Submission to on proposed pricing structure for domestic water

In Blog by Denis Naughten

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Unmetered Tariff
I believe that the structure of any unmetered tariff, should 1) reflect in so far is feasible, the water consumption of households of similar make up that are on a metered charge and 2) provide an option of having a meter installed, if the household believes that the unmetered tariff unfairly reflects actual water usage

Transition Period


The transition period from unmetered to metered charging should be a minimum of 12 months from the receipt of the first bill.


As you are aware Irish Water has proposed that there should be a transition period for metered customers during which bills will be capped at the appropriate assessed tariff level. This would allow customers with higher than average consumption time to adjust their consumption or fix leaks.

Irish Water has suggested a 6-12 month transitional period from the beginning of the first billing period after meter installation. This in reality could mean that a person may have as little as 3 months until the end of March 2015 to have all leaks resolved. This is far too short a time period, and even fails to take into account the potential for adverse weather conditions in the first quarter of the year.

The reality is for many households, they will not know the impact of their consumption until they receive their first water bill. It will take until their third water bill to see the full impact of any consumption changes or repairs that have been performed. It will only be at that stage that they can fully iron out any discrepancies once and for all, be it consumption changes or checks to see if repairs have been completed satisfactorily, or caused further damage elsewhere on the domestic side of the network.


So it is only when the household receives a fourth water bill that they will have an accurate reflection of their actual consumption and households will then have to use this data to reconfigure their household budget.


Therefore, at a minimum it should be the fifth bill, at the earliest, which should reflect the true consumption of the household, and not one at any earlier stage.

Water Supply Issues

a) Quality issues

1. Contaminated or potentially contaminated water impacting upon public health (boil water notice) I would disagree vehemently with Irish Water’s contention that there should be a 15% discount for supplying contaminated water, particularly for extended periods of time.
Clearly, there is a lack of understanding by Irish Water of the actual impact of supplying contaminated water.


Firstly Irish Water claims that water for all other domestic water use, whether for laundry, showering etc., is safe to use without boiling. But this is not the case for the whole population. The level of allergies within the population has increased dramatically in recent years and issues such as laundry or showering for such consumers can be directly impacted upon by either the contaminant or any measures used to militate against the contamination.


But it is not just that, for example if the water is contaminated it is not possible to 100% ensure that a small child will not consume some of the water during bathing etc.


Therefore, based on the WS Atkins Ireland projection that 26.7% of consumption can be attributed to toilet flushing and gardening then these are the only uses which do not impact on the total population placed under a boil water notice, due to contamination, not 15% as suggested by Irish Water.


Secondly, it must also be noted that there are significant additional costs associated with the boil water notice e.g. consumers must either spend more money boiling the water and cooling it or purchase bottled water, and this is on top on the inconvenience caused.


Furthermore, there is often accidental consumption of such contaminated waters causing illness where, for example, consumers, particularly children, inadvertently use the contaminated water for teeth brushing. This can at the very least lead to loss of a day’s work (either through illness or providing care), sometimes an A&E attendance fee and even the possibility of a hospital admission


Therefore if water is not fit for human consumption a charge should not apply until the problem is addressed. Not only does this acknowledge the significant impact of a boil water notice on a family but it also ensures that addressing the problem will be a priority for Irish Water.


Presently, the Local Authorities/Irish Water do not consider a boil water notice as a priority for a temporary treatment solution where it is estimated that the notice will be in place for an anything under a 12 month period. In practical terms this can leave communities with contaminated water for periods in excess of 18 months. This is not acceptable.


2. Other quality issues, other than a boil water notice


There are instances where a water supply does not conform to EU standards and in such instances a model along the lines of the Irish Water suggested tariff discount, should apply, depending upon the actual impact which this has on water usage.


3. Hard water


Presently, water hardness does not form part of the EU drinking water standards and in practical terms the cost of its removal on a large scale is prohibitive. However, in light of the fact that a large number of supplies have significant hard water problems, the regulator should incentivise Irish Water to explore alternative, cost-effective treatment processes to address this problem.


b) Quantity
In its submission Irish Water has dismissed quantity issues such as water pressure, because of the indirect water system in Irish homes. However, the fact is that water storage in homes does not meet the totality of the needs of a family and supply issues can directly impact upon the operation of many household appliances; be it the efficient use of such appliances or the reduction in the life of such appliances.


I would also presume that, as a regulator, CER will set a standard for minimum levels of supply and provide Irish Water with a window within which to achieve that target. Of course if this is not achieved, a penalty will then apply.


But what about those households today, who cannot function in a similar manner to other homes because of a grossly inadequate supply? When will they get some relief for their ongoing problem?


It should also be noted that for those who are unwilling to pay for water, it is envisaged that they will have their supply reduced.


So some consumers who are getting water for nothing will have a reduced supply, while others who are willing to pay may even have a poorer supply. How can this be seen as equitable?


Therefore, I would propose that where the water pressure is impacting on the operation of domestic appliances, then a discount similar to a.2. above should apply.