CAS submission to the Scottish Government’s ‘Investing in and paying for your water services from 2021’ consultation

The consultation seeks views on drafts of the two statutory inputs Scottish Ministers must make to the Strategic Review of Water Charges for the regulatory period 2021-2027 - the Principles of Charging statement and the Investment Direction. These provide the general policy framework which will guide the detailed work on the strategic review by the Water Industry Commission for Scotland and Scottish Water.

Key points made include:

• CAS supports the policy direction proposed in the consultation  but also acknowledges that the water industry will face many challenges in the 2021-2027 regulatory period and must ensure that it continues to provide affordable charges and stability for customers.
• CAS broadly agrees with the proposal to reduce the single occupant status discount from 25% to 10%, and use the revenue to improve support for customers facing affordability constraints. However our research has demonstrated some households which may face affordability constraints are not eligible for financial support.
• The current split between developers’ charges and current and future customer charges to fund strategic growth may not be fair to paying customers. CAS therefore welcomes plans to review the current charging model.
• CAS believes that an overarching principle of clear individual and community engagement policy and strong underlying policy would successfully underpin the investment principles.
• Scottish Water’s public ownership model provides it with a unique opportunity to support the delivery of a wide range of environmental, social, community, and economic benefits to Scotland. We would welcome the development of a contract or agreement that commits Scottish Water to supporting the broader public interest.