WaterSure Call for Input Responses

One respondent, Scope, called for the scheme to be opened up to customers who do not pay charges based on metered usage. They did so on the basis that this would enable more disabled people to be supported.

Other respondents argued that the scheme should remain limited to metered customers. It was noted that the purpose of WaterSure should be to protect low-income, high use, households with a meter from unavoidably high water bills. And that other social tariff schemes are aimed at supporting financially vulnerable households, more generally.

United Utilities highlighted that its scheme also supports households paying an assessed volumetric charge (AVC), where it has not been possible to fit a meter at the customer’s property. It recommends this expectation being added to the WaterSure scheme and applied where the capped WaterSure bill is lower than the AVC charge.

Means Testing

Just one respondent advocated that all means testing should be removed from the scheme. Other respondents noted that this would result in some high-income families being supported by households that are just about managing. Another observation was that given charges are capped removing means testing could significantly expand the number of households that have little or no incentive to reduce their consumption.

Yorkshire Water suggested that means testing requirements might be lifted under circumstances relating to short-term need or terminal illness.

Income Threshold

On the option of replacing benefit entitlement with an income threshold, two respondents voiced support for this. This was on the basis that it would extend eligibility to additional households who just miss out on means-tested benefits but still struggle with their bills.

Those opposing this option highlighted that the change would impact those currently supported, creating “winners and losers”, and that there might be significant overlap with social tariff schemes which use income as a qualifying criteria. Some companies mentioned the administrative advantages of using benefits as a qualifying criteria, given the data-sharing arrangements that they have in place with the Department of Work and Pensions.

However several respondents proposed that an income threshold might be added as an alternative qualifying criteria for WaterSure, alongside income related benefits. It was felt that this would make the scheme more inclusive, but would require additional cross-subsidy. It was also noted that it would increase the administrative complexity and costs of operating the scheme.

A further suggestion was for eligibility to be expanded to those with a ‘Financial Difficulty’ credit rating or a deficit budget highlighted within a Standard Financial Statement.

Non-means tested disability benefits

There was strong support for the list of qualifying benefits being expanded to include non-means tested disability benefits. It was felt this could help ensure that people with the extra costs of a disability will be able to obtain support with their high water bills. Their disability benefits will generally be used in extra care costs and other expenses related to their disability or condition.

Those opposing this change noted that non-means tested benefits, such as PIP, DLA and attendance allowance, are designed to help customers with their additional expenses, including water bills. And that it is the government’s responsibility, not that of water companies, to address any gaps in welfare support. Another point raised was that state benefits are funded though taxes that increase the more you earn, whereas any cross-subsidy funded by water customers would not share the same link to income.

Some respondents supported the inclusion of disability benefits as a qualifying criteria being subject to an upper income threshold. It was felt that this would moderate the scale of those brought into eligibility and help minimise cross subsidies flowing from lower to higher income households. Others noted that this would add administrative complexity and cost.

Additional Suggestions

One respondent suggested that Council Tax Reduction might be added as a qualifying criteria on the basis that those eligible are on a low income but could be above the threshold for Guaranteed Pension Credit. Therefore it could be a way of capturing those who are just above the threshold for Pension Credit.

One respondent called for households to be eligible where the person receiving benefits is not the named bill payer. However this is already the case with the existing WaterSure scheme.

Increase or reduce the number of children needed to qualify

There was strong opposition from respondents to this criteria being changed. It was observed that an increase in the number would disadvantage some existing recipients and a reduction in the number could increase the level of cross-subsidy required from other customers. It was also noted that WaterSure exists to protect from high water bills due to large family size, whilst a family with two children is closer to the average.

The Money Advice Trust argued that the eligibility should be reduced to two children. This was on the basis that some of these families would still not qualify for the scheme due to their water usage being below the average eligible for help, and so this change will only help those most in need of support.

Extending support to larger multigenerational households

A few respondents felt this might be an option which could be taken forward. It was argued that it is important WaterSure covers all larger households living on low incomes who are struggling with their water bills. And that this might be particularly fair where the higher water usage is due to the older family member’s medical condition. It was noted that intergenerational households may have higher levels of household income and that the means tested qualifying criteria might need to differ for such households to qualify.

Those actively opposing this extension of the scheme cited the higher income levels of such households as a reason that they should not qualify. It was stated that expanding the scheme to cover all multigenerational households, regardless of their specific circumstances, could significantly increase the number of beneficiaries and strain the scheme’s resources

Additional Suggestions

Yorkshire Water and Portsmouth Water both suggested that the qualifying age of ‘children’ under the scheme might be increased from 19 to 21 years to cover the circumstances where children are still in education (or low/no earning training roles) and continue to live in their family households.

Northumbrian Water said it would be supportive of the 3 child criteria being extended to include foster children, as they are currently excluded as the foster parent may not be receiving child benefit.

United Utilities suggested that further consideration should be given to the question of how best to calculate household occupancy where children split their time between multiple households, for example, in joint custody cases

The company also questioned whether a ‘fair usage’ clause should be applied to households qualifying under the large family criteria. This would set an expected maximum usage per occupant level. To maintain adequate incentives for water efficiency claimants would lose eligibility for the scheme where usage exceeds the threshold.

There is a strong consensus that it would be helpful to signal the universal nature of qualifying medical criteria more clearly. Some respondents felt this would be best achieved by fully replacing the list of named examples of conditions, which might require additional water use, with a clear description – to avoid giving an impression only those conditions are covered.

Others felt the list should be retained, and possibly extended, to help people identify their eligibility whilst also accompanying this with a strong statement around the universality of the scheme.

It was suggested that customers, including older people on low incomes with high water usage, should be engaged as part of the process of identifying an improved approach to communicating eligibility.

One respondent called for eligibility to be extended to cover those with medical conditions living in properties where they are not the bill payer. However this is already the case under the current scheme.

Change the cap to the company average metered bill level

There was strong support for the bill cap applied by companies being their average metered bill level, rather than their overall average bill level. It was noted that this seems logical since the claimant must be metered in the first place. Several companies confirmed that they already follow this approach, currently funding the difference in costs themselves.

It was pointed out that the arithmetic average “metered” bill includes subsidised tariffs – i.e. customers on social tariffs and WaterSure itself. A fairer measure could be the average metered bill for a customer on regular charges – i.e. the metered bill of a customer with average consumption.

Two respondents did not favour this change. One highlighted the added complexity of regionally different bill cap levels for NAVs (New Appointments and Variations) providing services across different operating areas.  The other advocated for the existing overall average bill cap being retained on the basis that it provides for a balanced level of support that is both fair and sustainable.

Change the cap to the lowest of the local metered bill level or industry average metered bill level

There was some backing for this approach from third sector organisations, who welcomed that it might be significant in improving the support to struggling households in regions where water bills are higher.

However water companies pointed to issues with the practicality of this option. Companies do not know what other companies’ average measured bills are until they have published them. To ensure compliance with revenue controls they need to know what the WaterSure rate will be before charges are approved by their Boards. So this might only work if companies were to agree an estimated national average bill ahead of annual charges being finalised.

There was also concern that the level of cross subsidy could vary considerably across the sector, with customers of companies with higher than average bills having to subsidise more.

Replace the cap with a percentage of fixed amount discount

On the whole respondents did not support these alternative approaches. A key concern included the impact which a change of this nature would have on existing claimants, some of whom could see the value of the support they receive reduced.

It was also noted that some medical conditions can require more water use than others, so these approaches would lead to differing beneficial positions across the range of customer circumstances. It could mean that some customers with higher consumption could still face high bills, and feel incentivised to reduce their water use when they are unable to do so.

The increased variability in bills was also a concern, as certainty in such matters is particularly helpful to low-income households managing on tight budgets who have a requirement for high water usage.

Some also felt that the change would be confusing for customers and difficult for companies to administer.

Those in favour of this option being explored pointed to the fact that moving to a percentage or fixed amount discount would preserve water efficiency incentives for customers on the tariff and highlighted the UK Government’s 2038 target of reducing water consumption to 110 l/p/d.

It was also suggested that this approach might be fairer, including more households given there would no longer be a break-even point on their existing bill compared to the current fixed charge approach.  It was also suggested that this might be addressed by given eligible households a choice between a bill cap and a discount.

Introduce a Single Occupier bill cap

The addition of a single occupier bill cap received some positive support.

Several respondents felt that this would be a really helpful way to reach those with high medical water usage needs that are currently missing out on support. It was noted that this would enhance the support provided by WaterSure without significantly increasing the required level of cross-subsidy.

There were mixed views on whether this change would add significant administrative complexity and cost.

Several organisations called for further exploration into the impact of implementing the change in terms of likely cross subsidy and the opportunities to obtain data from DWP and Councils to validate claims and auto enrol customers.

Status of the Scheme in Wales

One respondent commented on the status of WaterSure in Wales. They supported WaterSure being made statutory in Wales, on the basis that this would make the regulatory landscape clearer.

Raising Awareness

Several organisations were keen to ensure steps are taken to raise awareness of WaterSure and for water companies, CCW and others to work together to take greater advantage of the opportunities that an industry-wide scheme brings in terms of national promotion and consistent messaging.

It was felt further action is needed to proactively increase awareness among disabled customers of the extra help available to them. It was noted that this should not be solely online, as some of those eligible for help are often more likely to be digitally excluded.

Applying for Support

There were also calls for emphasis to be given to the importance of application methods to the scheme being available through both online and offline means, and being accessible to all applicants. This should include giving clear visibility to contact telephone numbers.

It was suggested that all customer service staff should have disability awareness training including the disability social model, so that they understand the barriers and challenges that disabled people face. Discussions with customers should be based on needs instead of conditions

There was also a call for all companies to have a direct access telephone line, for third party service support organisations contacting on behalf of their clients.

Access to Additional Help

Some respondents felt that those identified as eligible for WaterSure should be automatically registered on the Priority Services Register, or provided with bottled water in an emergency.

Funding Enhancements to the Scheme

A common theme in responses was the need to recognise the potential for changes to the scheme to increase the cost of operating it and associated cross subsidy applied to other customer bills. And for an appropriate balance to be struck in this regard.

However it was also observed that even a doubling of costs (around £2-3 per on annual bills) would have minimal impact on other customers. A respondent also called for companies to fund some of the support rather than relying on cross subsidies from other customers.

Future Social Tariff Support

A number of respondents called for the review of WaterSure to be accompanied by a wider review of future social tariff support. It was noted that any consideration of sweeping changes in the WaterSure scheme should only be made in conjunction with the real prospect for the development of a universal social tariff scheme for England and Wales.

Anglian Water

Metered bill

The purpose of WaterSure is to ensure that people are protected from higher bills driven by high essential water use needs.  We are not therefore recommending an option where the scheme is extended to unmetered customers whose charges don’t vary with the amount of water they use. However, we are happy to receive any comments or ideas on this aspect of WaterSure eligibility requirements.

Separate to WaterSure, water companies operate social tariff schemes which provide bill support to a wider group of low-income households. In the vast majority of cases these schemes are available to customers who pay unmetered charges.

ANH considers that metered based charging is the fairest approach to charging customers.  Although Watersure is a fixed charge and there is no usage-based eligibility criteria, a break-even point exists at which customers are better/worse off on Watersure charges compared to normal charges based on metered usage. This remains an important principle to be maintained given its underlying target is to alleviate the cost of high essential use.

Low Income

We would like to explore if the current requirements around income-related benefits are still fit for purpose to allow for those that need support to be able to access it.  We outline a number of different options for consideration below, and welcome other suggestions.

Remove the requirement for claimants to be in receipt of benefits

Instead of supporting only low-income customers this would extend help to any household with higher usage due to family size or medical conditions. There would be an option to remove the requirement for benefit receipt from one or both of these groups.

All households that have higher usage due to family size or medical conditions would be able to receive help with their water bill to offset the costs – thus significantly widening the number of households eligible for assistance. This would also remove the amount of evidence which claimants need to provide (ie evidence of benefit receipt) and which has to be evaluated by companies.

Considerations:

• In widening eligibility for the scheme there would be an associated increase in the cost of the cross subsidy required through bills to fund support
• Removing any element of means testing would mean that some very high-earning households would be eligible for support funded by those just about managing on low incomes
• This would remove incentives for water efficiency (in terms of non-essential water use) from a much wider group of customers (given many more customers would pay a fixed bill rather than one which increases with higher levels of usage)

ANH does not support a change to extend help to higher occupancy households per se.  It suggests an untargeted cross-subsidy from low occupancy to high occupancy households regardless of respective income levels and comparative affordability.  We support the principle that those with a medical condition requiring the use of more water should receive support towards the cost of that additional water use, hence our medical needs discount scheme to be introduced in AMP8, funded by our shareholders.  In developing this scheme, we noted that it is not necessarily the type of condition that determines the incidence of higher water use but rather an individual’s specific symptoms, and therefore eligibility is better based on medically certified higher usage.

Replace benefit entitlement with a household income level threshold

This would make household income the determining factor rather than benefit entitlement. For example, this could be set at a similar level to the income thresholds used for some social tariffs – e.g. £20,000. This would mean that support to lower-income households would still be available, and not limited to those that are in receipt of benefits.  This approach would negate some of the less positive considerations highlighted in option 1 above.

Considerations:

• Depending on where the income threshold was set this could again increase or reduce the number of households eligible, having an impact on the cross subsidy
• Some households currently supported could potentially lose access to help
• Different thresholds may be required for different household sizes in order to avoid larger families missing out on support (due to higher levels of benefit)
• There may be consequences for the process of validating eligibility, and the ability of companies to make use of existing data share arrangements with DWP to target support and validate entitlement
• An income threshold would need to be automatically increased with inflation

Once the proposal shifts to considering income thresholds as opposed to receipt of benefits as the basis of eligibility, it would seem to be moving into the area already discussed in relation to a single social tariff (“SST”).  Is the thinking that morphing Watersure into something closer to the scope of a SST avoids the need for new primary legislation, otherwise required?  Watersure was designed in order to protect large, low-income families from a sudden steep bill increase when moving from unmeasured to measured charges, hence current eligibility criteria; with the same consideration applied to those with qualifying medical conditions.  Rescoping Watersure as above would create overlap with some existing social tariff schemes.  A single income threshold does not equivalise variation in disposable income arising from differences in household occupancy; and therefore, would exclude higher occupancy households with incomes above £20k that nevertheless have lower effective disposable incomes and may therefore experience “water poverty”, compared to lower occupancy households with incomes below £20k.  Creating different income thresholds based on varying occupancy would create significant transaction costs in obtaining and verifying household occupancy.

Expand qualifying benefits to include non-means-tested disability benefits

Some people who have a disability are entitled to specific benefits which recognise the additional living costs they face, irrespective of the level of their income or financial circumstances. Adding these benefits (ie Personal Independence Payments, Disability Living Allowance (for children) and Attendance Allowance) as alternative eligibility criteria, alongside income-related benefits, would expand the number of households eligible for help.

This could help address a key area where people with a disability face higher living costs (and which may not be adequately covered by disability benefits).

Further variations might include placing an income cap on eligibility and/or capping bills to those qualifying on non-income related criteria at a different level.

Considerations:

• Widening the number of households eligible for protection would result in an associated increase in the cost of the cross subsidy required through bills to fund the scheme
• Some very high earning households could be eligible for support, funded by those just about managing on low incomes, although an upper income threshold cap might help address this

The eligibility assessment for ANH’s social tariff, LITE, excludes non-means-tested benefits in calculating income to compare to water/sewerage charges, recognising that these benefits are provided to households specifically to offset the higher living costs that people with disabilities incur, irrespective of income levels.  It is not immediately apparent why it would be reasonable to specifically include customers in this circumstance within the eligibility for a concessionary tariff (Watersure), simply on the basis that the (higher) benefits they receive may not adequately cover the higher living costs they face.  Given that state benefits are at least funded though progressive tax structures, whereas any cross-subsidy funded by water customers is essentially regressive in nature, on the basis that it applies to all customers irrespective of their income level, funding a discount for customers receiving non means-tested benefits will create a cross-subsidy funded in part from households that may have greater affordability issues than those receiving the discount.

Family size

The average UK household size has remained similar over the last 10 years, with 2.36 residents per household in both 2012 and in 2022. However analysis of ONS data suggests that there has been a recent significant increase in lone parent family units which have three or more children. These increased by almost a quarter (24.7%) between 2015 and 2020.

Within this context we would welcome views on the adequacy and scope of the existing WaterSure criteria in terms of targeting support to ‘large families’. We outline a number of different options for discussion below.

Increase or reduce the number of children needed to qualify

Changing the number of children required to claim support would widen or reduce the reach of the scheme.

Considerations:

• Changes would impact the level of customer cross subsidy needed to fund the scheme
• Reducing down to two children could mean families of just 3 people might qualify as a large family – in many cases their bill may already be below the bill cap level (as it stands) and so they would not see a benefit from the scheme
• If the number of children required to claim was increased then some households currently supported would lose access to help
• Changes would also impact the number of households subject to price signals in respect of their non-essential use of water

ANH has no objection to the principle of the number of dependent children being the determinant of eligibility for support.  We would again note that Watersure was designed in order to protect large, low-income families from a sudden steep bill increase when moving from unmeasured to measured charges, hence current eligibility criteria.  We assume further data analysis and modelling would be required to understand the potential increase in the cross-subsidy funded by non-eligible customers prior to any decision to change the basis of eligibility.

Extending support to larger multigenerational households

This could help support customers with higher water usage needs due to the presence of older family members within the household group. For example, the criteria could change to three or more people within the following groups living at the property:

• Dependent children
• People receiving state pension or pension credit

Considerations:

• Changes would impact the level of customer cross subsidy needed to fund the scheme
• Older family members living in the household will not normally be fully dependent – they will usually have income from a pension and/or pension credit

There has also been a notable increase in the proportion of multigenerational households. Households which include two or more adult generations rose from 1.8% in 2011 to 2.1% in 2021.

It is not apparent as to why the presence of an older family member in the household (i.e. someone in receipt of the state pension or pension credit) automatically puts the household into a position of struggling with affordability.  Effectively, the proposal is that a multi-generational household is good proxy for judging affordability.  It is not clear that this multi-generational circumstance necessarily creates a greater affordability issue for the household compared to e.g. a household with 2 dependent children compared to 3 children. Our understanding of the benefits system is that where a pensioner lives with a household (working or not) the pensioner’s application for pension credit will be on their sole (or couple) income and will not include that of the entire household. Therefore,  a pensioner can live with a family member that is potentially a high earner and they can still receive pension credit if their income is below the threshold.

Medical conditions

Signal eligibility more clearly

Feedback from organisations representing groups who apply for the scheme has suggested that on occasion there can be confusion about the eligibility of conditions which are not specifically listed in the regulations. This can be particularly true for mental health conditions which can lead to excessive water usage, such as obsessive compulsive disorders or dementia.

It might therefore be helpful to signal the fully inclusive scope of the regulations more clearly by replacing the list of specific conditions with a clear statement.

In giving equal prominence to all conditions it might also be appropriate to remove the ability for companies to require a medical practitioner’s note in some instances – reflecting how the scheme is now applied in practice.

Considerations:

• Removing the specified conditions may make the offer clear to some but may make it less clear for others

For clarity, the current eligibility requirements of Watersure, apart from the specific conditions listed, include any person residing in the Premises diagnosed as suffering from another medical condition as certified by a registered medical practitioner that necessitates the use of significant additional water.   The intent is therefore to include all medical conditions.  If the preceding list is leading to confusion as to the potential wider scope of eligibility, then ANH has no objection to replacing that list with a clear statement of approach. However, we would not support removing certification by a medical practitioner.  In developing our proposals for a medical needs discount to be funded by our shareholders, we gained greater awareness of the higher water usage that some mental health conditions may cause for some customers but also that this is a specific problem for individuals rather than generic to a wider condition such as dementia.  We therefore believe that support should be targeted at the symptom as evidenced i.e. the need for higher essential water use, rather than support simply dependent on presence of the underlying medical condition.

Bill support provided

We wish to explore whether this is the right approach, or if limiting or reducing bills in some other way is more appropriate.  Some companies have moved to capping bills at their average metered bill level (which is lower) – with the company funding the difference. As a recommendation of our 2021 affordability review, we called on other companies to consider doing this. Many companies are now offering this enhanced support.

We outline a number of different options for discussion below.

Change the cap to the company average metered bill level

This would expand the enhanced help currently available to some customers to those in all company areas.

Considerations:

• There would be an increase in the cross subsidy needed to fund this help.
• In the case of companies already offering such enhanced support, it would enable them to move these costs from being funded by the company to being paid for by customers.

ANH has no concerns in principle with this approach, based on customer funded cross-subsidy.  Over 87% of our household customers are charged on a measured basis, and the current cap is therefore weighted heavily towards the average measured bill.  As reflected in the considerations noted above, in order to move forward on this basis, we understand that regulation 3 of the Water Industry (Charges) (Vulnerable Groups) (Consolidation) Regulations 2015 should be amended to clearly mandate the new approach.  We assume further data analysis and modelling would be required to understand the potential increase in the cross-subsidy funded by non-eligible customers prior to any decision to change the basis of calculating the fixed charge.

Change the cap to either the local average metered bill or industry average metered bill – whichever is lower

Whichever is lower out of the local average metered bill or industry average metered bill would be used as the cap.  This would provide enhanced support in areas where average bills are already higher.

Considerations:

• Changes would impact the level of customer cross subsidy needed to fund the scheme

ANH can discern no apparent logical basis for adopting this approach.  It would seem to create something of a postcode lottery in terms of the proportionate support available and the relative levels of cross-subsidy to be funded by other customers, and also negates the reality of regional supply companies with varying costs to serve.  Of more concern, it would appear to be completely unworkable on an ex-ante basis in setting charges within the allowed revenue controls, and therefore would require a final reconciliation in the end of AMP true-up any under or over recovery of allowed revenues per the retail revenue control.

Replace the cap with a percentage of fixed amount discount

This would provide an element of free water services to all eligible households irrespective of the total amount of water used. This would be more inclusive in terms of households with additional essential use needs but where overall usage is modest. In addition the price signal for non-essential water use would be restored, potentially encouraging greater water efficiency

Considerations:

• Essential water use needs can vary considerably between households – in some cases a fixed or percentage discount may not fully cover these needs
• Changes would impact the level of customer cross subsidy needed to fund the scheme

ANH has no principled objection to this approach. It would seem fairer, including more households given there would no longer be a break-even point on their existing bill compared to the current fixed charge approach.  Companies are all considering how tariffs can support the efficient use of water, therefore retaining an unmeasured fixed charge, whatever level it is set at, is clearly at odds with this initiative. Watersure based on a single fixed discount against the standard fixed and volumetric charges would maintain a price signal and ensure all eligibility customers benefit in percentage terms equally.   The question is what would be an appropriate percentage discount that would not leave (most) customers worse off compared to the current situation, not just in respect of ANH but across the industry as a whole.  We calculate the average discount for Watersure customers to be 45%. We assume further data analysis and modelling would be required to understand the potential increase in the cross-subsidy funded by non-eligible customers prior to any decision to change the basis of support.

Introduce a Single Occupier bill cap

A separate bill cap for single person households, with a relevant medical condition, would open up support or enhance help for this group. The cap would be set at an average bill level for a single person. This approach would be more inclusive – people previously below the household cap level would move into support and those already receiving help would get a larger bill reduction.

Considerations:

• There may be some additional administration in terms of water companies validating single occupier status
• Changes would impact the level of customer cross subsidy needed to fund the scheme

ANH acknowledge the equity of this proposal.  On the basis that average occupancy is 2.1 people per household, the current basis of calculation of the Watersure bill means that a single person household with a relevant medical condition is disadvantaged compared to higher occupancy households.  However, the tariff was originally designed to support large families on low income from the impact of metering. An amendment for single occupiers not only changes the underlying principles of the tariff but also introduces further transaction costs.  We assume further data analysis and modelling would be required to understand the potential increase in the cross-subsidy funded by non-eligible customers prior to any decision to change the basis of eligibility.

Mr O – Individual respondent

Hi Andrew, I just read your call for input on CCW site and thought that I’d put my pennies worth in regarding the watersure scheme. I think that the medical criteria should include Diabetes as it does mean that a lot more visits to the toilet are neccessary and therefore a lot more water is used. Also I don’t think that it should be dependant on any means tested benefits for people with medical conditions. It should be possible to check that a person is telling the truth as it should be evident from a copy of the claimants prescription which will list any medications that are required for the reatment of the medical conditions.

Mr G – Individual respondent

Awareness of the WaterSure scheme is very low, even though it increased in 2023. Any revision of the scheme should be accompanied by efforts to raise awareness of it, particularly amongst advisors.

Metered Bill

I agree that there is not a rationale for extending this scheme to unmetered customers.

Low income

Given what has been decided about the Winter Fuel Allowance, it does not seem politically possible to extend the WaterSure eligibility criteria without reference to income, either household or individual.

Household income level threshold

This would significantly increase the administrative costs of the scheme. If this was a replacement for the existing scheme I think that the transition would be difficult because existing claimants could not be moved over to the new scheme without checks and there would be issues of take-up. It would need a good cost-benefit analysis before considering its implementation.

I would support a scheme which used household income as an additional qualification. That is to add another category. This would add to the administrative costs of running the scheme but would avoid the transitional costs of having just a household income threshold and the problem of setting the threshold at a level where receipt of certain benefits takes a person above the income threshold. This would make the scheme more inclusive but would require additional cross-subsidy.

Expansion to include non-means tested benefits

I would support this as reflecting the higher costs for those in receipt of these benefits. I would not support setting an income threshold or a separate cap for these people on the grounds of the additional complexity that would be introduced.

Family size

Increase or reduce the number of children

I do not see any case for change.

Larger multi-generational households

This would have to be restricted to those on pension credit. People receiving a state pension may also be in receipt of a workplace pension or have other sources of income.

Deciding whether a child is a dependent would add additional complexity to the scheme. The definition of a dependent child used by the ONS is tighter than the current definition of children in WaterSure. So I am not sure what is intended.

Medical conditions

I agree that medical eligibility should be signalled more clearly.
Companies will need the ability to check whether a person is suffering from a relevant medical condition.

Bill support provided

I would support setting the cap at the company average metered bill level. This seems logical since the claimant must be metered in the first place.

Because we have a regional system, I do not support basing the cap on an industry average.

I do not support the introduction of a percentage of a fixed amount discount. I do not see the benefits of this outweighing the time and costs of implementation. There will be continuing arguments about where this percentage is to be fixed.

I do not support a single occupier bill cap. Validating this would increase costs to the administration of the scheme.

Northumbrian Water

Thank you for sharing the call for input for WaterSure.

We have taken time to review the proposals and considered the feedback we have received about the current criteria to understand where we feel that a fair level of expansion would be appropriate.

Generally, the main feedback and complaints we receive from customers is where they are not in receipt of means tested benefits, so we welcome the proposals to expand this.

I have covered our feedback on the areas below, please let me know if you would like any further information.

Low Income

We are supportive that eligibility continues to be based on claiming of disability benefits and expanded to include non means tested disability benefits. We have had customers contact us sharing that they are on a low income, receiving PIP but not means tested benefits and they feel they are being penalised by not being eligible.

We complete data sharing with DWP to identify customers who are in receipt of eligible benefits, and having this simple match criteria has identified an additional 9000 customers for Bill-cap WaterSure. Moving away from a link to benefits, would make it more complex for customers to assess if they are eligible and for us to administer and automate identification of customers.

For customers who are on a low income and not in receipt of a disability benefit would be supported through our social tariff which generally would provide a higher discount for customers rather than an average bill.

Family Size

We feel that the current rules of 3 children is appropriate and a fair measure of large family.  We would be supportive if this was to be extended to include foster children, as they are currently excluded as the foster parent may not be receiving child benefit. This would be linked to the foster family being in receipt of a means tested or disability benefit.

Medical Conditions

We are supportive of expanding principles to support customers with a mental health condition; however, we have concerns on the onus this would put upon us to assess eligibility. We currently accept customers would have applied and live with OCD or dementia, where the condition has led to excess water usage.

With MIND quoting that 1 in 4 of the population could experience a mental health condition each year, and with these often being short term, we have concerns that customers could be going on and off the scheme, and lead to more intrusive conversations around why extra water usage is necessary.

We feel that it would be beneficial to have extra guidance around mental health conditions if this is to be considered.

Bill Support Provided

We currently cap customers bill at an average metered value. We would be reluctant to move to an average national bill as this would mean that the scale of discount would need to be considerably different for different companies and unfairly benefit customers.

We feel that continuing with an average bill value, aligns to the principle of helping customers with a disability or large family on a level playing field. If customers’ bills were lower than others in the region this would mean that the level of cross subsidy would be considerably higher for different areas.

We also have concerns with moving to a discount amount or percentage as this would make it more difficult to administer and assess. The simplicity of the current fixed amount for average bill value feels like a fair approach and easier for customers to budget on.

 The current single cap level at average bill does not feel appropriate for single occupiers, so we would support a move to a reduced cap level for single occupier customers. We feel this would be easy to administer and could be reviewed on an annual basis.

Portsmouth Water

Thank you for the opportunity to provide our input on the potential improvements to the WaterSure financial support scheme. We appreciate your efforts to ensure the scheme continues to evolve, especially given the growing financial pressures faced by households across England and Wales.

After reviewing the proposals and suggestions, we believe that WaterSure has served an important role since its inception. However, with the introduction and evolution of social tariffs, WaterSure may have outlived its usefulness in addressing affordability challenges. We are of the view that it would be beneficial to simplify the framework by establishing common eligibility criteria for social tariffs and a standardised percentage-based bill reduction. In this context, we would propose repurposing WaterSure to focus specifically on customers who have medical conditions requiring significantly higher water usage. This would allow the scheme to address their specific needs without the constraints of income thresholds, ensuring support for those whose medical requirements necessitate higher water consumption.

1. Current Eligibility: Must be Metered

We continue to believe that requiring customers to be metered is essential, as it provides a clear framework for capping charges based on actual water usage. However, we recognise that some unmetered customers, particularly those with medical needs, may face challenges in transitioning to a metered system. While we encourage the promotion of metering as the best value tariff, it’s important to ensure that unmetered customers are also considered fairly, perhaps through additional support mechanisms tailored to their specific circumstances.

2. Current Eligibility: Must be in Receipt of Income-Related Benefits

While we support the use of income-related benefits as an eligibility criterion for affordability schemes, WaterSure may not be the best vehicle for addressing these needs any longer. We suggest aligning WaterSure more with the social tariff framework and focusing it on specific needs like medical conditions, rather than keeping the existing income-based criteria.

3. Low Income Eligibility: Removal of Benefit Requirement

While broadening the eligibility criteria to include all households with higher usage due to family size or medical conditions could significantly increase the number of households eligible for support, we have concerns about the potential dilution of the scheme’s focus on affordability. Removing the requirement for benefit receipt could lead to supporting households that do not face financial hardship, thereby reducing the scheme’s effectiveness in targeting those most in need. We recommend maintaining a strong link between affordability and eligibility to ensure that support is directed where it is most needed.

4. Low Income Eligibility: Replace Benefit Entitlement with a Household Income Threshold

We agree that setting a household income threshold as a criterion for eligibility could enhance the scheme’s ability to support low-income households, regardless of benefit receipt. This approach would align with the objective of targeting support based on financial need, while also ensuring that larger families and households with medical conditions receive appropriate assistance. The income threshold should be carefully set, possibly with adjustments for household size, and automatically indexed to inflation to remain relevant.

5. Low Income Eligibility: Expand Qualifying Benefits to Include Non-Means Tested Disability Benefits

We believe that the exclusion of non-means tested disability benefits, such as Disability Living Allowance and Personal Independence Payments, represents a gap in the current WaterSure scheme. Many customers, including those with medical conditions or parents receiving disability benefits on behalf of children, may not qualify for WaterSure simply because these are the only benefits they receive. Expanding eligibility to include these benefits would fill a significant gap and ensure support for those who genuinely need it, regardless of their income level.

6. Family Size Eligibility: Adjusting the Number of Children Needed to Qualify

We do not see a strong case for adjusting the number of children needed to qualify for WaterSure, as the current structure seems adequate. However, we would support increasing the age limit for qualifying children, particularly in cases where they are over 18 and remain in full-time education while living at home. This would ensure that larger families with older dependent children are not excluded from receiving support.

7. Family Size Eligibility: Extending to Multigenerational Households

While we understand the growing trend of multigenerational households, we believe that the existing WaterSure criteria, which focus on medical needs and income-related benefits, already provide adequate support for such households. Expanding the scheme to cover all multigenerational households, regardless of their specific circumstances, could significantly increase the number of beneficiaries and strain the scheme’s resources. Instead, we suggest maintaining the current focus on supporting households with specific needs such as medical conditions or financial vulnerability.

8. Medical Conditions Eligibility: Signal Eligibility More Clearly

We support efforts to provide a clearer and more inclusive definition of medical conditions that qualify for WaterSure support. A core list of conditions, supplemented by the ability to add others based on evidence of significant additional water usage, would help clarify eligibility for both customers and stakeholders. We also recommend reviewing and enhancing the list of conditions to ensure it remains relevant and comprehensive.

9. Bill Support Provided: Cap Based on Company Average Metered Bill

We support continuing to cap charges at the average household bill level, as this approach offers a balanced level of support that is both fair and sustainable. However, we are cautious about proposals to use either the local or industry average metered bill, particularly if this could lead to disparities between regions or companies. Any changes to the cap structure should ensure that support remains consistent and equitable across all water companies.

10. Bill Support Provided: Replace the Cap with a Percentage or Fixed Amount Discount

We understand the rationale for introducing a fixed amount of free water services or a percentage-based discount. While this could encourage water efficiency and provide more tailored support, we foresee challenges in administration and determining the appropriate level of support for households with varying water usage. Further exploration is needed to ensure that any such changes are practical and fair for both customers and water companies.

While we support the overall direction of improving the WaterSure scheme, we believe it is essential to focus on simplifying the framework and aligning it more closely with the evolving social tariff provisions. Repurposing WaterSure to focus on customers with specific medical conditions, regardless of income, would streamline the scheme and ensure that it continues to provide meaningful support. Expanding eligibility criteria or altering the support provided should be carefully balanced to target those most in need, while maintaining the scheme’s financial sustainability and retaining customer trust.

We would welcome the opportunity to discuss these points further during the autumn as you continue to develop your recommendations. Please do not hesitate to contact us if you require any additional information or clarification.

Thank you once again for the opportunity to contribute to this important consultation.

SES Water

Here are some notes for Watersure improvements

• Not all low income households are on benefits – it should be household income and not just for those in certain benefits.
• Watersure is very high as a financial support scheme, should come hand in hand with Social tariff so we do not miss any on a low income
• Medical documents are very expensive to get from doctors as most will now charge, can prescriptions suffice.
• Look at whole new scheme incorporating low income with medical conditions for those who do not qualify for social tariff but a fairly low income and not on benefits
• Listing  criteria for this scheme is outdated and we may miss signing up customers if they look at our criteria on website etc.

Here are just a few of my thoughts on improvement

Southern Water

Metered Bill

SW supports the idea of Watersure remaining on Metered eligibility. There could be scope to introduce Watersure to assessed charges if it were evident that the assesed charge was higher than the Watersure cap.

Low Income

SW feels that the current means tested benefits are a good way of ensuring support is provided to those that need it. It is felt that a threshold level would be useful to ensure fairness, however consideration would need to be given to what is included within income range. Those on a low income could see their income level pushed above any pre set income threshold by receipt of benefits such as PIP, meant for personal independence. Therefore means teseted benefit is a good indicator of eligibility.

Family Size

SW feels the ‘Large Family’ indicator of 3 children under 19 is adequate and a good indicator of an increased requirement for water usage. It is likely families outside of the criteria would better benefit from individual water suppliers social tariff’s. Continuing the support at this level would ensure the right type of support for the right situation.

In prinicple SW supports extending the family size to include multigenrational households, however believe the same eligibility criteria as children under 19 would need to be applied to reflect eligibility for dependent adults.

Medical Condition

SW supports changing the medical criteria to any physical or mental health condition which may result in the use of significant additional water usage. However, feel that medical practitioners notes are important to ensure the support is provided for those that need it.

Bill Support

Our average metered bill is not lower than the average bill, so the existing approach is correct for us. We agree the fixed % reduction may not adequentaly provide support. SW support the use of a further ‘single occupancy’ capped bill with evidence provided (such as council tax bill reflecing single occupancy?)

Thames Water

HI Andy,

We have been discussing this request for feedback internally. Focusing on the important thoughts:

• Watersure is well targeted, but at quite a small segment of our customers
• Customers are often eligible for both WaterSure and WaterHelp, our social tariff, and only if their bill is twice the average will they be better off on WaterSure as WaterHelp’s discount is 50%
• The criteria is confusing to communicate, but the means tested benefit plus 3 children does make DWP data sharing possible. If NHS data on health conditions could be combined with DWP that would be very powerful.
• One way to extend the reach of WaterSure and make it more impactful would be to keep the criteria of medical condition/3 children but expand the means tested benefit to other assessments of financial vulnerability. For example ‘Financial Difficulty’ credit rating data or a deficit budget highlighted within a Standard Financial Statement. I’m afraid I’m not able to model the impact of this.