their views on the proposals to increase payment values in general and for their views on the specific payment values proposed.
Part 2.2 of the consultation proposed updates to existing standards in order to tighten the requirements and bring them in line with existing practice in the sector. Respondents were asked for their views on each of the proposed changes individually and, where appropriate, for their views on particular aspects of the changes.
Part 2.3 of the consultation proposed certain new standards to introduce to the GSS. The questions invited views from respondents on the proposed standards in general, and on the specific payment values proposed for each standard.
Part 2.4 of the consultation proposed 2 further changes to the manner in which the GSS is updated in future, and how it is administered by companies in general. Respondents were asked for their views on each of the changes, and in particular on any challenges which might be met in implementation.
Finally, in part 2.5, 7 additional optional questions were posed to respondents, with open text boxes inviting comment where appropriate.
Consultation part 2.1a: customer service standards
Question 1: Overall, do you support the policy to update payment values for customer service standard failures, setting aside the specific payment values?
| Support updating payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 177 | 82% |
| No (please explain) | 28 | 13% |
| Unsure | 20 | 5% |
Total responses: 215
This question had an overall positive response, with 82% supporting the update. Of the 20 online responses from companies and businesses to this question, 14 responded ‘yes’, 4 responded ‘no’ and 2 were ‘unsure’.
There were 38 responses to the open text box for this question. Of these, some of the negative themes that emerged were worries that it would result in higher bills for customers, the values would be too low and they could be ineffective.
Some of the key supportive themes were that the measures would be acceptable and could improve industry infrastructure and services.
Question 2: Do you support the proposed specific payment values for each customer service standard?
| Support specific values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 145 | 67% |
| No (please explain) | 49 | 23% |
| Unsure | 21 | 10% |
Total responses: 215
This question had an overall positive response, with 67% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded ‘yes’, 7 responded ‘no’ and 3 were ‘unsure’.
There were 55 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that the specific payment values would be too low, concerns with implementation and that they would be ineffective. Some of the key supportive themes highlighted a need for improvement to industry infrastructure and services, and that missed appointments have a major impact on customers so warrant high payment values.
Consultation part 2.1b: Supply interruption standards
Question 1: Overall, do you support that policy update payment values for failing to meet supply disruption standards, setting aside the specific payment values?
| Support updating payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 178 | 83% |
| No (please explain) | 26 | 12% |
| Unsure | 11 | 5% |
Total responses: 215
This question had a very positive response overall, with 83% supporting the update. Of the 20 online responses from companies and businesses to this question, 14 responded ‘yes’, 4 responded ‘no’ and 2 were ‘unsure’.
There were 35 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that payment values would be too low, concerns with implementation and that they would be ineffective. One of the supportive themes was possible improvement to industry infrastructure and services.
Question 2: Do you support the proposed specific payment values for each supply disruption standard for household customers?
| Support specific household values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 143 | 67% |
| No (please explain) | 57 | 27% |
| Unsure | 15 | 7% |
Total responses: 215
This question had an overall positive response, with 67% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded ‘yes’, 7 responded ‘no’ and 3 were ‘unsure’.
There were 60 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that the specific payment values would be too low, concerns with implementation and that they would be ineffective.
Question 3: Do you support the proposed specific payment values for each supply disruption standard for non-household customers?
| Support specific non-household values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 133 | 62% |
| No (please explain) | 49 | 23% |
| Unsure | 33 | 15% |
Total responses: 215
This response to this question was supportive, but not strongly so, with 62% supporting the update. Of the 20 online responses from companies and businesses to this question, 9 responded ‘yes’, 8 responded ‘no’ and 3 were ‘unsure’.
There were 54 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that the measures would be ineffective, that they should go further and that they should be business specific.
Consultation part 2.1c: Incidents of low pressure
Question 1: Overall, do you support the proposed policy to update the statutory payment values in incidents of low pressure, setting aside the specific payment values?
| Support updating payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 177 | 82% |
| No (please explain) | 26 | 12% |
| Unsure | 12 | 6% |
Total responses: 215
This question received a very positive response overall, with 82% supporting the update. Of the 20 online responses from companies and businesses to this question, 15 responded ‘yes’, 3 responded ‘no’ and 2 were ‘unsure’.
There were 37 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that the measures would be ineffective, that the definition of low pressure was unclear and therefore might be denied by water companies, and that the measures should go further.
Question 2: Do you support the proposed specific payment values for incidents of low pressure or in the event a customer receives a consistent supply of water with inadequate pressure?
| Support specific values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 149 | 69% |
| No (please explain) | 45 | 21% |
| Unsure | 21 | 10% |
Total responses: 215
This question had an overall positive response, with 69% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded ‘yes’, 7 responded ‘no’ and 3 were ‘unsure’.
There were 56 responses to the open text box for this question. Of these, some of the main negative themes that emerged were that the specific payment values would be too low, that they would be ineffective and that there could be repeated issues that the company would need incentive to resolve.
Question 3: Do you agree with the proposal to lift the cap on the number of times a customer can claim due to low pressure from one incident to five incidents over a year?
| Support lifting cap | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 167 | 78% |
| No (please explain) | 39 | 18% |
| Unsure | 9 | 4% |
Total responses: 215
This question had an overall positive response, with 78% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded ‘yes’, 7 responded ‘no’ and 3 were ‘unsure’.
There were 44 responses to the open text box for this question. Of these, some of the main themes that disagreed with the proposal included saying the cap should be removed, that there should be a definition of a standard problem, and the money would be better spent elsewhere. Some of the supportive themes included incentivising resolutions, preventing repeat offences and general acceptance of the proposal.
Consultation part 2.1d: Sewer flooding standards
Question 1: Overall, do you support updating the payment values in the event of sewer flooding, setting aside the specific payment values?
| Support updating payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 179 | 83% |
| No (please explain) | 26 | 12% |
| Unsure | 10 | 5% |
Total responses: 215
This question had an overall strong positive response, with 83% supporting the update. Of the 20 online responses from companies and businesses to this question, 12 responded ‘yes’, 2 responded ‘no’ and 6 were ‘unsure’.
Question 2: Do you support the proposed specific minimum and maximum payment values in the event of internal and external sewer flooding?
| Support specific values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 134 | 62% |
| No (please explain) | 58 | 27% |
| Unsure | 23 | 11% |
Total responses: 215
This question had a positive response overall, with 62% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded ‘yes’, 4 responded ‘no’ and 6 were ‘unsure’.
There were 69 responses to the open text box for this question. Of these, some of the main themes that disagreed with the proposal included that payment values would be insufficiently low, that they should be case specific to cover all costs to the customer and that it should account for non-financial harm.
Consultation part 2.1e: Penalty payments
Question 1: Overall, do you support updating the payment values in the event a company fails to pay GSS payment within a given time frame, setting aside the specific payment values?
| Support updating payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 185 | 86% |
| No (please explain) | 22 | 10% |
| Unsure | 8 | 4% |
Total responses: 215
This question had a very positive response, with 86% supporting the update. Of the 20 online responses from companies and businesses to this question, 16 responded ‘yes’, 2 responded ‘no’ and 2 were ‘unsure’.
There were 22 responses to the open text box for this question. Of these, the most significant theme was that the values would be ineffective. Respondents felt the proposals should go further because the values are too low to incentivise water companies.
Question 2: Do you support the proposed specific payment values in the event a company fails to pay a GSS payment within a given time frame?
| Support specific values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 148 | 69% |
| No (please explain) | 53 | 25% |
| Unsure | 14 | 7% |
Total responses: 215
This question had a positive response, with 69% supporting the update. Of the 20 online responses from companies and businesses to this question, 11 responded ‘yes’, 7 responded ‘no’ and 2 were ‘unsure’.
There were 57 responses to the open text box for this question. Of these, the most significant themes were that the penalty payment values are insufficient and should go further. A minority of responses, particularly from water companies, included themes that the penalty payments go too far and introduce costs to the industry which would be better spent elsewhere.
Consultation part 2.1f: Payment values further comments
Do you have anything further to comment on the updating of the current statutory minimum payment policies as outlined in this Part 2.1?
There were 108 responses to this open text box question. Of these, the most significant theme was a desire for stronger regulation of the sector more widely. The next strongest theme was that the payments proposed were insufficient and ineffective to improve services. A minority of responses included themes that the proposed payments are too high and introduce additional cost to bills. Many of these responses related to a wide variety of sector issues more generally.
Consultation part 2.2a: Broadening internal flooding from sewers
Do you support the proposal to define outbuildings used for domestic activities as ‘internal’ for the purposes of the GSS?
| Support broadening | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 175 | 81% |
| No (please explain) | 14 | 7% |
| Unsure | 26 | 12% |
Total responses: 215
This question had a very positive response, with 81% supporting the update. Of the 20 online responses from companies and businesses to this question, 11 responded yes, 2 responded no (please explain) and 7 were unsure.
There were 23 responses to the open text box for this question. Of these, the main theme was that further clarity is needed to ensure the guidance is effective and reasonable and does not contradict Ofwat guidance or introduce unfair company liability.
Consultation part 2.2b: Weather exemptions
Question 1: Do you support the proposal to remove the exceptional weather exemption from the sewer flooding standards?
| Support removing exceptional weather exemption | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 167 | 78% |
| No (please explain) | 26 | 12% |
| Unsure | 22 | 10% |
Total responses: 215
This question had a positive response, with 78% supporting the update. Of the 20 online responses from companies and businesses to this question, 11 responded yes, 2 responded no (please explain) and 7 were unsure.
There were 34 responses to the open text box for this question. Of these, one of the main themes was that exceptional weather events are becoming more common, requiring better definitions and improved clarity to prevent unfair company liability. Other minor concerns included that companies should invest more in infrastructure to prepare for exceptional weather, and that any exemptions could provide an easy ‘get out’ clause for companies to avoid making payments.
Question 2: Do you support the proposal to remove the severe weather exemption from the supply restoration standards?
| Support removing severe weather exemption | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 173 | 80% |
| No (please explain) | 27 | 13% |
| Unsure | 15 | 7% |
Total responses: 215
This question had a positive response, with 80% supporting the update. Of the 20 online responses from companies and businesses to this question, 12 responded yes, 4 responded no (please explain) and 4 were unsure.
There were 25 responses to the open text box for this question. Of these, some of the main themes were similar to the prior question, expressing that exceptional weather events are becoming more common, requiring better definitions and improved clarity to prevent unfair company liability.
Question 3: Do you support the proposal to retain the exceptional weather exemption for supply restoration, appointments and visit attendance where to complete the activity would risk the safety of water company staff?
| Retain exceptional weather exemption for staff safety | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 160 | 74% |
| No (please explain) | 27 | 13% |
| Unsure | 28 | 13% |
Total responses:215
This question had a positive response, with 74% supporting the update. Of the 20 online responses from companies and businesses to this question, 16 responded yes, 1 responded no (please explain) and 3 were unsure.
There were 31 responses to the open text box for this question. Of these, some of the main themes were that retention of this exemption could be used as an easy ‘get out’ clause for companies to avoid making payments, and that companies should be responsible for investment in infrastructure to cope with exceptional weather events. Also, consistent themes were that more clarity is needed on the scope of such exemptions, and a definition of exceptional weather would be beneficial.
Question 4: Do you support the proposal to introduce a replacement ‘force majeure’ clause in the case of sewer flooding?
| Support ‘force majeure’ replacement clause | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 134 | 62% |
| No (please explain) | 42 | 20% |
| Unsure | 39 | 18% |
Total responses: 215
This question had a positive response, with 62% supporting the update. Of the 20 online responses from companies and businesses to this question, 9 responded yes, 3 responded no (please explain) and 8 were unsure.
There were 49 responses to the open text box for this question. Of these, some of the main themes were again that this exemption could be used as a ‘get out’ clause for companies to avoid making payments, and that more clarity on the scope and wording of this exemption is needed. Some responses also contained the theme that companies should have a responsibility to invest in preparation for exceptional weather events.
Consultation part 2.2c: Methods of communication
Do you support this proposal to align communication methods across all standards?
| Align communication methods | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 198 | 92% |
| No (please explain) | 8 | 4% |
| Unsure | 9 | 4% |
Total responses: 215
This question had a very positive response, with 92% supporting the update. Of the 20 online responses from companies and businesses to this question, 17 responded yes, 0 responded no (please explain) and 3 were unsure.
There were 13 responses to the open text box for this question. Of these, some of the main themes were that communications should be flexible and include oral, written and online channels, but that further clarity is needed to understand how this proposal may be implemented.
Consultation part 2.2d: Appointments
Do you support the proposal for a review and update of Ofwat’s guidance to provide clarity on organisation and definition of appointment timeslots?
| Review appointment guidance | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 196 | 91% |
| No (please explain) | 11 | 5% |
| Unsure | 8 | 4% |
Total responses: 215
This question had a positive response, with 91% supporting the update. Of the 20 online responses from companies and businesses to this question, 15 responded yes, 2 responded no (please explain) and 3 were unsure.
There were 10 responses to the open text box for this question. Of these, some of the main themes were that such guidance must include further clarity and may be ineffective or unnecessary for improvements. Some other themes, in particular in responses from companies, were that inflexible guidance would be unhelpful, and that appointment arrangements should be clear and not introduce unnecessary costs, particularly to retailers.
Ofwat supports this proposal and will review in light of the responses to this consultation.
Consultation part 2.2e: Low pressure
Do you support this proposal for Ofwat to introduce new guidance on communicating the low-pressure standard to customers?
| New low-pressure guidance | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 199 | 93% |
| No (please explain) | 6 | 3% |
| Unsure | 10 | 5% |
Total responses: 215
This question had a very positive response, with 93% supporting the update. Of the 20 online responses from companies and businesses to this question, 19 responded yes, 0 responded no (please explain) and 1 was unsure.
There were 14 responses to the open text box for this question. Of these, some of the main themes were that such guidance must enable improved customer understanding of pressure measurement and help to align definitions with existing regulations. In addition, there were themes that the minimum pressure currently included in the scheme is insufficient, and that wider regulation of pressures is ineffective.
Ofwat supports this proposal and will review in light of the responses to this consultation.
Consultation 2.3a: Incorrect debt action standards
Question 1: Do you agree with the introduction of new debt action standards?
| Support debt action standard | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 182 | 85% |
| No (please explain) | 17 | 8% |
| Unsure | 16 | 7% |
Total responses: 215
This question had a very positive response, with 85% supporting the update. Of the 20 online responses from companies and businesses to this question, 15 responded yes, 3 responded no (please explain) and 2 were unsure.
There were 22 responses to the open text box for this question. Of these, some of the main themes were that the payment amount is insufficient and ineffective, and that such incidents could cause significant distress to customers. However, a minority of responses include themes that implementation of this standard would be complex and must include exemptions where customers are at fault, and that they may increase costs of bills.
Question 2: Do you think that the proposed payment rates for both household and non-household customers are suitable?
| Support payment rates | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 118 | 55% |
| No (please explain) | 62 | 29% |
| Unsure | 35 | 16% |
Total responses: 215
This question had 55% in agreement, which is generally favourable but not strong support. Of the 20 online responses from companies and businesses to this question, 13 responded yes, 3 responded no (please explain) and 4 were unsure.
There were 62 responses to the open text box for this question. Of these, a large majority of themes were that the payment amount is insufficient and ineffective, and that such incidents could cause significant distress to customers. Again, a minority of responses include themes that implementation of this standard may increase costs of bills and the payment values are too high.
Consultation part 2.3b: Meter reading and installation standards
Question 1: Do you agree with the introduction of new meter reading and installation standards?
| Support metering standards | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 180 | 84% |
| No (please explain) | 23 | 11% |
| Unsure | 12 | 6% |
Total responses: 215
This question had a very positive response, with 84% supporting the update. Of the 20 online responses from companies and businesses to this question, 13 responded yes, 5 responded no (please explain) and 2 were unsure.
There were 27 responses to the open text box for this question. Of these, some of the main themes were that the payment amount is insufficient and that the grace period of 24 months is too long. Other themes included that implementation of this standard would be complex and must include consideration of smart meter rollouts, and it may result in increased costs in bills.
Question 2: Do you think that the proposed payment rates are suitable?
| Support payment rates | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 144 | 67% |
| No (please explain) | 37 | 17% |
| Unsure | 34 | 16% |
Total responses: 215
This question had a positive response, with 67% supporting the update. Of the 20 online responses from companies and businesses to this question, 10 responded yes, 6 responded no (please explain) and 4 were unsure.
There were 36 responses to the open text box for this question. Of these, similarly to the prior question, the main themes were that the payment amount is insufficient and that the grace period of 24 months is too long. Other themes also included that implementation of this standard would be complex, that wider regulation must include consideration of smart meter rollouts, and that it may result in increased costs in bills.
Consultation part 2.3c: Priority Service Register (PSR) standard
Question 1: Do you agree with the introduction of the new priority service standard?
| Support PSR standard | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 173 | 80% |
| No (please explain) | 23 | 11% |
| Unsure | 19 | 9% |
Total responses: 215
This question had a very positive response, with 80% supporting the update. Of the 20 online responses from companies and businesses to this question, 12 responded yes, 5 responded no (please explain) and 3 were unsure.
There were 29 responses to the open text box for this question. Of these, the main themes were that the standard may be unnecessary and needs more clarity on what it requires.
Some responses included themes that the standard would be beneficial and that negative experiences could be reduced. However, others said that the payment value is insufficient, and the standard would unfairly favour PSR customers.
Question 2: Do you think that the proposed payment rate of £50 is sufficient to support vulnerable customers where a promised service has not been delivered?
| Support payment values | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 97 | 45% |
| No (please explain) | 75 | 35% |
| Unsure | 43 | 20% |
Total responses: 215
This question had a neutral response, with 45% supporting the update. Of the 20 online responses from companies and businesses to this question, 7 responded yes, 6 responded no (please explain) and 7 were unsure.
There were 72 responses to the open text box for this question. Of these, the most significant theme was that the standard provides insufficient payment for the inconvenience caused. Another major theme was that more detail is required for the standard to be flexible to the different needs of PSR customers. A minority of responses included themes that this standard may increase costs to bills and may be unnecessary and unfair in prioritising PSR customers.
Consultation part 2.3d: Drinking water quality notice standards
Question 1: Do you agree with the proposed introduction of drinking water quality notice standards?
| Support drinking water quality notice standard | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 180 | 84% |
| No (please explain) | 25 | 12% |
| Unsure | 10 | 5% |
Total responses: 215
This question had a very positive response, with 84% supporting the update. Of the 20 online responses from companies and businesses to this question, 11 responded yes, 4 responded no (please explain) and 5 were unsure.
There were 31 responses to the open text box for this question. Of these, the main themes were that companies should not be held unfairly responsible for notices issued due to third party faults, that the payment values are insufficient, and the grace period of 2 days is too long.
Additional themes also included concern that the standard could provide a perverse disincentive to issue notices for public health issues, and that wider regulation should be strengthened to prevent drinking water quality issues.
Question 2: Do you agree that the proposed payment of £10 per day triggered at the third day of a notice is sufficient for household customers?
| Support household payment value | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 109 | 51% |
| No (please explain) | 81 | 38% |
| Unsure | 25 | 12% |
Total responses: 215
This question had a neutral reaction, with 51% supporting the proposal. Of the 20 online responses from companies and businesses to this question, 6 responded yes, 7 responded no (please explain) and 7 were unsure.
There were 82 responses to the open text box for this question. Of these, the most significant themes were that the payment values are insufficient and the grace period of 2 days is too long. Additional minority themes again included concern that the standard could provide a perverse disincentive to issue notices for public health issues, that wider regulation should be strengthened to prevent drinking water quality issues, and that companies should not be held unfairly responsible for payments for third party faults.
Question 3: Do you agree that the proposed payment of £20 per day triggered at the third day of a notice is sufficient for non-household customers?
| Support non-household payment value | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 107 | 50% |
| No (please explain) | 66 | 31% |
| Unsure | 42 | 20% |
Total responses: 215
This question had a neutral reaction, with 50% supporting the proposal. Of the 20 online responses from companies and businesses to this question, 7 responded yes, 8 responded no (please explain) and 5 were unsure. This is the first instance where the business’ ‘No’ responses have been more than their ‘Yes’ responses.
There were 67 responses to the open text box for this question. Of these, the most significant theme was that the payment values are insufficient. Additional themes included concern that the grace period is too long, that the different contexts of business customers should be taken into account, that wider regulation should be strengthened to prevent drinking water quality issues, and that companies should not be held unfairly responsible for payments for third party faults.
Consultation part 2.3e: Other new standards
Question 1: Do you have any additional ideas for standards beyond that which is suggested in part 2.3?
| Additional standards | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 67 | 31% |
| No (please explain) | 128 | 60% |
| Unsure | 20 | 9% |
Total responses: 215
5 businesses or companies said yes, they had additional ideas for standards.
There were 69 responses to the open text box for this question. Of these, some of the themes included suggestions around wider regulation and reducing water pollution, ensuring company shareholders and executives are financially punished for poor service, and improving awareness and communication of the GSS standards.
Other themes included that the proposals are insufficient and may be ineffective and result in higher bills, that water supply quality must be improved, and any changes must be transparent.
Additionally, some responses included themes that companies should be consulted on future changes, should be fined for repeat service failures, and should face criminal liability for failures. Finally, there was support for regular inflationary and wider reviews of GSS.
Consultation part 2.4a: Inflation-based payment review clause
Question 1: Do you agree with the proposal for a joint review of payments to be triggered automatically after cumulative CPIH inflation exceeds 10%?
| Inflationary review | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 160 | 74% |
| No (please explain) | 31 | 14% |
| Unsure | 24 | 11% |
Total responses: 215
This question had a positive reaction with 74% supporting the proposal. Of the 20 online responses from companies and businesses to this question, 14 responded yes, 3 responded no (please explain) and 3 were unsure.
There were 33 responses to the open text box for this question. Of these, some of the main themes were that payments should automatically increase without review in line with inflation or bills, that the proposed 10% inflation trigger is too low, and that reviews should be planned regularly.
Other responses also included themes that the review may be overcomplicated and excessive or ineffective, that the focus should be on improving infrastructure and limiting shareholder profits, and that the 10% trigger is too high.
Question 2: Are there any challenges in implementing these proposals that you would like to highlight?
| Challenges to proposals | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 36 | 17% |
| No (please explain) | 136 | 63% |
| Unsure | 43 | 20% |
Total responses: 215
7 businesses or companies said yes, there are challenges to implementation.
There were 35 responses to the open text box for this question. Of these, some of the main themes were that implementation of changes could be overcomplicated and introduce costs to companies, and that they need further clarity, in particular for the inflationary measure.
Some additional themes were that privatisation is a barrier to further improvements, that the changes may take money away from infrastructure investments, and that executive and shareholder profits should not be protected from reductions.
Consultation part 2.4b: Automatic payments
Do you agree with the proposal that GSS payments should be made automatically to the extent practicable?
| Automatic payments | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 194 | 90% |
| No (please explain) | 9 | 4% |
| Unsure | 12 | 6% |
Total responses: 215
This question had a very positive reaction, with 90% supporting the proposal. Of the 20 online responses from companies and businesses to this question, 14 responded yes, 3 responded no (please explain) and 3 were unsure.
There were 15 responses to the open text box for this question. Of these, the theme of the majority was agreement with automation of payments. However, some other themes were that:
- the funding should be invested elsewhere
- the payments should be made according to the contextual differences between customers
- customers should still have an option to claim payments
- the costs may introduce a burden on company operations and should impact shareholder profits
Consultation part 2.5: Optional further questions
Question 1: What would be the impacts of these proposals for customers?
There were 93 responses to the open text box for this question.
Of these, the main themes were that the changes would improve service provision and remedy impacts on customers, improve trust and accountability of companies, and improve awareness and consistency of the application of the GSS.
However, a minority of responses contained themes that the changes would result in higher bills, would have limited or no impact on service provision, and would reduce investment elsewhere, requiring stronger regulation more widely to make a difference.
Question 2: The introduction of the PSR standard is intended to provide protection for vulnerable customers. Are you aware of any additional aspects of consumer protection that these proposals do not sufficiently provide for?
There were 57 responses to the open text box for this question.
The theme of the majority of responses was that the respondent was unaware of any additional aspects of consumer protection the proposals should provide for.
However, other responses included themes that the proposals are insufficient to provide effective consumer protection and that the different needs of PSR customers require different protections and tailored communications. A common theme was that greater clarity is needed for the standards. Wider concerns were that the standards provide too many exemptions for companies and that broader affordability concerns in the sector should be taken into account.
Question 3: What would be the impacts of these proposals for vulnerable customers?
There were 56 responses to the open text box for this question.
The main theme in the responses was that the proposals would improve the situation of vulnerable customers, and further themes included that customer wellbeing and trust would improve.
However, other responses included themes that there would be limited or no impact, and that the GSS should consider barriers to access and provide a tailored approach and financial help to vulnerable customers.
Question 4: Is there anything related to protection for vulnerable customers that has not been included in these proposals
There were 48 responses to this question, including 11 from businesses or companies.
18 of the 48 answered no, there was nothing more to include. Of the 30 that said yes, most pointed towards more flexible support for those on the Priority Services Register. This included saying it should be the water company’s responsibility to proactively ensure the register of vulnerable customers is up to date, and that some people are not online, so non-digital communication channels need to available.
Question 5: What is your experience of the provision of services to customers on the Priority Services Register, either in your capacity as a customer or as a company?
There were 47 responses to this question, including 11 from businesses or companies.
The responses from individuals detailed a mixture of positive and negative experiences, with the majority being negative, focussing on slow installation time or bad customer service. The responses from companies discuss their services and the main difficulty of tailoring services to those who need it most, particularly during larger events.
Question 6: Do you have any further evidence to indicate the likely number of breaches and cost of implementation of the proposed new standards that you would like to share?
| Further evidence on breaches and costs | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 7 | 3% |
| No (please explain) | 136 | 63% |
| Unsure | 72 | 33% |
Total responses: 215
This question had 9 open text responses, including 3 from businesses or companies.
The main themes were that more clarity is needed, and Defra should engage stakeholders that have knowledge on the subject. There was generally negative sentiment about pollution incidents and that there would be a minimal impact on the likely number of breaches.
Question 7: Are you aware of any potential disproportionate impacts of the updated standards on small and micro businesses?
| Disproportionate impacts on small and micro business | Number of respondents | Percentage of respondents |
|---|---|---|
| Yes | 5 | 2% |
| No (please explain) | 140 | 65% |
| Unsure | 70 | 33% |
Total responses: 215
There were only 7 open text responses for this question, including 2 from businesses or companies.
In general, these responses said the updated standards may disproportionately impact small and micro businesses. This is due to them having fewer resources and smaller budgets, making fixed penalties a more significant burden to them.
Annex B: summary of organisations who responded to this consultation
Water and sewerage and water only companies, retailers, and NAVs
Affinity Water Limited
Anglian Water Services
Business Stream
Dwr Cymru Welsh Water
ESP Utilities Group
Hafren Dyfrdwy
ICOSA Water Services
Independent Water Networks Limited
Leep Networks Water Ltd
Northumbrian Water Limited
Pennon Water Services Ltd
Portsmouth Water
Severn Trent Water
SES Water
South East Water Limited
South Staffs Water
South West Water and Bristol Water
Thames Water
United Utilities Water
Water Plus Limited
Wessex Water
Yorkshire Water
Consumer groups, advocacy groups, regulatory bodies, and other organisations
Micro-entities and small organisations (up to 49 employees FTE)
Airestead Property Developments Limited
Private Architect
Private Industry Consultant
Thetford River Group
Thorndon Court Ltd
Medium and large organisations (at least 50 employees FTE)
Bathroom Manufacturers Association
Brackenbury Residents Association
Citizens Advice working in partnership across Warwickshire
Consumer Council for Water
Drinking Water Inspectorate
Ofwat