Ilkley Clean River – Response to Ofwat’s Price Review 2024 Consultation

Our Overall Position on the Draft Determination

  1. We support this investment by a Yorkshire Water to provide basic treatment of our sewage in Ilkley and at the same time creating the example for how all sewage works across the country should operate.
  2. However, it should have been implemented as part of the company’s ongoing maintenance and improvement programme. All the proposal does is to ensure that there is a better degree of compliance with the law at Ilkley. We do not think customers should pay for the scandalous behaviour of water companies in the past, self-certifying compliance and the quality of infrastructure, which we now find to be woefully inadequate and a smokescreen for profiteering. Water companies have created scandalous pollution that is damaging our environment, and they should pay to clean it up.
  3. We do not agree with the proposal that water companies should improve infrastructure ( e.g. number of sewer collapses, burst pipes) rather than ensuring infrastructure does not fail in the first place.
  4. We are concerned that the regulators are not joined up in their regulation against the law, with confusion between regulators on
    1. the legal limit of storm overflows and the quality of treated effluent.
    2. their support for solutions (Ofwat and Defra supporting nature-based solutions, the Environment Agency blocking the NB solutions for Ilkley because they don’t know how to permit it).
  5. We do not think the customer should be paying up front when Ofwat does not have the capacity to claw back underspend. Ofwat is not currently able to monitor spend on investments to assess whether projects in progress or completed are within or lower than predicted spend and is finding multiple examples of projects not meeting deadlines for completion.
  6. We do not agree that the plans are ambitious, and the regulation is tough enough. We do not agree with the tolerance of illegal pollution embedded in the Determination, with compliance to increase by 44% only, when our rivers lakes and seas are being so damaged by pollution. Enforcement cases against several water companies are ongoing and yet Ofwat proposes to reward these companies by allowing bills to increase. No water company that has deteriorating performance, that is operating illegally should be permitted to increase bills. No water company should be paying bonuses to any director whilst it is not operating to contractual performance and is acting illegally. Yorkshire Water has been downgraded to Level 2 whilst the CEO takes a bonus, ‘improvements’ are unambitious compared to water companies in other countries, and bills are set to rise by £107pa before inflation. This is not tough regulation.

You can read the full submission here

Ilkley Clean River PR24 Formal Response