CCW’s response to DEFRA’s consultation on the Guaranteed Standards Scheme

We support the proposed payment levels for these standards.

The time period proposed for when a payment should be made, if a company has not read a customers’ meter, is too long.

CCW had recommended this be 13 months rather than two years as recommended by Defra. We still believe the payment should be due after 13 months.

Most companies already strive to apply a true meter reading at least once per year. In our company working group discussions concern was raised was about the fact that two billing periods (approximately 6 months), can together, be slightly over 12 months, therefore our recommendation was for 13 months to allow for this. We believe that 13 months is achievable for water companies, subject to reasonable caveats about access to meters and the nature of readings (ie: customer provided readings would be acceptable in the absence of a company reading).

CCW’s complaints report for 2023 shows that billing had the highest amount of complaints, and disputing the volume of water used was highest within the billing category.

We recognise that Ofwat guidance stipulates an accurate meter reading should be completed once every two years by companies, but with a reading taken every year, which could be done by the customer. Our recommendation for meter reading to be completed by companies at least every 13 months places an onus on companies to step in and complete a reading within a 13 month period where the customer cannot.

Long periods of estimated bills can lead to customer inconvenience and sometimes distress through the potential build-up of significant credit or arrears on their water bill accounts. This will also safeguard customers who are unable to complete their own readings for reasons relating to vulnerability such as mobility issues.

There are other benefit to more regular meter readings which can detect leakage sooner, benefiting customers from bill shocks caused by leakage.

The recommendation builds on CCW’s proposal by recommending that the payment be backdated to days one and two once the notice period reaches day three.

This delivers added benefit to those experiencing events lasting more than two days. However, those experiencing an event for up to two days may feel disadvantaged that compensation is paid for those initial days but only for those experiencing longer incidents.

Summary of the consultation questions: