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
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                         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:
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    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
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           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
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           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).
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    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
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           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
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           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
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           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
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           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.
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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.
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           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
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           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:




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     Date: ………………………………………………………….
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