Our response to Ofwat’s consultation on PSR Standards

We consider that you have taken on board insight and feedback from a wide range of sources.

If compensation for non-provision of PSR services does not ultimately get included in the revised GSS Standards, we would want to see it included as a PSR Standard.

To avoid reliance on data sharing alone to increase reach, we want to see a requirement for awareness levels to increase and for this to be monitored. Our review of water companies’ draft vulnerability strategies revealed that some companies, but not all, have a target to increase awareness but these targets vary from 45% awareness to 80% awareness. Having a standard for awareness would bring consistency across the sector whilst still allowing for companies to be innovative in this area. Companies should also use their demographic data to target awareness to groups of people who are likely to benefit from the extra help that PSR can provide.

It is also important that people feel that the support they receive is meaningful so we want to see a requirement for satisfaction with services research to be conducted and monitored.

Yes, in the absence of there not being a specific licence requirement for water and wastewater companies to have a PSR, we are pleased to see that the PSR Standards include an explicit note that Ofwat expects companies to have one.

Whilst we do not consider Priority Service Register to be the best terminology we accept that changing it at the present time could be disproportionately disruptive given the cross-industry focus on developing a single priority services hub. We would welcome the terminology being reviewed at a later date and across all relevant sectors.

Insight from our discussions with stakeholders, including Scope and Royal Association for Deaf People, revealed that they want companies to offer support that takes into account the individual’s needs. They were wary that a core list could result in an unexpected outcome of companies being prescriptive/restricted in offering support. We feel that the approach that Ofwat has taken meets this preference, however for some key areas there should be more detail on what is expected as a minimum service delivery such as supply interruptions – minimum water delivery times based on priority of needs e.g. Priority level one customers – water delivered within x hours unless customer confirms it is not required. If the provision of PSR Services is included in the revised GSS standard, this clarity would be needed either in the revised GSS standard or the PSR Standard as such it would be useful for Ofwat and Defra to agree the approach for this.

As the list of needs is non–exhaustive, we agree that the list set out covers the majority of needs that may benefit from extra support.

There are many services which have been omitted that water and wastewater companies currently offer. We would like it to be explicit that Ofwat would not expect the current offerings to reduce. It is our intention to continue to review the range of extra support that all water companies offer, share good practice within the sector and encourage all water companies to adopt this good practice.

Although Ofwat states that the list is non-exhaustive, we’d like to see a specific mention of British Sign Language (BSL) interpreter services as our last review of the services that water and wastewater companies offered found that support for people with a hearing condition was not widely adopted.

If provision of PSR services is included in GSS, we would want the core services this consultation outlines to be robust enough to allow Defra to use as the basis for the GSS measure.

In our discussions with stakeholders including Scope and Royal Association for Deaf People they were clear that support should be tailored to the individual’s needs and that having as comprehensive a picture as possible of those needs is crucial to ensure that meaningful support is delivered.

Companies should strive towards understanding potential PSR service requirements as well as actual PSR service requirements. Effective partnership working and demographic analysis are ways to achieve this. We have seen varying levels of partnership working and demographical analysis in water companies’ draft vulnerability strategies therefore we want all water companies to strive to be
exemplary in these areas.

It is useful to have a goal for water and wastewater companies to work to and has been successful during the PR19 period. As such, we agree that there should be a future target for companies to work towards.

The methodology is pragmatic, the data is robust. However, any estimate should sit alongside an understanding that eligibility does not necessarily result in signing up for the register. Some people may already have a good support network in place whilst for others inclusive design innovations in areas such as technology means that they are able to access services without needing additional support.

It is also essential that any proposed target based on the eligibility estimate does not inadvertently drive inappropriate enrolment tactics such as focussing on enrolment based on age eligibility criteria alone.

The rationale for not expecting new appointees to meet Ofwat’s eligibility estimate for incumbent water companies is pragmatic however there should be some estimate for reach set. A starting point could be the 10% target set for water companies for the PR19 price period.

Yes. It is vital that any data on consumers that companies hold is accurate.  Therefore data should be checked on a frequent basis to ensure that expectation is met. We consider the proposal to retain the current expectations is pragmatic.

We agree that people should be well informed about the extra support they can expect to receive from their water company. As well as how they can amend their details should their requirements change.

There should be more clarity on timescales for registration, currently it is proposed companies add people on “as soon as possible”. This is too open to interpretation so we would like to see a minimum requirement of “within 30 days as a minimum”.

We agree with the following monitoring proposals:

• Companies continuing to report on PSR reach, attempted contact and actual contact
• Companies reporting on progress against their vulnerability strategy commitments and targets
• Qualitative insight including from CCW and other stakeholders, water companies and research particularly around the satisfaction with services and awareness of services.

We are pleased to see that the PSR standards will be kept under review allowing flexibility.

In terms of implementation, should PSR services provision ultimately get included in the revised GSS Standards we would also like to see:

• Compensation – we expect the company to adhere to the GSS standards
  regarding PSR services provision.