Consumer Complaints About Castle Management
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19/11/09
DRAFT
CONSUMER COUNCIL FOR WATER
WALES COMMITTEE
MINUTES OF THE SIXTEENTH MEETING AT
BRECON CASTLE HOTEL, BRECON ON
6th OCTOBER 2009
Present: Chair Ms Diane McCrea
Members Mrs Alison Warman
Mr Norman Thomas
Miss Clare Evans
Mr Wayne Rees
Mrs Nia Gittins
Mr Mansel Thomas
In attendance:
Policy Manager Miss Lia Moutselou
Consumer Relations Mrs Ceri Walsh
Manager
Assistant Consumer Mr Mark Hayward
Relations Manager
Representatives:
Dŵr Cymru Welsh
Water [DCWW]
Managing Director Mr Nigel Annett
Head of Performance & Mr Tim Masters
Customer Relations
Head of Customer Mr Peter Hrastelj
Relations
Customer Relations Mrs Deb Parfitt
Manager
Dee Valley Water
[DVW]
Managing Director Mr Bryn Bellis
Regulation Director Mr Norman Holladay
Environment Agency
Wales [EA] Wales
Strategic Environment Mr Bob Vaughan
Policy Manager
19/11/09
Drinking Water
Inspectorate [DWI]
Deputy Chief Inspector Mr Milo Purcell
Inspector, Regulation Mr Phil Smart
Ofwat
European Affairs Mr David Hackett
Manager
Welsh Assembly
Government
Water Policy Manager Ms Olwen Minney
Public Gallery:
National Assembly for
Wales
Research Officer Ms Victoria Paris
1 Welcome & Apologies
1.1 Apologies were received from:
Mr Paul Roberts (Wales Committee Member)
Mr Anthony Giblin (Scottish & Southern Energy)
Mr Andrew Dunn (Ofwat)
1.2 The Chair welcomed everyone to the meeting.
1.3 The Chair announced that Mr Bryn Bellis, M.D. of Dee Valley
Water will retire on 27th November 2009. His successor Mr
Norman Holladay, Regulation Director (also present at the
meeting) was welcomed to the meeting.
1.4 Mr Phil Smart, of the DWI was formally introduced as the new
Inspector with company liaison for Wales.
1.5 Mr David Hackett, representing Ofwat‟s European Affairs office
and liaison for Welsh Assembly Government was introduced.
1.6 The Chair was pleased to note the attendance of Miss Victoria
Paris, Research Officer, National Assembly for Wales.
2 Minutes of the Previous Meeting & Review of Action Points
2.1 Minutes of previous meeting (09 16 02)
There were amendments as follows:
19/11/09
2.2 Item 9.7 refers;
Should read: The EA acknowledged the committee’s concern and
explained the Habitats Directive is a European Directive that has
to be implemented….
2.3 Item 10.6 refers;
Clarification: The WAG recently held workshops on the transfer
of private sewers to DCWW.
2.4 Review of Action Points (09 16 02b)
Most Actions from previous meetings are discussed under agenda
items for this meeting. Various actions relate to the content of
companies‟ reports on complaints, operations and AMP4 activity.
Companies have made adjustments to their written reports where
appropriate. It was agreed that the content and structure of
future written reports will be discussed outside this meeting.
2.5 DCWW Mixed Use Disconnection Policy - (Item 15.2.5)
DCWW stopped mixed use disconnections on 9th July following
CCWater‟s intervention. At a meeting held on 30th September
(DCWW & CCWater) the company presented CCWater with its new
disconnections process. In addition, collection procedures and
implications of its change of practice were also discussed. This
Matter will be kept under review, especially the costs of
implementation on debt recovery.
Actions that remain open are:
2.6 Water Resource Management Plans (WRMP) – (Item 15.2.5)
The committee is still planning to meet DCWW and the EA to
discuss the company‟s revised draft Water Resource Management
Plan (WRMPs) in the new year.
2.7 EA Representation - (Item 15.9.1)
The EA confirmed that Ceri Davies will attend the next committee
meeting in public scheduled for January 2010.
3 Report of Activities and Key Issues
3.1 Update of Board Activities (Verbal) (09 16 03)
The Board‟s main focus continues to be on this year‟s Price
Review (PR09), and obtaining a fair deal for consumers in the
final determination due on 26th November 2009
3.2 The Board is currently consulting on the issue of competition, as
raised in the Cave review.
3.3 The CCWater Board is due to meet Anna Walker at its November
19/11/09
Board meeting prior to publication of the final report in
December „09.
3.4 CCWater Consultations (09 16 03a)
The Wales Policy Manager gave an overview of the list of
consultations that the committee has been engaged with. The
main focus of Committee work has been the PR09 process and
responding to Ofwat‟s Draft Determinations (DDs)
3.5 CCWater submitted its response to the Draft Flood and Water Bill
consultation on 24th July 2009.
http://www.ccwater.org.uk/upload/doc/CCWater_Draft_Floods_
Water_Manment_Bill_Resp_2_7_2009.doc
3.6 CCWater responded to Ofwat‟s DDs. The overview CCWater
response can be viewed at:
http://www.ccwater.org.uk/server.php?show=nav.1178
Follow the hyperlinks for the Annexed responses specific to DVW
and DCWW. The CCWater response was informed by customer
views research on Ofwat‟s proposals.
3.7 CCWater Wales recently submitted its response to the interim
Anna Walker report reviewing household charging (25/09/10):
http://www.ccwater.org.uk/upload/doc/Response_to_Walker_Re
view_%285%29.doc
3.8 CCWater Wales has submitted its response to the WAG‟s Climate
Change Strategy Plan.
http://www.ccwater.org.uk/upload/doc/WAG_Climate_change_s
trategy_prog_action_cons.doc
3.9 CCWater Wales has been in liaison with EA Wales about its
Corporate Strategy
3.10 CCWater‟s response to all consultations can be found on our
website. http://www.ccwater.org.uk/server.php?show=nav.775
3.11 Wales Committee members‟ activities (09 16 03b)
The main focus of Committee work has been PR09 and responding
to Ofwat‟s Draft Determinations. The response followed
communications and discussions with both water companies,
Wales stakeholders, EA, DWI etc.
Representatives of the Wales Committee discussed key concerns
with Ofwat on 18th September prior to submitting our formal
response to the DD.
3.12 The Wales Committee had the opportunity to meet with the
„Anna Walker‟ team in the initial and subsequent stages of the
19/11/09
review (Sept 2009). Although initially encouraged by the
meetings, the committee was disappointed that the review is
taking so long and has concern about implementing
recommendations in what might be the run in to a General
Election.
3.13 The Chair reported that the Water For Health Partnership in
Wales continues to make good progress on emergency planning,
communication and partnership engagement. There are ongoing
meetings and the Annual Conference is planned for Nov ‟09,
which she is attending.
Action: CCWater will meet the two water companies following LM, PH,
the publication of Ofwat’s Final Determinations to hear how BB
they are planning to deliver their priorities within the prices
set.
4 Review of Complaints – right first time
4.1 Consumer Council for Water, Wales (09 16 04a)
The complaint statistics for June to August 2009 were tabled. A
total of 334 contacts were received. These consisted of 226
complaints and 108 enquiries against the Welsh companies. The
Wales office dealt with a further 70 complaints as part of the
case transfer between offices across the English regions.
4.2 CCWater recently published its comparative table of complaints it
had received against all the water companies. CCWater Wales
was disappointed at the increasing trend of complaints received
against the Welsh companies on average - unlike the English
regions where complaint numbers are now falling, on average .
4.3 The CRM announced that she had recently agreed with DCWW to
trial complaint referrals by telephone. It is felt there will be
much benefit to all, especially a faster resolution time for
customers.
4.4 The CRM referred to the type of complaints received in the Wales
office. Measured billing disputes continue to remain the highest
complaint category – and throughout the industry. A workshop
will be held in CCWater Birmingham in January with companies in
attendance to investigate and review reasons behind this trend.
4.5 The CRM gave an overview of case studies the Wales office has
handled in the last quarter. She spoke briefly about the
impending changes to the OPA and Ofwat‟s new SIM (Service
Incentive Mechanism), giving stronger weighting to investigated
complaints. This change will be monitored and reported back to
the Committee (debt & complaints).
19/11/09
4.6 The Assistant CRM presented the committee with GIS maps for
each of the Wales companies, as requested at the last meeting.
There was much discussion about their purpose, the datasets
used, and how they might be used.
Action: CCWater to discuss improvements to the complaints CW
tracking and reporting system with other Consumer Relations
Managers (CRM) with the aim of identifying why complaints are
increasing with the possibility of adding a secondary cause
code
4.7 The Chair ended this item by referring to the recent CCWater
Press release and reinforced the need for the Welsh companies to
resolve complaints Right First Time.
4.8 The Chair also recognised Dee Valley Water‟s that „one stage
complaint procedure‟ (all correspondence being addressed by the
M.D) delivers resolution of complaints (right first time) and is
good practice in the industry. On the contrary, DCWW‟s
complaint procedure lacked consistency at the first stage. Where
there is evidence of some cases being responded to several times
at stage 1 before being escalated.
4.9 DCWW announced that it has made significant changes (in-house)
to the escalation process and the Committee will see an
improvement next year. This needs careful monitoring.
4.10 Dee Valley Water Complaint Statistics (09 16 04b)
The company gave an overview of its complaint statistics. The
company has seen a 37% increase of charging and billing
complaints compared to the same period last year.
4.11 DVW also prepared information for the meeting about the number
of new applications received for its Watersure Tariff (formerly
Vulnerable Group tariff) and the Additional Services Register.
The Committee thanked the company for sharing the information.
It was noted that the take up of schemes is lower than the
average for England and Wales.
4.12 The Committee asked whether DVW advertises such schemes.
DVW confirmed it doesn‟t proactively advertise the scheme.
However, the company confirmed that details of the scheme are
enclosed within customers‟ bills [DCWW responded the same].
4.13 The Committee raised concern about the increase in complaint
numbers and asked DVW its understanding for the reason behind
the increase. The M.D. explained that it has recently tweaked its
systems to include more robust reporting particularly with regard
to multiple contacts arising from operational incidents; but that
once again the economic downturn is thought to be a major
19/11/09
factor behind customers‟ reason to complain about bills.
4.14 There was further discussion between each of the companies, and
stakeholders about the reported trend of increased complaints in
Wales, the classification of a complaint; and possible future
weighting of complaints for the SIM. However it was agreed that
Ofwat had spent considerable time consulting on this issue and
the definition is clear. CCWater confirmed it uses the same
definitions.
4.15 DCWW Complaint Statistics (09 16 04c)
The main categories where there have been more complaints in
the last quarter all relate to billing, disputed bills and charging
policies.
4.16 The company has also reviewed the reason behind customer
complaints and the difficulty managing customer expectation. As
a result it has made major changes in key areas of the business.
4.17 As a commitment to resolve complaints Right First Time, DCWW
set up a „Small Issue Resolution Team‟ on 5th October 2009. The
team will shadow the call centre and deal with issues that remain
unresolved at first point of contact. The Committee was
encouraged by this initiative.
Action: DCWW to monitor and report on the progress of the DP
newly established intervention team whose role is to follow up
unresolved calls.
4.18 The company has made additional changes to its billing &
charging system to review the way customer payment plans are
calculated, allowing greater flexibility for customers to pay.
4.19 DCWW‟s written correspondence teams have received refresher
training which will see an improvement in grammar, and more
importantly resolution skills. It is hoped this will reduce the
number of repeat complaints from consumers about inadequate
and repeat replies.
4.20 DCWW highlighted a reduction in the number of written
complaints it received for sewer flooding. The company now
proactively telephone customers after attending the clean up,
subsequently complaints about this side of the business have
significantly reduced.
4.21 The Committee asked DCWW to consider what GIS information
they could add to their reports.
Action: DCWW will provide GIS maps for water quality PH
19/11/09
complaints
4.22 The committee raised concern at the trend of increasing
complaint numbers (per 10,000 connections) for DCWW. This
concern was shared by the DWI, particularly in relation to
complaints received on water quality issues. The committee
challenged both companies to improve their position in the
industry‟s comparative tables on complaints.
Action: Companies to add a written report on the uptake of PH, BB
Welsh Assist/Water Sure, Additional Services Register and
Customer Assistance Fund on a quarterly basis, in either their
complaints or operational report provided for each meeting.
05 AMP4 Update – Water Companies
5.1 DCWW progress report on investment programme
(09 16 05a)
The company has completed work at five of its Water Treatment
Works (WTW‟s), and the sixth, Talybont will be opening on 30 th
October 2009. All stakeholders have received formal invitations
to the official opening of the plant.
5.2 A query was raised by a committee member about the number of
plants (17) that had been equipped with U.V. and the company‟s
plans to install U.V at a further 8 WTW.
5.3 DCWW acknowledged the increased detriment that U.V causes the
environment (carbon emissions), but reminded the Committee
this had to be carefully balanced against the risk of
cryptosporidium getting into the public water supply and public
health consequences. However, the company confirmed it has no
further plans to install U.V.
5.4 The DWI also commented on the „risks‟ to public health. And,
although it didn‟t previously agree with the company‟s
precautionary approach to install U.V. at its plants - citing its
costs as a major argument. The DWI is satisfied the company now
has a better understanding of cryptosporidium, and welcomes its
risk-based approach.
5.5 The company reported that it has reduced investment assigned
for its Section 19 mains renewal programme. However, it has
already delivered 1,720km of refurbished mains to date with a
further 70km planned by March 2010.
This will complete an investment plan of £229k for mains
refurbishment/renewal and should resolve and reduce complaints
about discoloured water. CCWater commended DCWW on the
completion of this investment programme to secure better
19/11/09
service delivery for customers.
5.6 DVW progress report on investment programme
(09 16 05b)
The company reported that it is on target to achieve all planned
outputs for its AMP4 programme.
6 Operational Reports from Water Companies
6.1 DCWW key issues (09 16 06a)
There are currently no concerns on the availability of water
resources for DCWW.
6.2 There was some discussion about the number of microbiological
failures DCWW had experienced in its operating area.
6.3 The DWI took opportunity to explain that there is no standard for
Cryptosporidium specified in water quality regulatory regime.
Therefore the companies have to report all incidents where
oocysts are detected regardless of whether they are active or
not. Incidents are reported for treated rather than raw water.
6.4 The DWI has carried out audits at four of DCWW Water Treatment
Works (WTW) and findings indicated deficiencies with several
aspects of the WTW process management. Further enforcement
action is being considered by the Inspectorate.
Action: DCWW to share their report in response to the DWI’s
findings on its service level failures with the Wales Committee.
6.5 DVW key issues (09 16 06B)
DVW reported that it is on target to improve on all of last year‟s
measures. Water integrity is likely to be at the same level as last
year.
6.6 DVW currently has no concerns about the availability of water
resources.
7 Private Sewers Transfer (09 16 07)
7.1 Update
The Committee asked for a verbal update from DCWW and the
WAG on the impending transfer of Private Sewers in 2011. Private
sewer transfer has not previously been discussed at a Wales
committee meeting but is now an important issue that will impact
on consumers in the near future.
7.2 The Committee was keen to understand the detail, timeframe,
and process of the forthcoming transfer, as well as the
consultation that will lead to it. The Committee is also interested
to know how WAG and DCWW are planning to prepare for this
19/11/09
transfer, as well as how communication to consumers will take
place.
7.3 CCWater supports overnight private sewer transfer as the best
solution for consumers. Yet, is concerned about the costs of the
transfer and the additional burden on all consumers.
Communication of the particulars and processes of the transfer
must be clearly communicated to consumers. It is important that
WAG and DEFRA plan this carefully.
CCWater also want DCWW to consider the best plan of
communication to both sets of consumers. For those with private
sewers the key questions that need to be addressed are a) what
the transfer will mean for consumers and b) will a prices increase
be needed to fund this transfer and what it is likely to be.
7.4 WAG responded that Defra is committed to a transfer of assets
commencing April 2011 but the Welsh Assembly was concerned
this date may be untenable for Wales. The forthcoming
consultation is likely to be launched mid December 2009. This will
be accompanied by an impact assessment and is likely to be
followed by workshops.
7.5 There is still much discussion between the WAG and DCWW about
the assets subject to the transfer, the difference between the
Local Authorities in England and Wales, and the cost implications
the impeding transfer will have on Welsh consumers. Not much
progress has been made on the preparation and identification of
assets.
7.6 A meeting is scheduled to take place between DCWW and the
WAG on 23rd October 2009 to discuss this issue further. CCWater
will be kept up to date (watching brief).
7.7 The WAG further explained that they have less resources
available than their counterparts in Defra to deal with the issue.
The WAG reassured the Committee and stakeholders that there
will be an opportunity for further consultation before March 2011.
Action: WAG to provide details of two previous consultations OM
that lead up to the decision to transfer private sewers in 2011.
Action: CCWater to keep a watching brief and be consulted on LM, OM,
developments relating to the private sewer transfer policy, PH
and especially to be actively engaged when preparing messages
for consumers.
19/11/09
8 Drinking Water Quality update on key water quality issues in Wales
(09 16 08)
8.1 The new inspector for Wales, Phil Smart, presented the DWI
report.
8.2 There have been a total number of 16 notifiable events reported
in the period June to August. Almost half of these were classified
as serious events (Category 3 or above). This brings up the total
number of incidents classified as serious for this year to 16.
8.3 Two DCWW incidents at Mynydd Llandegai WTW (Aug 08) and an
incident at Alwen WTW (Apr 09) resulted in boil notices being
issued to customers.
8.4 There have been 24 failures of water quality compliance this
period, bringing the total number to 49 breaches of water quality
to date.
8.5 The DWI has not received any consumer complaints during period
between the two CCWater Wales committee meetings in public.
8.6 A Committee member raised concern about the 233 positive
cryptosporidium detections YTD and the risk to public health.
8.7 DCWW asked the committee to note it reported 219 positive
detections of cryptosporidium to the DWI. All detections refer to
treated rather than raw water. It reminded the Committee that
these incidents could be broken down into a further three sub
categories, depending on the severity of the contamination:
treatment work should have removed the oocysts but
occasionally one remains
UV treatment in place but inactive oocysts can be detected
in treated water
no means of cryptosporidium treatment or oocyst removal
at the works is available and oocysts were detected
Action: DWI to distinguish between the severity of PS
cryptosporidium notifications in their report and at future
meetings (on the basis of the three categories of severity
provided by DCWW)
9 EA Wales update on key issues in Wales (09 16 09)
9.1 River Basin Management Plans
The six-month public consultation on the draft River Basin
Management Plans (dRBMP), and the accompanying draft
Strategic Environmental Assessments and Impact Assessments
closed on 22nd June 2009.
19/11/09
The first River Basin Management Plans (RBMPs) were submitted
to Welsh Assembly Government and Defra on 22nd September
2009. These are available on the EA‟s website.
9.2 Bathing Water Quality
2009 Bathing Season Summary, 30/09/09
The Bathing Water Season has now ended and the EA is assessing
what appears to be quite encouraging results for the Bathing
Water Quality around Wales. The EA is encouraged by this
considering a poor summer that follows two wet summers which
led to poor water quality. This year‟s results will be announced
by WAG at the end of October.
9.3 Water Framework Directive
The EA received a good response to the consultation, with a wide
range of organisations giving their commitment. This has helped
organisations, such as the Forestry Commission Wales, focus on
how their activities impact on the water environment, and how
they can commit to more. Because WFD is cross cutting it has
enabled broader strategic thinking. This has helped EA/WAG and
others to build WFD priorities into their day job, and business as
usual for funding many activities.
http://www.environment-
agency.gov.uk/research/planning/33106.aspx
9.4 Habitats Directive
The actions from the previous meeting asked the EA to “…confirm
Habitats Directive Site Plans and limitations on abstractions (as
well as projected cost of these limitations)”. The previous
publication of the results of the Review of Consents was met with
considerable concern due to the impact on water supplies. This
was particularly so for the abstractions on the Rivers Wye & Usk,
and also on the Cleddau. The EA has listened to concerns and has
undertaken a detailed review of the investigations. This is
progressing and will be released in the Spring of 2010.
10 Welsh Assembly Government Update(09 16 10)
10.1 WAG confirmed the reappointment of Diane McCrea, Board
Member and as Chair of CCWater Wales committee for the next 4
years. An official press release will follow.
10.3 Walker Review
The final report is now to be published in December ‟09, and
consultation will follow.
10.4 Floods & Water Management Bill
Surface Water Management (once a part of the Walker Review)
will be transferred into the Floods and Water Bill. This is on the
19/11/09
recommendation of the Secretary of State for Wales. Olwen
Minney informed everyone that she has now taken on work on the
Bill for WAG.
10.5 Wales Water Forum
WAG will be setting up a Water Forum, following on from the
PR09 forum. There is much support from DCWW on this.
CCWater will be actively engaged on behalf of consumers.
10.6 WAG‟s main area of focus is the affordability issue in Wales and
protecting vulnerable groups.
10.7 Cave Review
The Minister jointly published the Cave Review consultation on
competition jointly with DEFRA on 17th September (the
consultation period closes 19th December ‟09). In the process of
publishing the Caver review consultation, WAG had regular liaison
with all stakeholders.
Action: WAG to provide written update report at the next OM
meeting
11 AOB
11.1 The Chair thanked everyone for their attendance and
participation, and for timely submission of papers for the
meeting.
11.2 The Chair wished Bryn Bellis M.D. of Dee Valley Water a happy
retirement on behalf of the Wales Committee and staff. Diane
thanked Bryn for his participation in CCWater meetings in public
as well as involvement and contribution to CCWater work since it
was set up. The Committee look forward to working with his
successor, Mr Norman Holladay.
11.3 Next meeting to be held on 26th January 2010, Aberystwyth.
12 Signed by Chair, Diane McCrea as a true and accurate record:
………………………………………………………………………
Date: ………………………………………………………….
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