Our review of five years of the water retail open market

Question 1: Why the focus on numbers rather than outcomes? Surely it’s about quality of service and levels of consumption rather than switches. Is customer satisfaction not the key indicator? 

We agree in principle that customers’ experience of the market should be measured by more than just the numbers of those engaging in the water retail market, and ideally we would want to look at outcomes. However, many small business customers don’t even know that the open market in England exists.

The number of engaged business customers is one of the primary measures of how successful the market is, as businesses will not be motivated to switch (or re-negotiate) unless there is something in it for them.

Our report is clear on the outcomes we want to see, and the measures of success across the key areas that are important to business customers. In addition, having compared the switch rates we have seen in the energy market, and other sectors, we believe the target we have set is realistic and achievable.

Question 2: Do you think splitting consumers into household and non-household is conducive to providing consistent service? Splitting businesses further into low and high usage is likely to create even more delays in assessing eligibility.

Household and non-household customers should be receiving consistent levels of service. However, the needs of business and household customers can vary due to usage, size and affordability. It is also recognised that struggling households can be offered financial support schemes if they fit certain criteria.

Retailers are required to know which of their customers sit in each of the three consumption bandings in the Retail Exit Code (REC) due to the different regulatory protections applying to each one. Therefore, understanding the numbers of business customers using up to 0.5Ml of water a year (Customer Group 1 in the REC) for the purpose of eligibility should be relatively straightforward for retailers.

Question 3: One of the promised benefits from competition was savings for customers. Has CCW looked at how the retail charges for small businesses compare to households?

Our exploration of this area has highlighted just how difficult it is to make a straightforward comparison, as there are so many different tariffs in the market. Not being able to get a clear understanding and compare prices represents a challenge for small businesses if they are looking at whether it is financially worth them engaging in the market.

We will continue to explore this area further in order to help customers.

We have not reached a conclusion on whether or not the average business customer is paying more than before market opening due to the complexity of tariffs. This is an area that we are continuing to explore. However, we strongly believe that switching activity remains a key metric as an accurate indicator for whether or not customers are taking part in and benefiting from an open market.

Our Testing the Waters tracking research, carried out every two years, asks questions about customer engagement in the market, including whether a customer has re-negotiated their contract with their retailer. This has allowed us to track this activity since market opening, but we could enhance this by working with others to obtain more accurate insight.

Through research, we are also proposing to examine the views of low water users to understand whether there is a difference in satisfaction between those who have, and have not engaged in the market.

Question 6. What about businesses such as churches that operate on a voluntary basis. Is there a benefit to them being in the market? Is this being looked at? Should further consideration be given to charities?

The review has not focused specifically on such businesses, but we do know from CCW complaints data that businesses of this type can be disproportionately impacted in terms of time and cost in trying to resolve an issue such as an inaccurate bill.

If further analysis identifies that these customers are receiving a particularly poor service, then we may need to make additional recommendations. However, a large number of charities are likely to be low water users, so they would be covered by our proposed eligibility change recommendation for customers using up to 0.5Ml of water a year.

Question 7: I agree with the recommendation to remove Temporary Business Supplies from the market. It was recently reviewed by Ofwat and they have decided not to remove. How will this recommendation change their view on this?

Question 8: During the recent Ofwat Eligibility guidance consultation in 2022 both MOSL and the RWG suggested removing TBS from the market but Ofwat decided to keep it in. How will CCW approach this with Ofwat?

It is clear from our analysis that Temporary Building Supplies (TBS) are not working in the market as a competitive activity and we are recommending that they should be removed through a change in legislation.

Based on our report findings, we will build a strong case to show the issues customers are experiencing, along with highlighting the shared drive for change.

It is clear there is cross industry support for TBS to be removed from the market (both CCW, MOSL, and retailers and wholesalers via the RWG), which needs to be presented to Ofwat and Defra as an evidenced unified position to bring about the necessary change.

While we focus on this change, in the interim, wholesalers need to take responsibility for flagging a water supply as a Temporary Building Supply. Our proposals highlight that the market should be agile and react where changes can be made quickly.

The rapid changes that were made during the Covid-19 period were a good demonstration of how the market is capable of rapid change when needed

Customers are being let down by administrative problems in the current TBS process. There are delays in flagging TBS in the market, leading to a lack of clarity regarding billing arrangements. It is, therefore, right that wholesalers are made responsible for this process while the premises is still a temporary supply in the competitive market. Improved processes are vital to ensure households do not incorrectly enter the water retail market, thereby avoiding the associated impacts on customer billing.

Question 10. Given the proposal to change the Code of Practice to have customers billed on a minimum of two actual reads per year, what is CCW’s view on the responsibility of meter reading?

We know from previous research into small business customers metering preferences that customers want frequent meter reads so they can be sure they are being billed accurately. It was also clear that the vast majority would not want this frequency reduced.

While retailers are responsible for reads, and should make every effort to read meters frequently, accepting customer reads is also valid. We also expect wholesalers to assist retailers with locating meters where this is hampering the provision of frequent meter readings being taken.

Our proposed requirement would not necessarily lead to cost increases for retailers. It is important to remember that for the majority of meters, retailers are already obliged to submit two meter readings a year to MOSL’s Central Market Operating System (CMOS). These reads can therefore be used for billing purposes.

In addition, our recommendation for increasing smart metering will ultimately improve the availability of actual meter reads in the long term and lead to cost reductions.

Question 11. Reducing long unread meters to 0; part of the issue is blockers. Wholesaler policies on accredited entities and not allowing others to install and bill. Does CCW agree that market requires more open competition/ leniency for meter installs?

As the network is wholesaler owned, careful consideration would need to be given on a practical level as to whether this would work effectively. However, the primary concern needs to be whether allowing more open competition in this space would lead to service standards improving for customers.

It is clear that a unified approach by retailers and wholesalers to resolve the problem of long unread meter has historically been lacking. More needs to be done to better incentivise collaboration between retailers and wholesalers in this area, and our report is very clear that this kind of collaboration is needed across a range of issues.

The key concern here is primary usage, which is why we have made our recommendation that the market eligibility guidance needs to be clearer, and interpreted more consistently by retailers and wholesalers.

We do not believe that all mixed-use premises should be removed from the market, but only those that have been correctly identified as predominantly household.

While there may always be some differing conclusions, a more robust eligibility guidance process should allow these assessments to become relatively straightforward and clearer for customers.

Through our involvement on industry working groups, we know this is an important area of focus in the market, and that efforts are being made to address this.

Our report is very much focused on what complaints and research are telling us, with vacant properties not featuring as an issue of importance for the majority of customers. However, we believe it’s fair that everyone should be paying for the water they use, and that by doing so, businesses may start to experience some potential benefits from being in the market.

Firstly, it is difficult to comment in full at this stage as we haven’t seen the full impact of the recent REC review in terms of implementation, and how this will impact retailers’ margins.

Secondly, we believe it’s in customers’ interests for retailers to diversify if doing so produces tangible benefits, so we would always encourage greater innovation where it is done well.