The deadline for making representations on the draft determinations is 10am on 30 August 2019. This deadline is set in order for us to have sufficient time to give conscientious consideration to representations ahead of making our final determinations, which will be published on 11 December 2019.
Representations from water companies
To ensure we have sufficient information to effectively take account of representations for the final determinations, we are asking companies to complete a representations pro forma. Completing the pro forma will help companies to maximise the impact of their representations on the draft determinations, as they will enable us to better identify what the issues are that we need to address. The pro forma contains four tables:
- RP1 – Evidence summary for cost assessment purposes
- RP2 – Draft determination action and interventions response summary
- RP3 – Other issues summary (except cost assessment)
- RP4 – Schedule of data requirements for the final determination
There is one pro forma for all water companies to use which can be found here.
We expect companies to publish their representations on the draft determinations including any updated business plan tables.
RP1 – Evidence summary for cost assessment purposes
The purpose of this table is to make it possible for us to clearly identify where companies wish to make representations on our view of costs. Companies should clearly identify where their views of efficient costs differ from ours, and what further evidence they are providing to support their views. A unique reference code in the form [company acronym].DD.CAX will be automatically assigned as issues are recorded in the table.
This information will allow us to identify where there are remaining gaps between our view and company views of costs. In addition, this information will allow us to come to a view of a company’s final cost submission, for use in the calculation of cost sharing rates. If a company has not changed its view on costs in response to our draft determination then it should clearly state that this is the case. If the company agrees with our view of costs, it should clearly state this is the case. If a company does not include any lines in this table then we will assume that no gap remains with our view on costs.
RP2 – Draft determination action and interventions response summary
In this table, companies are required to signpost evidence from their representation of how they have responded to:
- any further actions set out in their draft determination action and intervention summary documents;
- other actions set out in their draft determination company specific documents; and
- generic actions for all companies required by Ofwat.
In addition, where companies make representations on issues connected to existing actions or interventions set out in the policy area action and intervention documents, we request that these are signposted in this table.
RP3 – Other issues summary (except cost assessment)
In this table, we request that companies set out each new issue that they wish to raise in response to the draft determinations as separate line items. Companies should highlight which parts of their representation provide relevant further evidence to support the company’s view. A unique reference code in the form [company acronym].DDXXX will be automatically assigned as new issues are recorded in the table. Where possible these reference codes should be used to reference relevant issues in the company’s representation documents.
Where issues relate to an existing action or intervention included in the draft determinations actions and interventions documents, these should be listed in table RP2.
RP4 – Schedule of data requirements for the final determination
This table specifies which business plan tables we require companies to resubmit and those tables companies are choosing to resubmit in support of their representations. The table also sets out specific data we require for the final determination in the areas of outcomes and developer services.
Companies should only resubmit tables where changes have been made from their 1 April 2019 submission and for fast track companies, 3 September 2018 or 11 February 2019 submitted data as appropriate. All changes should be highlighted in red formatting in the tables.
We are not publishing prepopulated versions of the business plan tables. We will be publishing a new excel files which are referred to as the ‘PR19 draft determinations – Outcomes representations data submission’ to collect specific outcomes data and ‘PR19 draft determinations – Developer services data request’ to collect data on developer services based on refined definitions.
All elements of company representations should be uploaded to Ofwat’s PR19 Data capture in Sharepoint. Companies may also email representations to [email protected]. We will consider all representations when making our draft determinations. However, representations that do not provide further evidence to support a view that differs from those set out in the draft determinations are unlikely to result in changes in the final determinations.
Outcomes-related data for draft determination representations
A general template of the Outcomes Draft Determination Representation Tables, applicable to water and sewerage companies (WASCs), is available for download here.
Representations from other stakeholders
Other stakeholders should email their representations to [email protected]. In order for us to have sufficient time for these to be taken into account ahead of final determinations, these should also be submitted to us by 10 am on 30 August 2019.