WRMP24: guidance for retailer involvement in water resources planning
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
WRMP24: guidance for retailer involvement in
water resources planning
1 Introduction
This guidance note has been prepared by the Retail Wholesale Group’s Water Efficiency
Sub Group as part of the delivery of the group’s Action Plan (Delivering Greater Water
Efficiency in the Business Sector Action Plan, January 20211). This guidance aims to
support wholesalers and retailers operating wholly or mainly in England to improve the
engagement of retailers in the water resource planning process as per Headline Action 3 of
the Action Plan. It was developed by a Task and Finish Group comprising representatives
and input from retailers, wholesalers, self-suppliers, regulators, and other stakeholders via
several interactive workshops in spring-summer 2021.
This guidance has been prepared to supplement the Joint Regulator Water Resources
Planning Guidelines2 first published in February 2021 that are designed to help water
wholesalers in England prepare Water Resources Management Plans that comply with all
the relevant statutory requirements and government policy for their 2024 submissions.
Companies that operate wholly or mainly in Wales may also use this as a best practice
guidance document.
While the water resources planning framework is primarily the responsibility of wholesalers,
the intended audience for this document includes water retailers and self-suppliers as they
may be able to contribute insight to inform future plans and can also collaborate in
mechanisms to support non household demand reductions in alignment with licence
conditions to promote water efficiency and to support strategic planning.
1.1 RWG road map to deliver greater non household water efficiency
The work of the RWG’s Water Efficiency Sub Group in 2020 and 2021 has identified a range
of barriers that are preventing customers, retailers and wholesalers from currently taking
action to deliver water savings. These include issues such as lack of awareness of water
scarcity issues by business customers, inadequate consumption data, low customer demand
for water efficiency services, no funding mechanisms for retailer water efficiency
programmes, lack of performance commitment drivers for wholesalers and concerns around
Competition Act contraventions.
In order to overcome the barriers that prevent all key parties from delivering water efficiency
in the non-household market at present, it is the view of The RWG Water Efficiency Sub
Group that the regulatory framework will need to change. The Group’s recommendations for
1 https://mosl.co.uk/groups-and-forums/industry-groups-forums/retailer-wholesaler-group/rwg-related-
documents/3851-delivering-greater-water-effeciency-in-the-business-sector-action-plan/file
2 https://www.gov.uk/government/publications/water-resources-planning-guideline/water-resources-
planning-guideline#contents
1
October 2021
change are being proposed to the Senior Water Demand Steering Group in October 2021 as
a 10-year roadmap (see below).
The importance of this roadmap for WRMPs 2024 is that we are in a period of transition and
that the current barriers, enablers and frameworks for non-household water efficiency are
likely to be subject to change in the short, medium and long term as all parties work together
to deliver greater water savings in this sector.
1.2 Structure of this document
The following sections are included in this note:
• Non-household customer engagement and the Competition Act – a section that
outlines wholesaler and retailer responsibilities with regard to business customer
engagement and issues relevant to the Competition Act that parties should consider.
• Drought planning – a section that outlines recommended engagement between
wholesalers, retailers and self-suppliers during the development and implementation
of Drought Plans.
• Baseline demand forecasting – guidance on how retailers can support the
development of baseline non-household water demand forecasts and the availability
of market data from MOSL.
• Mechanisms to support collaboration for non-household water efficiency –
examples of collaborative approaches for wholesalers, retailers and self-suppliers
• Metering – a summary of the MOSL led Strategic Metering Review.
2
October 2021
2 Non-household customer engagement and the
Competition Act 1988
In the context of this guidance, the Competition Act 1988 is concerned with abuse of a
dominant position and anti-competitive agreements.
During the separation of the English non-household water market into wholesale and retail
functions, a number of tasks and responsibilities were assigned to each party based on
suitability, capability and position within the overall transactional chain.
The largest single shift was customer (the end user of water) ownership, with a transfer of
ownership of this relationship to the Retailer. The market design, as codified, assumed that
wholesalers would no longer interact directly with the customer except in a few
circumstances.
Since the opening of the Retail market, legal teams across both Wholesale and Retail
companies have interpreted the implications of the Competition Act on the delivery of non-
household water efficiency activities with different results which has led to confusion and
uncertainty around the role and responsibilities of wholesalers and retailers in delivering
water efficiency services and become something of a barrier to activity in this area.
It is not the intent of this guidance note to offer legal opinion on the approaches trading
parties may wish to take forward non household water efficiency activity. Each organisation
should satisfy itself that approaches are compliant with the Competition Act 1988 and Market
Codes.
The following may serve as useful points for consideration:
• Both Wholesalers and Retailers have a statutory duty to promote water efficiency,
Wholesalers have an additional responsibility, through the statutory water resources
planning process, to maintain a balance between supply and demand whilst
protecting the environment.
• Under the provisions of the Wholesale Retail Code, “The Retailer is the primary point
of contact for its Non-Household Customers except in cases of Wholesaler planned
activities and unplanned events or incidents.” Part D of the Operational Terms3
identifies ‘planned activities’ as:
1. Capital works that may materially impact on water and/or wastewater
services (Process D1 and D2)
2. Reactive activities to avert material impact on water and/or wastewater
services (Process D3)
Wholesalers should give careful consideration as to how they can deliver water
efficiency activities in line with these code provisions. As Ofwat and EA suggested in
their letter (March 2020), particular consideration should be given as to how greater
3 https://mosl.co.uk/document/market-codes/wrc/4459-wrc-part-3-operational-terms-v15-0/file
3
October 2021
water efficiency could be delivered by working with and motivating the retailers they
supply.
• A market for water efficiency services exists beyond Wholesalers and Retailers. All
trading parties should consider the effect of their water efficiency plans on
competition in the water efficiency services market, to avoid ‘abuse of a dominant
position’.
• Wholesalers own the operational risk and benefits of consumption in demand –
particularly in water stressed areas – but Retailers are exposed to commercial risk of
demand reduction as under default pricing structure it reduces Retailer revenue.
4
October 2021
3 Drought Planning
Consideration of drought planning was not specified in the RWG Water Efficiency Action
Plan in Headline Action 3 on water resources planning. The Task and Finish Group,
however noted it’s importance as an area for collaboration between wholesalers and
retailers and so brought, at least its initial consideration, into the work programme for the
group.
Water wholesalers are required to prepare and maintain a drought plan on a five-yearly
cycle. The plan identifies actions they will take before, during, and after a drought to maintain
a secure supply of water and outlines how they will assess and mitigate against the
environmental impacts of their actions.
Further details of the drought planning process and regulatory requirements for companies
operating wholly or mainly in England can be found here: Drought: managing water supply -
GOV.UK4.
Drought Plans are tactical in their focus and set out the phasing of actions that would be
taken. In terms of engagement with water users to manage demand during droughts (i.e. to
reduce it, or attempt to stop it rising further or faster) activities might typically ramp up
through the following levels as a period of dry weather progresses:
• Level 1: General increased messaging and service offerings relating to water
efficiency, asking for users to ‘be mindful’ in their water usage and wastage
particularly related to discretionary activities
• Level 2: Imposition of Temporary Use (Hosepipe) Ban to restrict household
customers from undertaking certain activities with a hosepipe
• Level 3: Imposition of a Non-Essential Use Ban to restrict businesses from using
water for certain activities.
• Level 4: Rota cuts and standpipes, emergency Drought Orders
Other drought actions that wholesalers might undertake to manage demand or supply may
also have implications for businesses and therefore their retailers – these could include
network pressure reductions or changing water sources to a supply area that could alter
water quality parameters.
Research with a broadly representative sample of over 700 businesses and self-suppliers
undertaken by the RWG Water Efficiency Sub Group in summer 20215 found the following
points of relevance:
• Awareness of the increasing risk of future water shortages linked to population
growth, climate change and an increasing need to protect and restore the
environment by abstracting less is mixed – on a scale of 1 to 10 the mean level of
awareness respondents gave was 5.5 out of 10. 47% gave an awareness level of
less than six out of ten. Larger organisations (those with more employees) were only
slightly more likely to be aware of the threat to water resources.
4 https://www.gov.uk/government/publications/drought-managing-water-supply
5 Full results to be published on the MOSL website in Autumn 2021
5
October 2021• More than a third (37%) of respondents thought that water use restrictions like
temporary use bans and non-essential use bans could impact their organisations.
However, only half of these were aware of the threat.
These findings make it clear that business water users need to be better informed of water
security issues and the potential impacts of drought management.
The Task and Finish Group arrived at the following recommendations and points for
consideration to better involve retailers in drought planning:
• Wholesalers should engage with retailers and self-suppliers during the development
of their Drought Plans to identify to the potential implications for retailers and
business customers of the demand and supply actions in their drought plans. The
recent round of draft Drought Plans were submitted in March 2021 and so if not
already done, the opportunity to engage retailers in the pre-consultation phase has
passed. Some wholesalers may have an opportunity to engage with retailers and
self-suppliers before final plans are submitted. Outside of the formal consultation
process though wholesalers can inform retailers of their Drought Plans and the
implications for them and their customers.
• Of key importance is how information on the current and near future resource
position and its implications for retailers and their customers is communicated from
wholesalers to retailers and self-suppliers. As a period of dry weather evolves the
importance of clear and timely information exchange between parties will grow. Each
wholesaler can distribute information to all retailers that operate in their geographical
area (as per the Communications Plan contained in their Drought Plans). It should
however be recognised that engaging with and responding appropriately to this
information – which each wholesaler is likely to publish in different formats and at
different frequencies – is likely to be challenging and a potential barrier to effective
engagement with retailers and self-suppliers. This in turn may reduce the likelihood
of effective messaging reaching the business end users. The Task and Finish group
discussed the need to develop a centralised portal or information sharing system to
facilitate clear and timely engagement and collaboration between wholesalers and
retailers for drought management. This could include a site to publish current and
forecast water resource position information and implications for business users. To
support this the group recommended at least an annual event for wholesalers,
retailers and self-suppliers in February or March each year to share information on
the forecast resource situation by wholesaler area or by region for the coming
summer. Further sessions could be held depending on how the water resource
situation evolved in each year to maintain timely information exchange when it’s
needed most. These outputs were beyond the scope of activities defined in in the
Action Plan but will be considered by the RWG Water Efficiency Steering Group for
inclusion in future workstreams.
Following the drought in 2018 the Environment Agency held lessons learnt workshops
involving various parties including wholesalers and retailers. Some of the key points
recorded from these sessions are useful to draw upon now:
• There needs to be clear roles and responsibilities for who talks to who. Consensus
in the group was wholesaler to retailer to customer.
• Important that the retailers communicate the correct message to their customers.
6
October 2021• Early communication allows customers to plan. Need to talk early to critical users,
such as livestock farmers, priority customers and services. In the past the traffic light
system has worked well.
• Water company drought plans should reflect how the company will communicate with
retailers.
• Clarity and consistency between retailers and wholesalers water savings messages
would be helpful. Best practice messages for different customer groups are required.
• There needs to be better feedback between retailers and wholesalers – have the
messages had an impact?
• Go to companies and then the message filters down to the employees - same with
Schools – opportunity for wholesaler-retailer collaboration.
7
October 20214 Baseline demand forecasting
4.1 Principles of engagement between wholesalers and retailers
The preparation of a baseline non-household demand 25-year forecast is a core component
of a WRMP. The baseline planning scenario should forecast customer consumption without
any water company intervention. Section 6 of the Water Resources Planning Guidelines sets
out regulatory expectations for forecasting assumptions and technical methods – these items
are out of scope of this guidance document.
The preparation of the non-household demand forecast is the responsibility of wholesalers
under their statutory duty to prepare and maintain a WRMP.
Section 4.2 below sets out the data that is available via MOSL now and a road map to
further data publications that can be used to support the preparation of non-household
demand forecasts for WRMP24.
Wholesalers should give retailers and self-suppliers the opportunity to feed into the
development of their demand forecast, but not all retailers will be able to contribute so this
should not be seen as a requirement of retailers. A route to engage, but with no requirement
to do so, could be provided if Wholesalers notify retailers and self-suppliers as they are
developing the forecast and invite submissions of insight within a reasonable time frame.
Under the Wholesale Retail Code, Retailers are expected to support wholesalers with the
preparation of long terms plans, for example with the provision of information from non-
household customers about projected future consumption where this is ‘reasonably
requested’. A key factor that will affect the ‘reasonableness’ of requests is the varying
capacity of Retailers to provide support, because Retailers significantly vary in size and
maturity. Wholesalers should be mindful of this and engage with Retailers in their operating
area at an early stage to understand what support can be given. Retailers should equally be
mindful of their obligations to provide support where this is requested in a timely way.
Wholesalers should only engagement directly with business water users where this has
been agreed with the retailer first.
4.2 MOSL data availability and road map
MOSL, as market operator, should be considered the first point of contact for water
companies, the five water resource regional planning groups, and Natural Resource Wales
to obtain market data and insight on the NHH market for demand forecasting. This includes
formal code defined data that is held in CMOS (Central Market Operating System), defined
in CSD0301 Data Catalogue6 and enriched CMOS data that is an output of MOSL’s Data
Insight improvement programme7 and other work underway to support delivery of the RWG’s
Water Efficiency Action Plan – and specifically Headline Action 2 on the ‘smarter use and
better sharing of data’.
6 https://mosl.co.uk/document/market-codes/3802-csd-0301-v14-0/file
7 https://businessplan.mosl.co.uk/data-insight
8
October 2021MOSL is working to improve the market’s understanding of when, where, how and why water
services are consumed through enrichment, analysis and visualisation of NHH CMOS data
so as to drive improved decisions and best outcomes for customers. Some of the outputs
from this work are available to use now, some will continue to be developed over the next
three years – this is set put in section 4.2.3.
4.2.1 Data enrichment and analysis
Data insight has focussed on improving the market’s understanding of consumption,
geographical context, carbon emissions and customer insight.
Enriched data is available to share for each of these areas:
• Consumption – SPIDs (Supply Point Identifiers) enriched with best view of
consumption from most up to date view of settlement available for 2019 and 2020.
Further work in 2021 to incorporate unplanned settlement runs (USRs) occurring
after the final planned settlement run (RF) into this analysis
• Context – CMOS meter point locations enriched with the region, Water Stressed
Areas (WSA, if wholly or mainly in England), and water resource zone (WRZ) they
are located within and further attributes on forecast water deficit from WRMP 2019
submissions and EA Water Stress Area designations
• Carbon – Consumption linked to carbon emission data for operational water and
sewerage treatment provided annually by water companies
• Customer – initial proof of concept matched CMOS premises name and address to
external datasets from Companies House and Valuation Office Agency to get
indicative SIC level division (Standard Industrial Classification on Economic
Activities). Further work on targeted sector analysis and enduring “fix from centre”
solution being proposed by MOSL in 2022.
9
October 20214.2.2 Data visualisation and sharing
It is intended that water companies, regional water resources groups, and retailers use the
data visualisation tools and data extracts provided by MOSL to support demand planning
and work together as follows:
1. Refer to same aggregate views on MOSL Water Efficiency Dashboard
The Water Efficiency Dashboard8 is intended as an initial guide to enable organisations to
connect and start discussions on how they can work together on NHH demand planning.
The Water Efficiency Dashboard released on the MOSL Portal in August 2021 was made
publicly available in September 2021.
The dashboard provides an aggregate view of NHH SPIDs and consumption and allows
users to interactively filter by wholesaler, retailer and further enriched data such as water
resource region, water stressed areas, water resource zones and an indication of SIC
division industry type – see example screen shot below.
Please note that this screen shot is provided as an example for illustrative purposes only – for up-to-
date information please visit the MOSL website.
The information can be used by all parties to help facilitate targeted discussions around
demand forecasting and collaborative customer engagement.
To support understanding, interactive maps giving a national view of regional Water
Resource planning groups, Water Stress Areas and Water Resource Zone boundaries along
with summary attributes can also be found on the MOSL website9 (example below).
8 https://mosl.co.uk/chart/chartitems/water-efficiency
9 https://mosl.co.uk/market-insight/market-performance/environmental-impact
10
October 2021Please note that this screen shot is provided as an example for illustrative purposes only – for up-to-
date information please visit the MOSL website.
2. Refer to same enriched CMOS supply point level data extracts to support more
targeted discussions on demand planning
SPID level enriched CMOS data is available to authorised users on the MOSL Portal, Water
Efficiency Data Base ‘Raw Data’ tab: https://portal.mosl.co.uk/Portal/Login/Login
Wholesalers and Retailers can request access to the MOSL Portal and the Water Efficiency
Data Base with the ‘Raw Data’ tab via their organisation’s nominated Contract Manager
listed on the MOSL website here10
SPID level raw data can be provided to owning retailers and wholesalers or regional groups
via a dedicated MOSL SharePoint site, subject to the regional group or individual wholesaler
signing the relevant MOSL data sharing agreements. Access can be requested to these
SharePoint sites and the enriched SPID level by emailing ITsupport@mosl.co.uk
4.2.3 MOSL data insight roadmap
Market data continues to be improved and enriched and new visualisations will be made
available. The following gives an indication of future work that could support water resource
demand planning and high-level delivery timescales – subject to market agreement and
detailed planning.
10 https://mosl.co.uk/about/our-members
11
October 202112 October 2021
5 Mechanisms to facilitate collaboration in NHH water
efficiency in WRMP24
The joint Ofwat and Environment Agency letter sent on 17 March 2020 sent to all licensed
wholesalers and retailers in England stated a request for wholesalers and retailers to “work
together to develop and deliver WRMPs 2024 that deliver significantly improved levels of
water efficiency in the business sector”.
Section 1.1 of this note set out the RWG WE Group’s road map and vision for change that
will support the delivery of more water efficiency in the non-household sector over the short,
medium and long term. At the time of writing this note it is not known which of these
proposed changes to the incentives and supporting frameworks will be in place for the start
of the next WRMP delivery period commencing in 2025/26 or indeed the roll out and pace of
change thereafter. Given this uncertainty, it is recommended that wholesalers develop
WRMPs for 2024 that have regard for existing frameworks of non-household water efficiency
but also consider the applicability of any proposals as the road map is implemented. This is
somewhat akin to the overarching ‘adaptive planning’ objectives of the WRMPs.
Non-household water efficiency can be delivered via a variety of different option types
including business audits, device retrofits and plumbing loss fixes, behavioural engagement,
site process efficiency review and site leakage reduction measures. The purpose of this
guidance is not to compare the relative savings and cost efficiencies of these delivery
activities but to outline the potential mechanisms for collaborative delivery with retailers and
self-suppliers for WRMP 2024 in accordance with the aims of the RWG Action Plan.
The Task and Finish Group involved in developing this guidance generated the following list
of mechanisms for collaboration. It is not intended to be an exhaustive list or to stifle
innovation if wholesalers and retailers wish to develop other collaborative mechanisms.
Mechanism Description
Bid Assessment Frameworks Retailer or other third-party submissions to wholesaler
Bid Assessment Frameworks
Incentive schemes Wholesaler invitations to retailers or other third parties
to apply to a wholesaler fund to cover all/part of the
costs of delivery
Joint education/awareness Collaboration between wholesalers and retailers to
campaigns strengthen the reach of campaigns by sharing
expertise and relationships
Retailer-facilitated and/or Retailers promote wholesaler led activities to business
supported wholesaler delivery customers, or wholesalers offer these directly to
customers where this is supported by the retailer
Auctions Online marketplace for retailers and other third parties
to make bids to deliver water efficiency activity to see if
the price they want is likely to be paid – e.g. the
Entrade model11
11 https://www.entrade.co.uk/
13
October 2021National projects e.g. Collaborative projects that target specific customer
Department of Education project types or issue (e.g. leaky loos) and involve multiple
for schools wholesalers and retailers
The group then voted to select three mechanisms to discuss and develop further – the use
of Bid Assessment Frameworks, incentive schemes and joint education and awareness
raising – and these are described below in 5.1 to 5.3.
5.1 Bid Assessment Framework opportunities
Ofwat requires that all wholesaler water companies produce a Bid Assessment Framework
(BAF) to support the bidding market for water resources, demand management and leakage
services. The aim of a BAF is to stimulate third party bids and solutions to meet future water
needs and other outcomes by setting out how bids will be assessed in the context of key
procurement principles.
In the context on non-household water efficiency therefore, the BAF provides a mechanism
for wholesalers to publish their need for non-household demand reduction – and for retailers,
and indeed other third parties, in the market to makes bids to supply non-household water
efficiency services.
It is recommended that wholesalers consider the following points to facilitate retailer
engagement and collaboration in the BAF process:
• Retailer customer bases are not fixed. Although many still have most of their
customer book inherited at market opening, customers could switch away at any
time. For a retailer, the most confidence they have of future customer base is where
they have customers on a fixed term contract. 3-year contracts are fairly typical and
not many retailers offer longer contracts as customers prefer not to be tied in for too
long. This is important to consider in the framing of the wholesaler statement of need
for demand reduction; retailers might be more encouraged to participate if option
delivery could occur in relatively short-term blocks and are not tied to too small a
geographical area.
• The assumption at market opening was that customers would be willing to pay for
water efficiency services – which has so far proved to be largely wrong, although that
may be expected to change as the road map is rolled out and more customer
incentives for water saving are implemented. It would be up to retailers and other
third parties in the market to define the specifications of their bids but using the BAF
doesn’t necessarily mean wholesalers fully fund the activity and businesses receive
the service for free. Parties could bid for funding to deliver water efficiency on a
subsidised basis – with the wholesaler funding the subsidy. This would be cheaper
for the wholesaler than doing direct delivery free to the customer, could enable
retailers to take more action, and the customer receives a subsidised service
delivered through a competitive market model.
5.2 Incentive schemes
Incentive schemes are a mechanism for wholesalers to financially incentivise retailers to
work with their business customers to reduce demand. In general terms the approach
involves wholesalers specifying the need and location for demand reduction and that
incentive payments will be made to retailers who participate if they do so within the terms
14
October 2021specified by the wholesaler for the scheme. Terms may include: the incentive rate payment
per unit of water saved, any caps to payments, timescales for submissions to the scheme,
evidence of water saving requirements and calculation methods.
The Severn Trent Water Water Efficiency Incentive Trial Scheme in 202112 can be reviewed
as a case study of this approach and the United Utilities Vacancy Incentive scheme13 also
serves as a useful test of wholesalers stimulating desired retailer activities through
wholesaler defined incentive schemes.
The RWG WE Group recognises that there are modifications to the existing examples of
incentive schemes that could be made to encourage greater participation of retailers in this
mechanism, but these examples are a step towards greater collaboration between parties
that sits comfortably within existing and likely future frameworks for collaboration.
The development of a standardised incentive scheme framework to for wholesalers to follow,
as per the Vacancy Incentive Scheme Guidance published by MOSL will be considered by
the RWG WE Group for inclusion the future work programme of the group. Setting out a
common framework helps to ensure consistency in eligibility and processes.
In the current absence of an industry framework, it is recommended that wholesalers
consider the following points in developing a non-household water efficiency incentive
scheme:
• Specification and eligibility criteria:
o Location – water resource zones or other defined areas or regions
o Preferences for customer types if applicable – e.g. preferred SPIDS list, or
business sectors or customer usage thresholds.
o Type of demand reduction sought, i.e. is there a preference for average
demand or peak demand reductions.
o Timescales for demand reductions to be delivered by.
o Requirements for evidence and measurement of water savings.
• Timescales for retailer submissions following publication of requirements – allow
ample time for bids to be compiled and submitted.
• Simplicity of processes, procedures and timeliness for payment and administration of
the scheme. Schemes that are too complex are likely to hinder retailer involvement.
5.3 Joint education/awareness campaigns
Both wholesalers and retailers have a statutory duty to promote water efficiency. Retailers
however own the relationship with non-household customers, as such they should be taking
a leading role in direct communications or campaigns.
In cases of drought and/or short-term water supply resilience issues which may cause
wholesalers to request all water users for restraint in their usage, sometimes with operational
urgency, retailers should at least be made aware of any non-household engagement
initiatives in advance of the activity. See also Section 3 on drought planning. It is also
12 https://www.stwater.co.uk/businesses/retailers/
13 https://www.unitedutilities.com/Business-services/retailers/incentive-schemes/vacancy-incentive/
15
October 2021impossible to isolate businesses from messaging in general water efficiency campaigns run
by wholesalers to target household customers.
A joined-up approach to education and awareness initiatives between wholesalers and
retailers has the potential to deliver great benefits, particularly where programmes are
designed to appropriately draw upon each party’s resources, knowledge, and relationships.
Below are some examples of how collaborative education and awareness raising can work
in practice.
Geographic area campaigns
Retailers can ‘piggy-back’ on wholesaler initiatives and campaigns in specific areas to
facilitate direct engagement with non-household customers, and augment and enhance
messages with specific business messaging and campaigns. Although postponed due to
Covid, an example of this is on the Isle of Arran, which frequently experiences supply and
demand issues during peak tourist periods. Education and awareness campaigns and local
talks were planned with joint representation from Scottish Water and third parties (including
retailers and environmental groups), reaching both local residents, businesses and tourists
on the island. In addition to media campaigns, physical presence was also planned from
Business Stream to speak to businesses directly and carry out field-based activities such as
checking for leakage or meter issues to support demand reduction.
Targeting specific customers, i.e. high consumers in water stressed areas
Where wholesalers have drivers in specific water stressed areas, top consumers can be
identified and targeted for raising awareness, as well as offering further interventions to
reduce usage. This requires collaboration with the respective retailers to engage their
customers. An example of this is currently being piloted in Hampshire as part of the recent
MOSL/Isle study, where Southern Water are providing funding for water audits and
subsequent interventions, which is being combined with educational talks and promotional
material. Two customers have been identified – a high school and student accommodation.
The retailer and wholesaler will work together to develop a business case to prove benefits
with the intention of applying similar interventions on a wider scale, working with local
authorities to implement in other schools, and with the university to apply in other student
accommodation in the area. These business cases can also be utilised by the retailer to
demonstrate benefits to other similar customers to replicate on a wider scale.
Train-the-trainer events
Retailer driven campaigns with willing customers provide an opportunity for broad reaching
education initiatives. Examples include national supermarkets who are keen to engage in
education campaigns for both employees and customers in store, which can benefit
businesses in terms of reducing wastage (and associated costs and environmental impacts)
as well as messages that can be taken home to deliver wider savings in the household
sector. Collaboration with wholesalers can help to provide knowledge expertise to train
trainers within non household organisations, and jointly branded collateral can educate on
how to save water while also raising brand awareness in an environmentally positive
manner.
16
October 2021National / international events
Events such as Water Saving Week, World Water Day and World Toilet Day provide an
opportunity for joint awareness campaigns. There is already a great deal of collaboration
between wholesalers and environmental groups in relation to such events, with a heavy
focus on domestic consumption. It would be entirely feasible for retailers to participate in
these engagement activities to expand the reach to non-household customers.
17
October 20216 Metering
Improvements to non-household water consumption metering has been identified as a key
enabler to support further water efficiency initiatives. Many trading parties have expressed
concern over the inadequate performance of metering assets and metering process to
deliver cost efficient and robust services in the market. Metering has been identified as a
root cause of a number of issues in the market, leading to a poorer customer service,
inaccurate bills and limited water efficiency uptake.
In response to these issues MOSL are currently leading work on a Strategic Metering
Review14 as a key improvement programme that is due to be completed in 2024. The
programme seeks to identify and implement a programme of metering-related improvement
initiatives with a focus on accurate and timely consumption data.
The programme of work will focus on four key areas:
• A series of 'quick-start' projects that will develop solutions and change proposal to
resolve some immediate issues facing the market (see below)
• A range of detailed projects developed with the Metering Committee that will address
issues relating to incentives and behaviour, technology and data quality
• Associated operational strengthening through better use of existing procedures and
processes to improve performance on issues such as long unread meters
• More strategic initiatives that could introduce change into the market including a
review of asset ownership and responsibilities for market activities and how to
introduce new technology such as smart metering.
7 Concluding remarks
The roadmap for change set out in Section 1.1 highlighted that the current barriers, enablers
and frameworks for non-household water efficiency are likely to be subject to change in the
short, medium and long term as all parties work together to deliver greater water savings in
the sector.
It is likely that as the delivery of the roadmap progresses that the guidance to support retailer
involvement in water resources planning will evolve too.
The packages of work identified in this guidance as requiring further development to facilitate
greater and more successful collaboration between wholesalers, retailers and self-suppliers
will now be considered by the Water Efficiency Steering Group for the next work programme.
14https://mosl.co.uk/services/market-improvement/programmes-and-projects/strategic-metering-
review
18
October 2021You can also read
