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Annual Return 2001-05
A consultation paper on monitoring companies' performance
The Director welcomes your views on the issues that are addressed in this consultation paper. Please send them to:
Roger Dunshea
Director of Operations
Office of Water Services
Centre City Tower
7 Hill Street
Birmingham B5 4UA
or by fax to: 0121 625 1413
by 4 July 2000
All responses should be marked Annual Return 2001-05.
If you wish to clarify any points in this paper, please contact Julia Havard, Head of External Relations (0121 625 1450) in the first instance and she will ensure that your query is dealt with.
Unless otherwise requested, responses will be placed in the Ofwat library and made available to the public.
FOREWORD
Since 1989 Ofwat has set up a tried and tested annual process of information capture from the water and sewerage companies and water only companies of England and Wales. This information in the form of the annual June Returns(1) has been central to monitoring the performance of the industry and taking any necessary regulatory action. The information collected in the Annual Return also plays an important part in the Periodic Reviews of price limits.
This consultation paper sets out the proposed Annual Return from June 2001 to June 2005. The information collected annually to monitor the companies and take action as required, has been updated to reflect Future Water and Sewerage Charges 2000-05, the Water Industry Act 1999 and our review of the June Return 2000 aimed at reducing the burden of unnecessary data capture.
The new information requirements take into account the separate monitoring carried out by the quality regulators, the Environment Agency and the Drinking Water Inspectorate.
The proposed Annual Return 2001 will have two sections. The first will be a board level overview with supporting tables. This overview will report the performance of the company on delivering the main outputs set out in the 1999 Final Determination and Monitoring Plans and the way companies are financing their functions between price reviews. I will expect the board of each company to take ownership and sign off this section. The board level overview supporting tables will cover, at a high level, outputs, activities on the network, costs and financial performance with supporting text.
The main of body of the Annual Return consists of the detailed tables necessary to report outputs, services to customers and enable comparative competition, and to understand the financing of company functions and to prepare for the next price review.
The proposed Annual Return information submissions reflect the minimum necessary to ensure that I can carry out my duties. The information needs to be accurate. Companies have a responsibility to rigorously check their data, which will be scrutinised by Auditors and Reporters. The proposed Annual Return needs to be complete and submitted in time for me to publish the following reports.
- Report on financial performance and expenditure of water companies in England and Wales (July)
- Report on levels of service for the water industry in England and Wales (July)
- Report on water and sewerage service unit costs and efficiency (December)
- Report on leakage and efficient use of water (September).
Since February of this year my staff have undertaken a review of the information requirements set out in the June Return 2000. This review has been a detailed process which has resulted in a measurable reduction in the requirement, however this has been offset in part by the new information needed, arising from the Water Industry Act 1999 and the Periodic Review 1999 Final Determinations. The overall outcome is that the Annual Return 2001 has a reduced information requirement compared to the June Return 2000.
I welcome comments on the structure, information requirements and timing of the Annual Return for 2001-05.
I C R Byatt
1 The Annual Return was submitted in July up to 1998.
Objective
This paper sets out for consultation the proposed structure, timing and content of the information required by the Director for the regulation of the water and sewerage companies in England and Wales over the next five years 2001-05.
The background to the annual return of information, now known as the June Return (JR), was set out in Information for Regulation 1995.
This current review has been based on the following aims:
1) To ensure the new Annual Return reflects the monitoring requirements arising from the 1999 Final Determinations and Monitoring Plans.
2) To ensure that the new information requirements arising from the Water Industry Act 1999 are incorporated into the return.
3) To ensure that data collected in previous years is still necessary for the effective monitoring and regulation of the industry.
The consultation paper covers the following sections:
1) The Board's overview of its company's performance with supporting tables in Annex A.
2) The addition of new requirements for bad debt and vulnerable customers (Water Industry Act 1999).
3) The process and results of our review of the JR2000 information capture tables. The proposed main tables for the Annual Return 2001 are set out in Annex B.
4) The proposed timetable and structure of the Annual Return 2001.
SECTION I
THE BOARD'S OVERVIEW OF COMPANY PERFORMANCE
Currently companies are required to submit a textual overview to inform the Director of significant matters concerning overall output performance, capital investment and financial performance and progress on improving efficiency.
It is proposed that the overview for the next five years should be aligned more closely to the 1999 Final Determination and the Monitoring Plan. This will require a number of additional tables which record outputs, serviceability, costs and financial performance of companies at a high level, with supporting text.
The proposed tables are set out in Annex A.
A number of companies in responding to the consultation on the Monitoring Plan Reporting Requirements expressed the wish to be able to update their plans year on year. Companies will be able to explain in their textual commentaries where their outputs have varied from those planned.
The additional data required for the overview draws on the Monitoring Plan or can be drawn from the main body of the June Return or information provided to the Quality Regulators and should not place an undue burden on companies for additional information.
The proposed structure requests text to support the data submitted, each section addressing the following issues:
Section 1: Key Outputs – Customer Service (Tables 1 and 2)
Companies would be asked to describe their progress in delivering enhanced levels of customer services and maintaining current levels.
Section 2: Key Outputs – Quality Enhancements (Table 3)
Progress on the delivery of the five-year improvement programme against the out put expectations of both the company and the Director.
Section 3 Capital Maintenance Activity (Table 4)
Companies are asked to report the amount of activity carried out in replacing and refurbishing above and below ground assets as part of their capital maintenance programmes.
Companies should also comment on significant activity undertaken to enhance service levels or to improve supply/demand balance.
Section 4: Water Resources, Supply and Demand (Table 5)
In this section companies should report on the current water resource position against the Water Resource Plans submitted to the Environment Agency and included in their Business Plans.
Companies should highlight any emerging difficulties in terms of security margins in individual resource zones or at company level. Any restrictions placed on the use of water during the year should be explained in this section with details of the duration of restrictions, the type of restrictions in place and the regions affected.
Finally, the company should report on measures taken to manage demand, including those to encourage the efficient use of water by customers and the number of meters installed, both on a selective and optancy basis.
Section 5: Efficiencies
Companies would be required to comment on capital and operating expenditure achievements and confirm that savings have been made without any reduction in outputs.
Section 6: Investment (Tables 6 and 7)
Companies to comment on costs (capital and operating) against expectations (company and regulator), including the extent of equivalence between capital maintenance expenditure and accounting charges.
Section 7: Financial Performance Measures (Table 8)
Table 8 summarises the financial position of the regulated business for the year. The table includes summarised profit and loss information and the key financial parameter of the return on the regulatory capital value together with data on financial indicators.
Companies should comment on profitability, dividend policy, the financing of investment and the impact on financial ratios.
Section 8 Competition
Companies to comment on current activities including inset appointment proposals, common carriage proposals, developments in competitive services and other competitive initiatives/new product initiatives.
SECTION II
INFORMATION REQUIREMENTS FOR BAD DEBT AND VULNERABLE GROUPS (WATER INDUSTRY ACT 1999)
In RD7/00 Ofwat consulted on the data required to provide basic comparative information to inform Ofwat's consideration of the cost implications of any interim determinations involving notified items on bad debt and vulnerable groups.
While a number of companies felt the proposed requirements were broadly acceptable, others expressed concern at the additional burden on companies and suggested data should only be required when an interim determination was triggered. About half the companies said they would have difficulty providing historic data on bad debt and a few were currently unable to split commercial and domestic bad debt.
In the light of companies' comments some changes have been made to reduce the information burden. However Ofwat does think it necessary to collect basic comparable information from all companies both to monitor the impact of the WIA on bad debt levels, and the cost of administering the regulations on vulnerable groups, and because any interim determination would have to be informed by benchmark information from other companies. This does not mean, however, that local factors may not also have to be taken into account. The Director will be consulting separately on this shortly.
A key change to the proposals in RD 7/00 is the collection of information at a company level, rather than split between water and sewerage. For bad debt, the number of age bands of outstanding revenue will be reduced, and for vulnerable groups the medical categories will be combined. These changes will substantially reduce the total number of additional lines to be collected, as reflected in Tables 6a and 6b. Details of companies' comments and Ofwat's intended revisions to the proposals in RD 7/00 will be published shortly.
The implementation of the Vulnerable Groups Regulations will be reviewed separately in conjunction with the Department of the Environment, Transport and the Regions.
SECTION III
REVIEW OF INFORMATION REQUIREMENTS (Feb-May 2000)
The review of the June Return information requirements was carried out over a five-month period from the start of 2000. This followed from the publication of the Final Determination at the end of November 1999. The review objective as explained in the Ofwat Forward Plan 1999-2002 and MD156 was to ensure that the process of collection and analysis is efficient and effective in supporting the Director and to avoid any unnecessary data burden on the companies.
The review identified that the input data items collected for the June Return 2000 could be reduced by 17%, however this has been offset by the new information needed, arising from the Water Industry Act 1999 and the Periodic Review 1999 Final Determinations. The net effect is a reduction of almost 8%.
The data required for the Board level overview can be largely drawn from the main body of the June Return or information provided to the Quality Regulators and is not considered to place an undue burden on companies for additional information.
A detailed review of the lines and table of the 2000 June Return was carried out. Changes proposed are based on the following criteria:
· Materiality – is the information - critical to price setting;
- required under Licence Conditions F, J and K; or
- necessary to monitor the outputs specified in the Final Determination; and
- to support required regulatory action?
· Performance – is the data- required under Licence Condition J;
- required under the Guaranteed Standards Scheme;
- associated with an identified area of concern; or
- necessary to monitor serviceability?
· Comparative Competition – is the data- critical to ensuring that effective comparisons may be made;
- critical to an evaluation of unit costs and efficiency; or
- necessary for comparing customer service standards?
· Data accuracy and completeness - does the definition set out clearly the information required;
- are the current confidence grades appropriate;
- what action is taken over incomplete/inaccurate data;
- is the data duplicated elsewhere, either within the Return, other returns submitted by companies to Ofwat or returns to third parties such as the EA or DWI?
The outcome of the review indicated that some duplication and redundant data should be excluded. The remainder of the tables remain largely unchanged. Refer to Annex B for layout of tables.
New definitions
It is intended to restrict change in the Annual Return over the next five-year period to a minimum. Any new requirements will follow the same criteria of tests set out above and will be consulted upon prior to implementation.
Main purposes for the Annual Return information
In November 1999, the Director set price limits for all water and sewerage companies to cover the five-year period from 2000. In reaching his determination, the Director took account of the outputs that companies would be required to deliver within the new price limits in order to carry out their functions properly.
Each water and sewerage company has set out in its Monitoring Plan its commitments to delivering the required levels of drinking water and environmental quality outputs and standards of service consistent with the price limits set.
Each Monitoring Plan has been scrutinised by Ofwat in the light of the minimum outputs allowed for within the Final Determination to ensure that the committed outputs are no lower than those assumed for the company in the Final Determination.
Companies' progress in delivering their outputs will be monitored through the Annual Return and the separate reports from the quality regulators against the output requirements set out in the Final Determination Supplementary Report.
The Director requires information for two main purposes:
· first, to ensure that customers' interests are protected: by monitoring companies' performance in the delivery of their outputs and measuring companies' costs and returns; and · secondly, to prepare for the next review of prices.
Monitoring companies' performance
Companies have both an incentive and obligation to deliver the required outputs to the timetable agreed and within the price limits set. The Director will review progress on outputs, costs, returns and charges(2)regularly.
The DWI and EA will report in parallel on the performance of the companies in meeting their quality obligations.
Where companies fall short in delivering services to customers, the Director will require them to report to him how they intend to improve. The Director would take formal enforcement action, if necessary, to achieve this. The DWI and EA deal with non-compliance in meeting water quality and environmental obligations. The Director will take account of the financial effects of any such shortfalls together with any additional expenditure on future new obligations in the next price review. In certain circumstances(3), the Director (or a company) may initiate an interim determination of the price limits.
Information required to monitor company performance
During the 1994 Price Review the Director developed a structure for information analysis using a matrix of purpose and cost categories. Information for Regulation (May 1995) reiterated the importance of the matrix as an important structure for the analysis of company performance and in price setting. The business planning process, customer consultation and information requirements for the 1999 Periodic Review illustrated that the Final Determination of price limits would make judgements on a range of issues concerning all four purpose categories of the matrix.
| Matrix of purpose and cost categories | Operating Costs | Capital Maintenance | Return on Capital |
RPI – X | Base service levels | | | |
| Enhanced service levels | | | |
| Supply/Demand balance | | | |
| RPI + Q | Quality enhancements | | | |
Outputs
In monitoring companies' performance in delivering the required outputs within the price limits set, the Director needs information to judge how they are performing against the following categories based on the table above:
This involves supplying water and sewerage services to current quality requirements and customer service standards. The Director therefore needs information both on company compliance with current quality standards, which will be provided by the quality regulators, and on levels of customer service (assessed, for example, by the DG indicators4).
He also needs information on the maintenance of current levels of serviceability to customers and its relationship to expenditure and activity on maintaining existing assets (and in some cases new investment).
· Enhanced service levels
Information is required on the enhancements being made by companies to customer service levels (whether specifically included in the recent price review or resulting from a sharing with customers the benefits from greater efficiency).
Where comparisons indicate that performance is unsatisfactory, the Director requires a company to report to him how it intends to improve.
The outputs over and above base service level required to ensure continuity of services to current and future customers as a result of material changes to either available water resources or customer demand for services.
The Director publishes a report annually on these levels of service output measures to inform and facilitate comparative competition.
Information on company progress towards meeting the required quality enhancements is also required. The quality regulators will provide detailed information on compliance and scheme completion. The companies will be expected to report on progress against key milestones for a number of major schemes.
The Director will take account of any shortfalls in delivering enhancements to the timescale assumed when setting price limits, and in achieving legal requirements by the due dates. These will be viewed alongside extra expenditure on new obligations at the next price review.
The costs associated with the outputs (above), categorised as operating costs and capital costs (including capital maintenance), are collected in order for the Director to monitor the ability of the companies to finance their functions between price reviews.
Review of Regulatory Accounts
The Annual Return includes tables on the financial performance of the companies which are part of the formal Regulatory Accounts prepared and published by companies in July each year.
The Regulatory Accounts are prepared in accordance with Regulatory Accounting Guidelines (RAGs) specified by the Director under Condition F.
The financial performance tables in the Annual Return are also compiled in accordance with the RAGs.
Ofwat will review the form and content of the Regulatory Accounts and the RAGs in a separate consultation exercise during the autumn. This review will cover the following issues:
· The links between the outcomes of the 1999 Periodic Review (including projected regulatory capital values) and the reporting of actual performance of the companies in the Regulatory Accounts.
· Whether the accounts are sufficiently transparent to show the costs of providing services. This will help our work in implementing the Competition Act.
· Whether the accounts are consistent with those of other utilities. This will be considered in conjunction with the other regulators.
· The impact on the Regulatory Accounts of recent accounting policy standards.
The outcome of this review may impact on the financial performance tables in the Annual Return but it is likely that any changes would be available for incorporation within the Reporting Requirements to be issued in December 2000.
(2) Information on charges is collected in January each year in the Principal Statement
(3) for example, in respect of the level of company receipts from land disposals.
(4) the DG indicators are specific quantitative measures of service covering aspects of customers' writted and telephone contact, meter reading and billing contacts, reliability of water supply and risk of flooding from sewers.
Customers' interests
The Director requires information to ensure that customers' interests are protected regarding:
· the prices charged, to ensure that the price limits are being adhered to and that tariffs avoid undue preference and undue discrimination in compliance with company licence conditions; · bad debt and vulnerable customers (See Section II) · the allocation of costs between the appointed and non-appointed businesses; · the appropriate ring fencing of resources for the appointed business;
· transactions carried out between the appointed business and associated companies; and · the use of proceeds from the disposal of land.
He also needs to keep the relevant changes of circumstance for an interim determination under review and maintain up to date costing information and financial models to inform his judgement regarding possible revisions to price limits.
The role of the Ofwat National Customer Council and Customer Service Committees
The Ofwat National Customer Council (ONCC) and the ten regional Ofwat Customer Service Committees (CSCs) represent the interests of customers. They advise and support the Director in regulating the industry and protecting customers' interests.
CSCs submit an Annual Report of their activities to the Director and he has asked them to report to him periodically on a number of service issues.
The CSCs assist the Director in monitoring the performance and outputs of the companies in carrying out the functions allowed for in the setting of new price limits. As part of their monitoring work, the CSCs conduct audits of a sample of cases involving individual customers to assess how well the companies are complying with their customer care policies and procedures. The CSCs and the CSC Chairmen, as members of ONCC, bring grass roots knowledge of the companies in their region and of the concerns of customers which complements the statistical information provided by the companies to the Director.
The areas in which CSCs will work with the Director in monitoring the companies include:
· assessing the effectiveness of the companies' complaints procedures approved by the Director;
· the companies' operation of the Guaranteed Standards Scheme and the approach to compensating customers for poor service;
· assessing the effectiveness of the companies' debt recovery procedures for all customers and their disconnection procedures for non-domestic premises;
· the companies' management of optional metering applications;
· the companies' management of applications received under the vulnerable groups tariffs scheme;
· assessing companies' performance against Ofwat guidelines on services for disabled and elderly customers;
· handling of telephone contacts; and · the companies' compliance with Ofwat's transfer pricing guidelines.
During the current review of information requirements the Customer Service Committees views were sought with reference to the current information collected and future information requirements.
Each CSC was invited to identify areas where further information might be requested. A number of CSCs suggested that more detailed information was needed on the number and nature of complaints made by customers to companies and also on the proportions of complaints passing through to different stages of the complaints procedure. This information would be useful to CSCs, indeed some companies already regularly provide such data to the relevant CSCs. However companies information systems are differently structured and the additional benefit of requiring a standard return is debatable. Ofwat therefore proposes that every company should provide their CSC with complaints information in the form in which their system is able to provide it rather than as part of the Annual Return.
One CSC suggested that external sewer flooding might be monitored through the annual return. However that CSC is already provided with data by the sewerage undertaker, which it monitors. Ofwat believes that given the difficulties in agreeing an appropriate and auditable definition mean that this issue is best monitored through discussion between CSCs and their local companies.
No other additional information requirements were proposed.
Information on Customer Satisfaction
Water UK routinely monitors customer satisfaction at a national level through six monthly surveys conducted by Mori. The results are published. Most companies, but not the smaller companies, carry out their own regular surveys of customer satisfaction with service quality. Ofwat considers that such information would support the primary information it collects on company performance. Because satisfaction levels in any one-year can be influenced by a number of factors, including company public relations activity, the main benefit to Ofwat will be in tracking trends over time.
The wording of the questions varies so that direct comparison between companies is not possible. However, tracking trends over time would not be affected by the precise questions used, provided these are unchanged.
Earlier this year Ofwat sought companies' views on a requirement that the larger companies should carry out surveys of overall customer satisfaction at least once every two years, and smaller companies once every two years, and that both should share the results with Ofwat. It was suggested that it would be beneficial in timing such surveys to coincide with one (or both) of Water UK's twice-yearly national surveys.
Most companies have responded positively, but they have raised concern over the possibility of Ofwat publishing the results. Given that the results in any one-year can be influenced by a number of factors, and given that the information would not be comparable, Ofwat does not consider that any useful purpose would be served by publishing the results each year. Ofwat will, however, consult on what information should be published on trends in customer satisfaction over time.
Some smaller companies, who do not monitor customer satisfaction regularly, have argued that it would be disproportionately expensive for them to carry out such surveys on a regular basis.
Ofwat proposes that companies with more than 300,000 customers should be required to monitor satisfaction with overall service quality at least once a year and provide Ofwat with the results. Views are invited on this proposal and on whether all companies, regardless of size, should be required to provide this information.
SECTION IV
STRUCTURE AND TIMING OF THE ANNUAL RETURN
This section sets out how the information is currently collected from companies and identifies other alternatives.
Structure
It is intended to retrict changes in the Annual Return over the next five-year period to a minimum. Certain information, which is requred for the price review will be collected for two years only
(5) as an extension to the Annual Return. This primarily concerns explanatory information which provides an indication of the differing environments within which companies are working, and necessary extra financial information needed to model price limits correctly. Companies will need to maintain their systems for collecting this explanatory information but will only be required to inform the Director of significant changes in the intervening years.
The review of the information collected from companies has resulted in recognising that some information is no longer required either due to changes in legislation or policy while still maintaining the detail and coverage necessary for regulation(6). However, additional duties under the Water Industry Act in respect of bad debt and vulnerable customers have imposed additional information requirements on the company.
Annex A sets out the data requirements for the Board level overview for 2001-05.
Annex B sets out the Annual Return information required for 2001-05.
Timing
During the internal review of information requirements a number of options were discussed. These included the timing of the return and different submission dates for separate sections.
Historically the Annual Return has been submitted at the beginning of July each year. During 1999, because of the timing of the Periodic Review, the companies agreed to submit the return in June.
Companies announce their preliminary results during May and early June. In order to bring forward publication of the Report on levels of service and Report on financial performance and expenditure from the autumn to late July to enable customers and other key stakeholders to compare and use the preliminary results with Ofwat's analysis of the performance of the appointed business, the Director sought the co operation of companies in submitting the Return again in June. The Director wishes to see this practice continue.
In order to facilitate this, Ofwat would issue the Reporting Requirements in December each year and the Information Capture System by the end of March.
Companies would be required to submit the full return in early June.
Next steps
The aim is to ensure a developed evolution in the changes to the Annual Return. Following the consultation we will publish the Annual Return information requirement by 31 July. After this period we will review the table lay out and titles to ensure they are easy to follow and have a logical structure. This will not mean any changes to the proposed information requirement. These changes will be reflected in the Annual Return 2001 Reporting Requirements (December 2000) and the capture system (March 2001).
(5) for example June 2002 and 2003 for a price review taking effect in April 2005. Until then, the Annual Return will show the explanatory information held for the base year 1997-1998.
(6) Annex B contains the detailed format for the Annual Return and Regulatory Accounts.
Your views are sought
The Director welcomes your views on:
1. the proposed format of the Board's overview and data requirements; 2. the range and scope of information required for regulation; 4. any concerns you have over accuracy and timeliness of collections; 5. the proposal that companies with more than 300,000 customers should be required to monitor satisfaction with overall service quality at least once a year and provide Ofwat with the results or whether all companies, regardless of size, should be required to provide this information; 6. the use of the web for submitting the returns;
Following consideration of the responses, Ofwat will finalise the content, structure and submission date for the Annual Return. A copy of the decision document will be sent to all respondees, companies, Reporters, Auditors and key interested parties, publicised and posted on Ofwat's website by the 31 July 2000.
Please send your comments to:
Roger Dunshea
Director of Operations
Office of Water Services
Centre City Tower
7 Hill Street
Birmingham B5 4UA
or by fax to: 0121 625 1413
by 4 July 2000
All responses should be marked June Return 2001-2005.
If you wish to clarify any points in this paper, please contact Julia Havard, Head of External Relations (0121 625 1450) in the first instance and she will ensure that your query is dealt with.
Unless otherwise requested, responses will be placed in the Ofwat library and made available to the public.
Annex A - Proposed data requirements for the Board's Overview
Annex B – Information required for the Annual Return 2001-05
Annex B has been issued on disc in the first instance to the companies.
The disc is also available on request from the Ofwat library on 0121 625 1373 and the tables will be posted on Ofwat's website
List of consultees
Other government departments
Department of the Environment, Transport and the Regions
Wales Office
National Assembly for Wales
Water Industry Commissioner for Scotland
Water and sewerage companies
Water companies
Water UK
Quality regulators/environmentalists
Council for the Protection of Rural England
Council for the Protection of Rural Wales
Countryside Agency
Countryside Council for Wales
Country Landowners' Association
Drinking Water Inspectorate
English Nature
Environment Agency
Friends of the Earth
Institute of Hydrology
National Farmers' Union
Royal Horticultural Society
Royal Society for the Protection of Birds
Surfers Against Sewage
UK Round Table on Sustainable Development
Other regulators
Office of Gas and Electricity Markets
Office of the Rail Regulator
Office of Telecommunications
Civil Aviation Authority
Office for the Regulation of Electricity and Gas (Northern Ireland)
Reporters and Auditors
Water companies' Auditors and Reporters
Organisations representing customer interests
Age Concern England
Association of British Chambers of Commerce
Chartered Institute of Purchasing and Supply
Chemical Industries Association Ltd
Child Poverty Action Group
Confederation of British Industry
Confederation of British Industry, Wales
Consumers' Association
Food and Drink Federation
Help the Aged
Institute of Directors
Major Energy Users Council
Money Advice Association
National Association of Citizens Advice Bureaux
National Campaign for Water Justice
National Consumer Council
National Council for One Parent Families
National Federation of Consumer Groups
National Federation of Small Businesses
National Federation of Women's Institutes
Ofwat Customer Service Committees
Public Utilities Access Forum
Save the Children Fund
Utility Buyers Forum
Waterwatch
Welsh Consumer Council
Trade bodies, suppliers and contractors
British Plastics Federation
British Water
Chartered Institute of Water and Environmental Management
Clay Pipe Development Association
Federation of Master Builders
House Builders Federation
Institute of Plumbing
Sewer Renovation Federation
Society of British Water Industries
Trade unions
TUC
UNISON
Members of Parliament
Associate Parliamentary Water Group
Liberal Democrat Spokesman on the Environment
Shadow Secretary Environment, Transport and the Regions
Local government organisations
Local Government Association
National Association of Local Councils
Welsh Local Government Association |
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