An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities 0 Reference: CRU/20/041 Date Published: 27/03/2020 Closing Date: 22/05/2020 Irish Water Domestic Customer Handbook Requirements Consultation Paper March 2020 An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities www.cru.ie
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Irish Water Domestic Customer Handbook Requirements
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An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities
0
Reference: CRU/20/041 Date Published:
27/03/2020 Closing Date:
22/05/2020
Irish Water Domestic
Customer Handbook
Requirements
Consultation Paper
March 2020
An Coimisiún um Rialáil Fóntais
Commission for Regulation of Utilities
www.cru.ie
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CRU Mission Statement
The CRU’s mission is to protect the public interest in Water, Energy and Energy Safety.
The CRU is guided by four strategic priorities that sit alongside the core activities we
undertake to deliver in the public interest. These four strategic priorities are:
• Deliver sustainable low-carbon solutions with well-regulated markets and networks;
• Ensure compliance and accountability through best regulatory practice;
• Develop effective communications to support customers and the regulatory process;
and
• Foster and maintain a high-performance culture and organisation to achieve our
vision.
Customer Impact Statement Irish Water is the single national utility responsible for public water and wastewater services in
Ireland. It is tasked with operating, improving and investing in water and wastewater systems
to provide safe, reliable and high-quality Water Services to customers. The CRU’s role in
regulating Irish Water is established in the Water Services (No. 2) Act 2013, which sets out the
CRU’s key functions and powers as economic regulator of Irish Water.
One of the critical functions of the CRU is to protect the interests of customers and ensure that
customers of Irish Water receive a high quality of service from the utility. This is achieved
through setting minimum standards which Irish Water must offer its customers. These
customer standards are published in the ‘Irish Water Domestic Customer Handbook’,
developed by the CRU. The Customer Handbook sets out requirements to which Irish Water
must adhere when providing water and wastewater services to customers. The Handbook was
first published in 2014 and the CRU considers this an appropriate time to review the
document, reconsider the requirements and, where appropriate, update it and recommend
new obligations to refresh and enhance the approach taken to customer protection.
By reviewing the Handbook, the CRU ensures that customers continue to receive a high-
quality service, and that where required, the provision of these services is improved. In this
paper, the CRU outlines how and why it has proposed amendments and how this could impact
customers.
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Executive Summary The CRU is responsible for protecting the interests of customers and ensuring that customers
of Irish Water receive a high quality of service from the utility. This is achieved through setting
minimum standards which Irish Water is obliged to offer its customers, in accordance with the
Water Services (No. 2) Act 2013. These customer standards are published in the ‘Irish Water
Domestic Customer Handbook’, developed by the CRU. The Customer Handbook sets out
requirements to which Irish Water must adhere when providing water and wastewater services
to customers. Within the Handbook, the CRU set out those requirements under three main
sections – the Customer Charter, the Codes of Practice and Terms and Conditions.
Over the past five years the CRU has monitored Irish Water’s performance and how it delivers
for its customers. The CRU receives Domestic Customer Handbook quarterly reports which
outline Irish Water’s contacts with customers and its performance on complaint handling, water
quality and other areas. The CRU also monitors Irish Water’s compliance with the Domestic
Customer Handbook and its performance under the Performance Assessment Framework
metrics. Such activities provide the CRU with insights into how Irish Water performs in areas
such as complaints handling and dealing with customers and vulnerable customers during
interruptions to water supply. Through its Customer Care function, the CRU also forms a view
on how the Handbook could be updated to further protect the interests of customers.
The CRU is now consulting on amendments to the service level requirements of the Domestic
Customer Handbook. The purpose of these amendments is to strengthen the standards of
service Irish Water is obliged to provide to its domestic customers and ensure that they are fit
for purpose and appropriate for customers.
The CRU proposes measures such as amending some Customer Charter commitments and
introducing new charter commitments. It also proposes to strengthen the Handbook by
introducing additional requirements in some sections. The CRU is of the view that the
proposals will improve Irish Water’s engagement with customers during its complaints
resolution process and will ensure that, where required, Irish Water will escalate customers’
complaints to the CRU in a more efficient manner. The CRU considers that the proposals
provide vulnerable customers with increased protection, particularly those that require
alternative methods of communication or those that wish to be represented by a third party.
The CRU also considers that the amendments will lead to improved customer service in
metering, billing and network operations and offer additional protection where customers have
queries regarding pipework ownership.
In its review of the Handbook, the CRU has engaged with regulators in other jurisdictions to
understand how their approach to regulation has been evolving. In keeping with the approach
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taken in other jurisdictions (and with the CRU’s Energy Suppliers Handbook), the CRU has
proposed a set of “Overarching Principles” to which Irish Water must abide. It also proposes to
increase the customer charter payment amount (from a minimum €10 to a minimum €30) and
to introduce a penalty for late payment of charter payments (€15) for Irish Water. Applying
best-practice regulation ensures water customers in Ireland receive the same standard of
protection as seen in other jurisdictions.
The CRU has also improved the wording, structure and clarity of the Domestic Customer
Handbook since it was last published. This includes reordering some requirements, improving
readability by splitting lengthy requirements into separate shorter requirements or aligning
definitions set out in the Handbook with those in the published Water Charges Plan. This
enhances the Handbook as a more customer-facing and easy to understand document. These
changes should assist customers’ awareness and understanding of how the Handbook
protects the interest of Irish Water’s customers.
By reviewing the Handbook, the CRU ensures that customers continue to receive a high-
quality service, and that where required, the provision of these services is improved. By
consulting on the Handbook requirements, the CRU seeks to garner views on the proposals
and involve Irish Water’s customers and stakeholder groups in the process.
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The CRU’s proposed amendments are summarised in the table below:
Summary of CRU Proposals
Handbook Section CRU Proposal
Introduction • Including “Overarching Principles” in the Handbook to
guide Irish Water’s overall obligations to abide by in all its
interactions with customers.
• Introducing a new “Implementation Date” section to
provide clarity as to the date(s) of the new and amended
Handbook requirements coming into force.
Customer Charter
• Increasing the charter payment penalty from a minimum
of €10 to a minimum of €30 where Irish Water fails to
meet a charter commitment.
• Introducing a late payment penalty of €15 if Irish Water
fails to issue a charter payment to customers within six
weeks of the award being determined by Irish Water.
• Introducing new Customer Charter Commitments, i.e.
setting timeframes for Irish Water’s complaints handling
and resolving queries relating to pipework ownership,
undertaking leak investigations and repairing leaks under
the First Fix Free Scheme.
• Expanding Customer Charter Commitments to reflect the
CRU’s decision on the First Fix Free Scheme in 2015, i.e.
a new policy decision not previously reflected in the
Handbook.
• Amending Customer Charter Commitments to reflect the
CRU’s decision on Excess Use Charges.
• Introducing new requirements obliging Irish Water to
promote and increase awareness of the Customer
Charter.
Code of Practice on
Communication with • Introducing a new requirement relating to information that
Irish Water must provide to customers. The requirement
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Handbook Section CRU Proposal
Domestic Customers reflects the CRU’s recent decision on Excess Use
Charges. This includes providing detail on how the policy
works and practical information and advice on water
conservation.
• Amending a requirement relating to planned interruptions
to specify that Irish Water is obliged to communicate
updates to customers that Irish Water anticipates will be
affected during the planned interruption.
• Amending a requirement relating to unplanned
interruptions to set out a timeframe (proposed two hours)
in which Irish Water must inform customers of an
unplanned interruption in their area after Irish Water
became aware of the interruption.
• Amending a requirement which obliges Irish Water to
identify themselves in the “text” of an SMS when
contacting customers by SMS by making the requirement
more general.
• Removing requirements and introducing new sub-sections
to the Code to reflect the CRU’s decision on Excess Use
Charges.
• Amending a requirement relating to Irish Water providing
customers with its Terms and Conditions.
• Amending a requirement relating to billing frequency to
reflect the introduction of Excess Use Charges.
• Introducing a new requirement obliging Irish Water to
inform customers if it identifies a leak at a customer’s
premises.
Code of Practice on
Metering • Reducing the proposed notification period Irish Water
must give a customer when installing a meter from two
weeks to two days.
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Handbook Section CRU Proposal
• Introducing a new requirement which sets out a timeframe
for Irish Water to follow when unmetered customers
request to have a meter installed.
• Amending a requirement relating to damage to customer’s
premises that occurred as a result of meter installation.
• Introducing a new requirement that obliges Irish Water to
upon customer’s request, assist customers in locating a
meter on their premises.
Code of Practice on
Billing • Introducing an overarching requirement which sets out the
CRU’s high-level expectations from Irish Water in relation
to billing.
• Amending a requirement about billing frequency and
billing methods to a more general statement so that the
requirement can relate to all bills that Irish Water issues to
customers.
• Amending a requirement relating to billing calculations.
• Amending a requirement relating to billing methods and
billing timeframes.
• Removing two requirements to reflect the CRU’s decision
on Excess Use Charges.
• Amending a requirement that obliges Irish Water to allow
customers to nominate a third party when dealing with
their bills.
• Introducing a new requirement relating to a high-level
expectations regarding information that Irish Water must
provide on customer’s bills.
• Removing a requirement relating to Irish Water providing
customers with a notification when customers are paying
their bills by direct debit.
• Amending a requirement relating to historical data that
Irish Water must include on bills.
• Amending a requirement that obliges Irish Water to
display capped and fixed charges to customers.
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Handbook Section CRU Proposal
• Amending a requirement relating to Irish Water notifying
customers of charges applicable to them.
• Removing a requirement relating to payment options to
reflect the introduction of Excess Use Charges.
• Removing a requirement relating to customers paying bills
by direct debit.
Code of Practice on
Vulnerable Domestic
Customers
• Introducing a new requirement relating to Irish Water’s
compliance with the GDPR legislation when dealing with
vulnerable customers.
• Introducing new requirements relating to communication
methods for vulnerable customers and enabling
customers to nominate a third-party representative who
can contact Irish Water on their behalf.
• Amending a requirement relating to information that Irish
Water must report to the CRU.
Code of Practice on
Networks Operations
• Introducing new requirements that oblige Irish Water to
inform customers of processes Irish Water has in place for
unplanned interruptions and emergency events.
• Amending a requirement relating to asset flooding to
distinguish between internal and external asset flooding.
This allows Irish Water a greater amount of time (24
hours) by which it must respond to an external asset
flooding incident. Internal asset flooding response time is
proposed to remain the same, at four hours.
Code of Practice on
Complaints Handling
• Introducing a new requirement relating to clarification on
complaint escalation to the CRU.
• Amending a requirement for Irish Water to make
customers with a complaint aware of its Code of Practice
on Complaints Handling.
• Introducing a new requirement for Irish Water to provide
customers with an update on the progress of their
complaint.
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Handbook Section CRU Proposal
• Introducing a new requirement for Irish Water to provide
customers with information on how they can escalate their
complaints.
• Introducing a new requirement for Irish Water to provide a
timeframe on escalation of customers’ complaints.
• Introducing a new requirement relating to Irish Water
responding to the CRU with a confirmation of Irish Water
implementing the CRU’s Final Decision on a complaint.
Terms and Conditions • Introducing a new requirement which obliges Irish Water
to make its terms and conditions available to customers
on its website.
• Removing a requirement that obliges Irish Water to within
their Terms and Conditions, include a letter specifying to
whom the Terms and Conditions are addressed.
Table 1: Summary of CRU’s Proposals
In addition to the above proposals, the CRU is making several editorial changes to the
current requirements in order to make the Handbook clearer, more accessible and easier to
read for customers. The CRU is not consulting on these explicitly as they do not relate to
policy, but they are provided here for completeness.
Other Amendments
Amendment
Type Amendment Detail
CRU’s
Legislative Role • The Handbook now sets out Irish Water’s and the CRU’s role in
relation to the Handbook as outlined in legislation to aid clarity.
Consistency of
Terms Used • All reference to ‘Account Holder’ was removed from the
Handbook, with ‘Customer’ now used consistently throughout. A
definition of ‘Customer’ is now included in the Introduction
section.
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Amendment
Type Amendment Detail
• This section also makes clear that the Handbook requirements
apply to Irish Water and any representative working on behalf of
Irish Water.
• Apply a consistent use of terms to avoid confusion for
customers.
• All references to ‘sign up’ and ‘register’ are removed from the
Handbook as domestic customers, in the context of possible
liability for excess use charges, do not ‘sign up’ or ‘register’ with
Irish Water but rather ‘set up an account’ with Irish Water.
Clarity and
Transparency • In a number of places within the Handbook, lengthy
requirements are split into several shorter requirements to add
clarity and for ease of reading for customers.
• The removal of out-of-date requirements to make ensure that
the Handbook is fit for purpose.
Table 2: Other Requirements
This paper provides a summary of the CRU’s main proposed amendments to the service
standards and seeks views on these proposed amendments. The detail of the CRU’s
proposed amendments to the service standards are set out (via tracked changes) in the Irish
Water Domestic Customer Handbook (CRU/20/040), which is published alongside this paper.
The CRU is seeking views of all interested parties on the proposals herein. Following the
consultation period, the CRU will consider all responses on the proposals. This will shape the
CRU’s decision on the Handbook, which it plans to publish in Q2 2020.
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Table of Contents
Table of Contents ............................................................................... 10
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3. Consultation Proposals and Questions
3.1 Introduction
This section provides a summary of the amendments to the standards of service the CRU is
proposing to make to the existing requirements of the Domestic Customer Handbook. Under
each section, the CRU outlines questions which aim to seek customer’s views on those
proposals.
The CRU is proposing to make the following categories of changes to the Handbook:
• Editorial changes to the current requirements in order to make the Handbook
clearer, more accessible and easier to read for customers and potential customers.
These changes do not have a material impact on the service requirements, but aim
to add clarity by, for example, using clearer language, ensuring consistent use of
terms and dividing lengthy requirements into separate sub-requirements.
• The introduction of additional requirements to strengthen the standards of service
Irish Water is obliged to provide when providing services to its domestic customers.
This includes strengthening existing customer service requirements and adding new
requirements to achieve a higher level of service for customers.
• The removal of out-of-date Handbook requirements to make ensure that the
Handbook is fit for purpose.
The full list of the CRU’s proposed amendments to the customer service requirements are
detailed (via track changes) in the Irish Water Domestic Customer Handbook (CRU/20/040),
which is published alongside this paper.
3.2 Universal Amendments to all Codes – Consistency of
Terms
There are a number of terms used throughout the Handbook. The CRU has reviewed these
with the aim of achieving consistency in use of terms in order to provide greater clarity to the
Handbook requirements. This section sets out the CRU’s proposed amendments to all terms.
As these amendments do not change Irish Water’s customer service obligations, the CRU is
not consulting on these editorial changes. However, they are outlined in this paper for clarity
and to provide context to the changes detailed (via track changes) within the Customer
Handbook document, which is published alongside this paper.
‘Customer’ and ‘Account Holder’
The Domestic Handbook makes a distinction between a ‘Customer’ and an ‘Account Holder’.
A Customer is defined as anyone who utilises water supplied by or wastewater services
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provided by Irish Water at a specific premises, while an Account Holder is an individual who
pays for services supplied by Irish Water to the premises. This distinction is made as certain
Handbook requirements relate to providing services to the occupier of a premises (such as
notifying the occupier of an upcoming interruption of supply, or the existence of a Boil Water
Notice) while other requirements relate to providing services to the individual who pays the bill
for services provided at a premises (such as the requirement to bill accurately and provide
information on tariffs and billing frequencies).
In some instances the customer (who utilises water supplied by or wastewater services
provided by Irish Water) does not pay the bill (in the event of an Excess Use Charge) for the
water service(s) provided at the premises and another party may register with Irish Water as
the account holder and pay for the services on behalf of the customer. An example of this, is
where a landlord (the account holder) pays an Excess Use Charge on behalf of its tenants (the
customer). In most cases, the customer is the account holder, that is, the customer utilises the
water services and also pays for it (in the case that the usage exceeds the allowance amount
and attracts a charge).
There are a number of instances throughout the Handbook where the two terms “customer”
and “account holder” are used interchangeably, and in some instances incorrectly, which may
lead to confusion for customers. For example, many of the requirements in the Billing Code of
Practice reference ‘customer’ when it should reference ‘account holder’ as it is the account
holder who pays the bills. For consistency and clarity purposes the CRU is proposing to
remove all references to “account holder” and replace with “Customer” in all Codes of Practice
in the Irish Water Domestic Customer Handbook.
In order to make this clearer, the CRU is proposing to include the following text in the
Introduction section of the Handbook:
‘Property’ and ‘Premises’
A relatively small number of requirements make reference to either “premises” or “property”.
These terms refer to the same thing, i.e. a customer’s premises as defined in Water Charges
Plan. The two terms are used interchangeably throughout the Handbook. The CRU will use
the term “premises” throughout the Handbook to aid clarity and consistency.
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‘Tariffs’ and ‘Charges’
The Handbook also refers to both ‘charges’ and ‘tariffs’ in a number of places. The CRU is of
the view that it would be clearer to use the term ‘charges’ throughout the Handbook, as both
‘charges’ and ‘tariffs’ refer to the same thing. That is, a charge that Irish Water applies to a
customer for the provision of a service (which could be a charge to connect a customer to the
network, charges for the provision of water services, a charge for testing a meter etc.).
3.3 Introduction Section
The Introduction section of the Handbook presents the purpose and legislative background to
the Handbook. It also lists “Overarching Requirements” that summarise the CRU’s
expectations of Irish Water’s customer services operations.
The full list of the CRU’s proposed amendments to the customer service requirements within
the Introduction Section of the Handbook are detailed (via tracked changes) in the Irish Water
Domestic Customer Handbook (CRU/20/040), which is published alongside this paper. Below
is a description of the CRU’s main proposed amendments to this section.
3.3.1 Implementation Dates of Handbook Requirements (Section 1.1)
The CRU recognises that Irish Water may not be in a position to implement a number of the
new Handbook requirements immediately, for example, due to the need for IT and system
development to support the new service level requirements. The CRU is proposing to insert a
new subsection called ‘Implementation Dates’ to clearly identify the date by which such
Handbook requirements will come into force.
The CRU proposes the following timeframe for the implementation of the CRU’s new and
amended requirements.
CRU Questions
1. Do you agree with the CRU’s proposed amendment to replace all references to “Account Holder” with “Customer” apart from the specified exemptions?
2. Do you agree with the CRU’s proposed amendment to replace “property” with “premises” for consistency purposes?
3. Do you agree with the CRU’s proposed amendment to replace “tariffs” with “charges” for consistency purposes?
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• Obligations which are new and require IT system changes – Irish Water to implement
these requirements no later than 12 months after the date of the CRU’s Decision on
the Irish Water Domestic Customer Handbook.
• Obligations which are new but do not require IT system changes – Irish Water to
implement these requirements no later than 6 months after the date of the CRU’s
Decision on the Irish Water Domestic Customer Handbook.
• Obligations relating to policy decisions which are already in place, (e.g. First Fix Free
Scheme) – Irish Water to implement these requirements immediately.
During the consultation period, the CRU will engage with Irish Water to understand which of
the new requirements fall under each of these timeframes and this will be specified within the
CRU’s Decision on the Handbook. The CRU wishes to strike a balance between providing
Irish Water with sufficient time to implement new Handbook requirements and ensuring that
customers see the benefits of the improved standards of performance as soon as possible.
The CRU expects Irish Water during the consultation period to provide realistic but challenging
timelines to implement the new Handbook requirements that the CRU will review and take into
account when deciding on the implementation dates for the new Handbook requirements.
Please see Section 1.1 in the Irish Water Domestic Customer Handbook for further detail on
the full list of proposed amendments.
3.3.2 Overarching Principles (Section 1.2)
Notwithstanding the CRU’s conclusion that it is not the right time to move to a more ‘principles-
based’ approach for setting the customer service standards which Irish Water must provide to
its customers, the CRU considers that there may be situations that are not covered under the
Handbook requirements that could impact customers. The CRU is of the view that customers
should have a high level of protection in these circumstances. The CRU, therefore, is
proposing to introduce two new overarching principles to this section. These overarching
principles will provide guidance as to how Irish Water should interact with its customers
whether directly or indirectly. They do not relate specifically to any Code of Practice but rather
have a general application to all facets of the customer-utility interactions.
CRU Questions
4. Do you agree with the CRU’s proposed implementation dates? Please provide rationale for your answer.
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These overarching principles serve to further enhance the service level requirements within
the Handbook rather than to replace the existing prescriptive requirements as would be done
under a ‘principles-based’ approach to setting customer service standards.
The CRU is of the view that the introduction of these overarching principles will benefit
customers in their interactions with Irish Water. The principles require that Irish water shall
treat customers in a fair, honest and professional manner and that Irish Water shall ensure
consistency, accuracy and clarity across all its written and oral communications with
customers. Similar overarching principles are in place in the Electricity and Gas Suppliers’
Handbook which provide guidance to how electricity and gas suppliers interact with their
customers. The introduction of these principles into the Irish Water Handbooks (both Domestic
and Non-Domestic) will achieve consistency across the energy and water customers. The
CRU also notes that similar customer service standards are in place in other jurisdictions and
notes that the water regulator in England and Wales, Ofwat, has also introduced similar
principles that water retailers must follow when interacting with their customers.
The overarching principles are as follows:
1. Irish Water shall treat Customers in a fair, honest, transparent, appropriate, reasonable
and professional manner;
2. Irish Water shall ensure consistency, accuracy, clarity and transparency of information
across all means of written and oral communications with Customers. This includes,
but is not limited to, definitions, terms, words used in bills, statements, Terms and
Conditions of Supply, processes and charging documents.
Please see Section 1.2 in the Irish Water Domestic Customer Handbook for further detail on
the full list of proposed amendments.
CRU Questions
5. Do you agree with the CRU’s proposed principles? Please provide rationale for your answer.
6. Are there additional or alternative principles that should be included in the Handbook? Please provide rationale for your answer.
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3.3.3 General Obligations (Section 1.3)
This section sets out “General Obligations” that summarise the CRU’s expectations of Irish
Water’s customer services operations.
Amending a requirement relating to how Irish Water provides information in its
communications with customers
The CRU proposes one minor amendment to a requirement which obliges Irish Water to
provide all communication material to customers in an appropriate format. The amendment is
intended to improve the wording of the obligation by making a separate distinction between
potential Customers and those registered on Irish Water’s priority services register. This
amendment ensures that vulnerable customers are not considered “potential customers” (as
the original wording appeared to suggest).
The exact wording of the CRU’s proposed amendment is as follows:
3.4 Customer Charter
Currently, the Customer Charter sets out minimum commitments where charter payments
apply if service standards are not met. Customer Charter requirements cover areas such as
customer complaints, billing, metering, vulnerable customers, unplanned water interruptions
and boil water notices. Under the customer charter, a customer is entitled to a payment of €10
for each time Irish Water breaches any of the charter commitments. The CRU proposes
amending this section and adding new requirements and customer charter commitments.
The full list of the CRU’s proposed amendments to the customer service requirements and
commitments within the Customer Charter are detailed (via track changes) in the Irish Water
CRU Questions
7. Do you agree with the CRU’s proposed amendment relating to how Irish Water provides information in its communications with customers? Please provide rationale for your answer.
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Domestic Customer Handbook (CRU/20/040), which is published alongside this paper.
Below is a description of the CRU’s principal proposed amendments to this Code.
3.4.1 General Requirements (Section 4.1)
This sub-section of the handbook covers general obligations on how Irish Water should apply
the customer charter and specifies the charter payment amount of €10 which will apply if Irish
Water breaches any of the customer charter commitments.
Increasing the minimum Charter Payment
The CRU proposes to increase the customer charter amount to a minimum of €30. This is
consistent with the minimum charter payment in the energy sector under the CRU’s Energy
Suppliers Handbook. It is also consistent with the charter payment equivalent in other
jurisdictions. The proposed increase reflects Irish Water’s increasing maturity as a utility, over
the past number of years and the desire to challenge Irish Water in its performance for
customers, in a manner similar to other sectors. The CRU envisages Irish Water performing
and treating customers to the same standard as energy suppliers in Ireland and water
companies in the UK.
Furthermore, the CRU’s findings from Irish Water’s quarterly customer handbook reports show
that Irish Water has issued a very low number of charter payments to customers over the past
five years. Below is a graph outlining the trend of customer charter payments issued between
2015 and 2020.
Figure 2: Customer Charter Payments issued to customers by Irish Water
The CRU notes that Irish Water received approximately 12,000 complaints in 2019. The CRU
0
10
20
3 0
40
50
60
70
80
90
2015 2016 2017 2018 2019
nu
mb
er
of C
ha
rte
r p
aym
en
ts
Customer Charter Payments Issued
Number of Charter Payments
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considers that the number of customer charter payments Irish Water issues to customers is
low (i.e. less than 100 per year) when compared to the number of complaints that Irish Water
receives every year. Since a customer has to proactively request a charter payment from Irish
Water, the CRU considers the low value of existing payments may be a factor in the low
numbers of charter payments made, rather than solely reflecting the response level of Irish
Water to complaints received. The low number of charter payments made would also indicate
that an increase in the charter payment would be manageable for the utility while also offering
improved protection to the customer in line with the minimum level offered to, for example, gas
or electricity customers.
The CRU is of the view that €30 is a very reasonable and manageable minimum level for a
utility to grant a customer in the event that the service the customer receives has not met
expectations. The CRU also considers the current level of a minimum of €10 to be low in the
event of an issue that warrants a charter payment. Such a low level, it may be argued, is
inadequate recompense for a customer having taken the time and effort to pursue a complaint
where service levels have not met expectations.
The CRU understands that proportionality of the charter payment to the total annual water
charge was considered when setting the charter payment at €10 in 2014. This was in the
context of a gas or electricity bill being higher than the level of the domestic water charge
(when these were introduced and applicable in the 2014-2016 period). Where a gas or
electricity bill may have been circa €1,000 per annum and an associated charter payment was
€30, the lower proposed domestic water charge in 2014 may have been a factor in the charter
payment being accordingly set lower. The CRU does not consider this to be a strong argument
for retaining a charter payment in the water sector that is one third of the equivalent in gas or
electricity. The customer service obligations of Irish Water’s business should not be linked to
the level of charges that a customer pays. Regardless of what customers pay for water
services they should expect and receive the same service as they would from any other high-
performing utility.
Furthermore, in the CRU’s response to comments paper on its original proposal in August
2014 (see pages 15-16 of (CER/14/365)), it is noted that several responses indicate a high
level of support for charter payments being set even higher than €10. These responses
indicate that the proposed charter payment of €10 is very low. Responses to that consultation
included the following comments:
• €10 payment is not in line with payments made under energy Customer Charters
(e.g. €30); payments made under utility charters should be standardised.
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• a charter payment of €50 would be a significant fine on Irish Water, big enough to be
partially penal and yet not too large for Irish Water to contest (in the courts) every
complaint.
In that decision, the CRU acknowledged that Irish Water was in an early stage of
establishment and considered €10 appropriate. The decision further notes, “However, we will
keep the level of the payment under review over time to ensure that Irish Water is incentivised
to provide an improved customer service standards”.
The CRU now considers it appropriate to raise the charter payment level from €10 to €30.The
exact wording of the CRU’s proposed amendment is outlined below:
Introducing a new requirement relating to a late payment penalty
The CRU proposes to introduce a late payment penalty of €15 where Irish Water fails to issue
a charter payment to the customer within 30 working days. The 30 days is proposed to
commence from the date the Customer confirms all payment details information with Irish
Water.
The CRU is of the view that introducing a late payment penalty will encourage Irish Water to
provide customers with a charter payment promptly, thus, delivering improved customer
service. A late payment penalty is a standard practice in other jurisdictions and the CRU
considers that this proposal will strengthen customer protection measures. The CRU considers
the addition of late payment penalties for customers in the event of a delay in their charter
payment beyond a reasonable duration to be a positive development for customers of Irish
Water. This will act as an incentive for Irish Water to close the charter payment process in an
efficient manner. Furthermore, the CRU considers the 30 working days, i.e. six weeks, rule to
provide sufficient leeway for Irish Water to issue a payment in normal circumstances. The
CRU does not envisage such a length of time to create a significant challenge for Irish Water
while also holding it to a standard level of performance for its customers. The CRU considers
€15, i.e. half of the proposed minimum charter payment to be an appropriate level. The CRU
proposes to keep this under review after it becomes operational to assess its effectiveness as
a customer service measure.
The exact wording of the CRU’s proposed requirement is outlined below:
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Introducing a new requirement relating to promoting the Customer Charter
As discussed above, the CRU is concerned that the lack of knowledge regarding the
availability of charter payments and the level of charter payments is discouraging customers
from seeking this remedy from Irish Water, in the event that Irish Water fails to meet their
charter commitments. The CRU is of the view that Irish Water may need to improve how they
promote the Customer Charter. The CRU proposes to introduce a requirement that would
oblige Irish Water to promote the customer charter and to increase awareness among
customers that charter payments are available in the event that customer service levels fall
below expectations. The CRU considers that putting such a requirement on Irish Water would
contribute to improved customer awareness about their entitlement to charter payments and
how to avail of the payments.
The exact wording of the CRU’s proposed requirement is outlined below:
CRU Questions
8. Do you agree with the CRU’s proposal to increase the customer charter payment amount to a minimum €30? If not, can you explain why you do not agree? If you believe the CRU should propose a different amount, can you indicate what amount that would be and provide reasons for this.
9. Do you agree with the CRU’s proposal to introduce a late payment penalty of €15 in the event of a charter payment not being made within 30 working days of Irish Water receiving payment details from the customer? If not, can you explain why you do not agree and provide an alternative suggestion?
10. Do you agree with the CRU’s proposal to introduce a requirement that would oblige Irish Water to actively promote the customer charter? If not, please provide rationale for your answer.
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3.4.2 Minimum Commitments where Charter Payments Apply (Section 4.2)
This sub-section of the Handbook sets out the customer charter commitments that Irish Water
must follow in their customer services operation.
Introducing new Customer Charter commitments relating to the First Fix Free Scheme
The CRU proposes to add a new commitment relating to First Fix Free Scheme to the
Customer Charter to reflect CRU’s decision on the introduction of the First Fix Scheme in
2015. Under this scheme, customers are eligible for one free fix of a leak on its external supply
pipe, subject to some conditions. This is another interaction between customer and utility
which was not previously covered in the Domestic Handbook and now requires certain
obligations to be placed on Irish Water in delivering the service.
The CRU considers that adding commitments around the First Fix Free Scheme to the
customer charter will ensure that customers wishing to avail of the scheme receive the
appropriate information regarding how to avail of the scheme, information regarding Irish
Water’s obligations to fix leaks in a high-quality standard. Adding such commitments to the
customer charter is also in line with requirements already introduced in other jurisdictions and
is consistent with the scope of other aspects of the Customer Charter.
The exact wording of the proposed new commitment is outlined below:
Introducing new Customer Charter commitments relating to pipework ownership
The CRU has monitored and reported on several aspects of Irish Water’s performance over
the last five years. It is also responsible for resolving customer complaints that are referred to
the CRU. Where a customer complains about a service issue and the complaint cannot be
resolved by Irish Water, it is escalated to the CRU’s Customer Care Team. From experience,
the CRU has seen some recurring issues which customers either have a grievance about or
simply require clarification on. One such area where the CRU has seen a recurring issue is
that of pipework ownership. By virtue of recurring customer referrals, the CRU considers that
there is scope for Irish Water to further improve the way it engages with customers with regard
to pipework ownership.
According to the CRU’s Customer Care Complaint Resolution reports, pipework responsibility
disputes are becoming more frequent. To give one example of this, the CRU’s Customer Care
Team report that a customer contacted the CRU seeking a refund from Irish Water for €175
which the customer had paid to a private company to clear a blocked drain. The customer
insisted the drain in question was Irish Water’s responsibility to maintain and felt he should not
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be out of pocket.
Irish Water is responsible for maintenance of the public wastewater system and will clear any
blockages that occur within the public sewer. Customers are responsible for their internal
plumbing and private side pipework. The customer provided a report from the private company
that removed the blockage, which the customer felt demonstrated that the blockage was on
the public side. Irish Water had its wastewater engineer review this report who confirmed, that
the pipe was a private one and stated that Irish Water was not responsible for reimbursing the
customer for work carried out at his property.
While a resolution to the issue was ultimately determined, this case indicates, at least, that
there is some confusion on the customer side regarding pipework ownership. Considering the
increasing volume of issues relating to pipework clarification, the CRU proposes an additional
commitment that obliges Irish Water to respond to customers’ queries on clarification of
pipework ownership within three working days. The CRU considers that this commitment will
ensure that Irish Water attempts to resolve such issues efficiently.
The exact wording of the proposed new commitment is outlined below:
Introducing new Customer Charter commitments relating to complaints handling
Data that Irish Water submits to CRU on a quarterly basis and the CRU’s Customer Care
Team (CCT) reports indicate that there are aspects of their engagement with customers that
Irish Water needs to improve throughout its complaint resolution process. One specific issue is
around the timeliness of closing out complaints.
According to the Customer Care Team’s 2018 Annual report, a customer contacted the CCT in
relation to damage to their property, which the customer stated was caused by a leak from an
Irish Water mains pipe. In referring the issue to the CRU, the customer explained that they had
been in contact with Irish Water for months in relation to the issue, to no avail. Irish Water had
not provided updates in relation to the matter, the customer had been transferred to several
different Irish Water departments, and no resolution was ever outlined.
According to the Irish Water’s Customer Handbook quarterly reports, Irish Water receives a
high number of complaints categorised as “Customer Case – General Follow-Up” i.e. over 300
in 2019, 300 in 2018 and 200 in 2017. This indicates that Irish Water may need to provide
customers with more regular updates about their complaints.
At the moment, within the customer charter there is one commitment relating to Irish Water’s
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complaints resolution process. This commitment requires Irish Water to resolve customer’s
complaints or advise customers of the plan for the resolution of their complaint within 5
working days. The CRU now proposes to introduce an additional customer charter
commitment that would require Irish Water to provide a customer with an update on their
complaint if their complaint remains open for 10 working days. The CRU expects that such a
commitment would provide an additional protection measure for customers in cases where a
complaint remains open and the Customer feels that Irish Water is not engaging with them
satisfactorily.
The exact wording of the proposed new commitment is outlined below:
Amending Existing Customer Charter commitment relating to meter installation
The CRU proposes to amend a commitment that requires Irish Water to cover the cost of
damage to customers’ property during meter installation in two ways.
Firstly, the obligation is expanded to encompass works carried out under the First Fix Free
Scheme. Again, as stated in proposal above, amending the requirement will allow the CRU to
bring the First Fix Free Scheme decision of 2015 into the Handbook. The CRU now proposes
the commitment to oblige Irish Water to cover the cost of any damage to customer’s property
during meter installation as well as leak investigation and leak repair undertaken as a part of
the First Fix Scheme.
Secondly, the CRU has added the provision that Irish Water will remedy the damage that
occurred as a “direct” result of meter installation, leak investigation or leak repair. This wording
is intended to reflect that while Irish Water is expected to remedy damage and return a
customer’s property to the exact condition that it had been in prior to the works being carried
out, there may be some occasions where, despite its best efforts, e.g. restoring concrete to the
exact colour that it was prior to the works, that may not be possible.
The exact wording of the CRU’s proposed amendment to the commitment is as follows:
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The CRU also proposes to amend a requirement that obliges Irish Water to provide customers
with a notification of meter installation two weeks prior to the meter installation date. The CRU
proposes to amend the required “two weeks” notification to “two days” notification. The CRU is
of the view that since most meter installations will arise due to the metering of newly
constructed properties, the replacement of existing meters, or requests to install meters arising
from Excess Use charges, the customer will have been in prior contact with Irish Water in
advance of the meter installation taking place. Therefore, the CRU considers that there is no
need for such a long period of advanced notification regarding meter installation. The two-
week requirement was initially in place at a time when Irish Water was undertaking a broad roll
out of meters, and the CRU considers that the two days notification is a more appropriate
timeframe for the current situation and level of meter installation.
The exact wording of the CRU’s proposed amendment to the commitment is as follows:
Amending existing Customer Charter commitment relating to unplanned interruptions
The CRU proposes to amend a commitment that relates to contacting Priority Services
Customers during an unplanned interruption to discuss any critical needs they may have in
relation to their water supply.
Since the publication of the Customer Handbook in 2014, in agreement of the CRU, Irish
Water has amended how it contacts vulnerable customers during unplanned interruptions i.e.
from only using telephone calls to also issuing SMS. The main benefit of this change is that
Irish Water issues SMS to all affected vulnerable customers at approximately the same time,
whereas previously Irish Water called all customers individually. In many cases it took a
number of hours before all customers received the information. In some instances, the
problem was resolved by the time all customers were informed of the interruption. Under this
initiative, the default will be for Irish Water to use SMS as the way to communicate with priority
services customers, but a customer has the opportunity to opt out and request that Irish Water
contacts them by phone. However, for those that do receive an SMS, the disadvantage is that
Irish Water can no longer directly discuss with customers any critical water supply needs that
they might have, compared to if the contact had been made by phone. Considering this, the
CRU proposes to amend the wording of this requirement obliging Irish Water to afford all
customers registered on a priority services register with an opportunity to discuss any critical
needs that they may have in relation to their water supply.
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The exact wording of the CRU’s proposed amendment to the commitment is as follows:
Amending existing Customer Charter commitment relating to billing
Lastly, the CRU proposes amending a customer charter commitment regarding Irish Water
obligation to provide customers with accurate bills and that the bills that Irish Water issues to
customers must be in line with the CRU’s Water Charges Plan.
The CRU proposes a minor amendment to the wording of this requirement to reflect the CRU’s
decision on Excess Use Charges. This amendment is effectively to acknowledge that any
recurring domestic customer billing will be in relation to excess use and that these bills will no
longer be issued on a quarterly basis.
The exact wording of the CRU’s proposed amendment to the commitment is as follows:
CRU Questions
11. Do you agree with the CRU’s proposal to amend the customer charter commitments? Please identify which commitment you are referring to and please provide rationale for your answer.
12. Do you agree with the CRU’s proposals to add new commitments to the charter? Please provide rationale for your answer.
13. Are there any further areas where you consider additional minimum charter commitments should be placed on Irish Water? If so, please provide which areas and a detailed rationale for why you consider this to be important.
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3.4.3 Water and Wastewater Quality (Section 4.3)
This section sets out a requirement relating to discounts that customers must receive when
their water is unfit for human consumption.
Amending a requirement relating to discounts for water unfit for human consumption
The CRU is proposing to update this requirement to reflect the CRU’s decision on Excess Use
Charges. The current requirement obliges Irish Water to provide customers with a discount in
cases where customer’s water was unfit for human consumption. In line with the CRU’s recent
decision on Excess Use Charges, Irish Water will not apply Excess Use Charges to customers
for periods during which their water was unfit for human consumption. Charges will be applied
in accordance with the CRU’s decision on the Water Charges Plan.
Please see the exact wording of the CRU’s proposed amendment below:
3.5 Code of Practice on Communication with Domestic
Customers
It is important that all of Irish Water’s communications with its customers are clear, easy to
understand and transparent. The Handbook contains several requirements relating to
customer information provisions which outline the minimum requirements Irish Water is
obliged to meet when it comes to communication with its customers.
CRU Questions
14. Do you agree with the CRU’s proposal to amend the requirement relating to discounts for water that is unfit for human consumption? Please provide rationale for your answer.
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The full list of the CRU’s proposed amendments to the customer service requirements within
the Communications Code of Practice are detailed (via track changes) in the Irish Water
Domestic Customer Handbook (CRU/20/040), which is published alongside this paper.
Below is a description of the CRU’s principal proposed amendments to this Code.
3.5.1 Customer Information Requirements (Section 5.1)
It is important that all of Irish Water’s communications with its customers are clear, easy to
understand and transparent. The Handbook contains several requirements relating to
customer information provisions which outline the minimum requirements Irish Water is
obliged to meet when it comes to communication with its customers.
Adding clarity to a requirement relating to how Irish Water communicates with its
customers
The CRU proposes to add clarity to the requirement that obliges Irish Water’s employees to be
sensitive and take steps to cater for persons inexperience or vulnerability when
communicating information on their services by replacing the term “are sensitive” with “act
empathetically”. The CRU is of the view that the requirement can be more applicable if it
focuses on how an employee or representative of Irish Water acts in certain circumstances. As
adding clarity to this requirement is an editorial change only, the CRU is not consulting on this
requirement.
Reordering requirements relating to information that Irish Water must provide to
customers in its communications
The CRU proposes to reorder some requirements under section 5.2.5 of the Domestic
Customer Handbook that set out the information that Irish Water must provide in its
communication with customers. This amendment aims to add clarity of what is expected
from Irish Water under those requirements. Also, currently, the requirements are not ordered
by topic, for example, requirements relating to pipework ownership were not placed beside
each other whereas now, the requirements are easier to follow. As reordering of
requirements is an editorial change only, the CRU is not consulting on this amendment.
Splitting up lengthy Handbook requirements to aid clarity
In addition to reordering the above requirements, the CRU proposes to simplify some lengthy
Handbook requirements to add clarity to the Handbook. This includes splitting the requirement
which relates to pipework responsibility into separate standalone requirements. The CRU
proposes to do this as the original requirement contained two separate components, one on
pipework responsibility and ownership and the other relating to leakage or an issue with
pipework. Both components are linked by pipework ownership, however the CRU considers it
would benefit customers to split this requirement to more clearly identify the two distinct
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obligations on Irish Water. A corresponding change is proposed for the Non-Domestic
Customer Handbook. As the splitting of a lengthy Handbook requirement is an editorial
change, the CRU is not consulting on the splitting of this requirement.
Introducing New Requirements relating to Excess Use Charges
To reflect the CRU’s 2019 decision regarding. Excess Use Charges, the CRU proposes to
introduce some new requirements relating to Excess Use Charges into the section
“Requirements in Providing Information to Customers”. The CRU is of the view that these new
requirements will be useful for customers to understand how the policy works and increase
awareness of their water usage, enabling customers to become more mindful of the
importance of conservation and their general household usage.
The exact wording of the proposed new requirement is as follows:
3.5.2 Customer Communication During Supply Interruptions and Poor-Quality
Supply Periods (Section 5.3)
Subsection 5.3 of the Handbook outlines the requirements Irish Water must follow when it
comes to customer communications during a supply interruption (planned or unplanned) and
poor-quality supply periods (for example, when a boil water notice is issued). This includes
such things as ensuring regular up-to-date information is available in advance of planned
interruptions, ensuring anticipated affected customers will be notified at least two days in
CRU Questions
15. Do you agree with the CRU’s proposal to introduce new requirements around water conservation and the Household Water Conservation Policy in this section? Please provide rationale for your answer.
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advance of the planned interruptions and ensuring certain information is provided to customers
when notices are issued that declare water unfit for human consumption.
Adding sub-headings to the section
The CRU proposes to split requirements in this section into several sub-sections, to aid
transparency. Such sub-headings include Planned Interruptions”, “Unplanned Interruptions”,
“Water Unfit for Human Consumption” and “Alternative Water Supply Arrangements. As
adding sub-headings to this section is an editorial change, the CRU is not consulting on this
amendment.
Splitting up lengthy Handbook requirements to aid clarity
To simplify some lengthy Handbook requirements, the CRU is proposing to split Handbook
requirement that outlines what communications Irish Water must provide for its domestic
customers in advance of and during planned interruptions into three separate Handbook
requirements. For the same reason, the CRU also proposes to split a lengthy requirement
which relates to notification that Irish Water must provide customers with during unplanned
interruptions. The CRU is of the view that separating those requirements into three stand –
alone requirements will make the requirements easier to understand for customers. As the
splitting of lengthy Handbook requirements is an editorial change, the CRU is not consulting
on the splitting of those requirements.
Adding clarity to a requirement relating to Information provision on planned
interruptions
In addition to splitting the above requirements on planned and unplanned interruptions, the
CRU has amended the wording on the requirement relating to notification of planned
interruptions to add clarity that Irish Water is obliged to communicate updates to customers
that Irish Water anticipates will be affected during the planned interruption. This existing
requirement does not specify to whom Irish Water should provide updates. This is important as
supply interruptions can cause considerable disruption, and affected customers should be
informed in advance of and during a planned interruption, with regular and up-to-date
information regarding the planned timing of the interruption as well as the anticipated time of
supply restoration. As adding clarity to a requirement relating to notification of planned
interruptions is an editorial change, the CRU is not consulting on this amendment.
Adding timeframe to a requirement relating to unplanned interruptions
The proposal to include a timeframe on this requirement is brought about by the CRU’s
analysis of the most frequent issues which lead to customer contacts (complaints) with Irish
Water. Irish Water’s Domestic Customer Handbook quarterly reports, which it provides to the
CRU, indicate that Irish Water receives a significant number of complaints relating to “no
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water”. This would include instances of unplanned interruptions. For example, there were over
2,400 complaints in 2018 and over 2,100 in 2019 relating to “no water”.
In light of this, the CRU proposes to strengthen the obligation on Irish Water by placing a
timeframe on the requirement to inform customers of an unplanned interruption. The CRU
proposes to add to the requirement that Irish Water must as soon as possible and at least two
hours after Irish Water becomes aware of unplanned interruption, inform customers of the
interruption.
The CRU considers that this amendment will introduce additional protection at times when
customers experience unplanned water supply interruptions in their local areas and will
increase customer’s awareness during unplanned interruptions thus decreasing the volumes
of complaints being logged with Irish Water.
Furthermore, currently, the requirement specifies that Irish Water must inform customers of the
anticipated time of restoration of the supply. To add clarity to the information that customers
receive during unplanned interruptions, the CRU proposes to add to the requirement that in
the case of unplanned interruption Irish Water must notify customers of a likely duration of the
interruption. The CRU is of the view that this additional information may be useful and
comforting to a customer during a poor-quality supply period. For clarity, the CRU proposes
that Irish Water informs customers of both the number of days their supply will be out for and
the date by which Irish Water expects supply will return to normal. Once Irish Water has better
information, say for instance an updated date by which they believe supply will return to
normal, the CRU expects that Irish Water would then contact customers to inform them of the
latest information. The CRU considers this an important customer protection measure,
particularly so during periods such as Christmas or Bank Holiday weekends.
The exact wording of the amended requirement is outlined below:
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3.5.3 Customer Communication Through Printed Material (Section 5.4)
This section sets out a requirement which obliges Irish Water to make any relevant printed
material available for customers. This must at minimum include Irish Water’s Customer
Charter, Terms and Conditions and information on any applicable charges.
Removing the word “Potential Customer” from the requirements.
The CRU proposes removing the word “potential customer” from this requirement, as the
definition at the beginning of this Code already outlines that by a “Customer” the CRU refers to
a customer or a potential customer. The CRU is of the view that this will add clarity to the Code
as a whole and avoid confusion. As this amendment is an editorial change, the CRU is not
consulting on this amendment.
3.5.4 Customer Communication by Telephone (Section 5.5)
This section sets out requirements which Irish Water must follow when contacting a customer
by telephone. This ranges from requiring Irish Water to provide an opportunity for customers to
contact Irish Water by phone to setting out hours during which Irish Water must not contact a
customer.
CRU Questions
16. Do you agree with the CRU’s proposal to amend a requirement relating to
unplanned interruptions? Please provide rationale for your answer.
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Removing the word “Potential Customer” from the requirements.
As per above, the CRU proposes removing the word “potential customer” from this
requirement, as the definition at the beginning of this Code already outlines that by a
“Customer” the CRU refers to a customer or a potential customer. The CRU is of the view that
this will add clarity to the Code as a whole and avoid confusion. As adding clarity to this
requirement is an editorial change, the CRU is not consulting on this amendment.
3.5.5 Customer Contact by SMS (Section 5.8)
This section sets out one requirement which Irish Water must follow when contacting
customers by SMS.
Adding flexibility to a requirement relating to Irish Water contacting customers by
SMS
The CRU proposes to remove the provision for Irish Water to identify themselves in the text of
an SMS. However, the CRU would continue to require Irish Water to identify themselves in the
subject title of the SMS itself. This provides Irish Water with flexibility to how it identifies itself to
customers in a SMS, e.g. in the Subject bar of the SMS.
The exact wording of the amended requirement is outlined below:
3.5.6 New Customers (Section 5.9)
This section of the Handbook outlines obligations that Irish Water must follow when signing up
a new customer.
Removal of the words ‘sign-up’ for new customers
Irish Water is required under the Handbook to have in its Code of Practice on Customer
Communications clear rules around setting up a new customer account.
The occupier of any premises that receives water and wastewater services from the Irish
CRU Questions
17. Do you agree with the CRU’s proposal to add flexibility to the above requirement?
Please provide rationale for your answer.
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Water network is a customer of Irish Water, and as such should have a customer account with
Irish Water. All domestic customers of Irish Water are liable for charges for water and
wastewater if their annual consumption exceeds the annual household allowance and will
receive a bill accordingly. It is important that Irish Water has the customer information for all
premises connected to their network, so that customers can be billed appropriately for excess
usage, in the event that they are liable for charges. The CRU is proposing to change the title
from “Account holder sign up” to “New Customer”. This aligns with Non-Domestic Handbook
proposal. The CRU is also proposing to amend all reference to “sign up” in subsection 5.8 of
the Handbook to “setting up a new Customer account”. As amending the heading and
replacing the term “sign-up” with “setting up a new account” is an editorial change, the CRU is
not consulting on this amendment.
Amending a requirement to reflect the introduction of Excess Use Charges
The CRU proposes to amend a requirement that states, when setting-up a new customer
account, that Irish Water will inform customers how to pay a bill and inform them of a billing
frequency. The CRU proposes to remove an obligation on Irish Water to inform customers of
the billing frequency from the requirement as it is no longer applicable. This is in line with the
CRU’s decision on Excess Use Charges where customers will be charged for Excess Usage
annually and on an ad-hoc basis and will not be billed at regular intervals.
The exact wording of the amended requirement is outlined below:
Removing a requirement to reflect the CRU’s decision on Excess Use Charges
The CRU proposes to remove a requirement within this section, which states that when
setting-up a new customer account, Irish Water must inform the customer that their contract is
evergreen.
The exact wording of the removed requirement is outlined below:
Amending a Requirement relating to provision of Terms and Conditions to Customers
The CRU proposes to amend the requirement that obliges Irish Water to provide customers
with a copy of the Terms & Conditions of supply of water and wastewater services. The current
requirement obliges Irish Water to provide customers with Terms and Conditions of water
supply, wastewater services contract and the rates that apply to the service they are signing
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up to. Under this requirement, where a customer is not provided with a copy of these
documents at the point of sign up, Irish Water must send copies of these documents to the
Customer.
The CRU now proposes to replace the sentence obliging Irish Water to issue Terms and
Conditions to each customer with a sentence that obliges Irish Water to direct customers as to
where they can find their Terms and Conditions. This is to reflect the CRU’s proposed
amendment to a requirement in section 3.11 of the paper, which no longer requires Irish Water
to issue Terms and Conditions to each customer but rather requires Irish Water to make
Terms and Conditions available on their website.
Also, the CRU proposes to replace the sentence which states that where an account holder is
not provided with a copy of these documents at the point of sign up, copies of these
documents must be sent to the account holder and key terms must be highlighted and
explained. The proposed replacement states that where requested by a customer, Irish Water
must provide a copy of these documents in writing (via post or e-mail) which must highlight
and explain key terms. The CRU is of the view that this amendment will strengthen this
requirement, thus create an additional protection measure for customers.
Similar requirements exist in the Electricity and Gas Suppliers’ Handbook and the Irish Water
Domestic Customer Handbook. The CRU considers that this amendment will achieve greater
consistency in service standards across both domestic and non-domestic water customers as
well as energy customers.
The exact wording of the CRU’s proposed amendment is outlined below:
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3.5.7 Introducing New Sections to the Code (Sections 5.10 – 5.12)
The CRU also proposes to introduce three new sections to the Code of Practice on
Communication with Domestic Customers. The proposed new sections cover:
• Customer notification relating to Excess Use Charges;
• Information that Irish Water must provide to customers on allowances for household
size;
• Information Irish Water must provide to customers regarding exemptions for those
with a medical need.
The addition of these sections aims to ensure that customers are aware of and have adequate
CRU Questions
18. Do you agree with the CRU’s proposal to amend a requirement in this section to
reflect the CRU’s decision on Excess Use Charges? Please provide rationale for
your answer.
19. Do you agree with the CRU’s proposal to remove a requirement from this section
to reflect the CRU’s decision on Excess Use Charges? Please provide rationale
for your answer.
20. Do you agree with the CRU’s proposal to amend a requirement relating to
provision of Terms and Conditions to customers? Please provide rationale for
your answer.
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protection in the introduction of Excess Use Charges. The CRU considers it important to
include the operation of the policy as an area that Irish Water must have certain customer
service obligations.
Introducing a new section on customer notification and communication relating to
Excess Use Charges
This section sets out requirements which oblige Irish Water to notify customers when they are
using water above the annual allowance amount and requires Irish Water to explain to
customers specific terms relating to Excess Use Charges. It also sets out requirements for
how Irish Water must notify customers that they are using water excessively and the
information that Irish Water must include in its notification letters.
The exact wording of proposed new requirements is as follows:
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Introducing a section relating to allowances for household size
This section requires Irish Water to inform customers of how they can apply for an additional
allowance where they have more than four individuals in the dwelling. Irish Water must also
provide customers with the minimum information that they must provide, ranging from the
eligibility criteria for customers to apply for such allowance to procedures which customers
must follow if there is a change in the number of occupants in their dwelling.
The exact wording of the CRU’s proposed requirements is outlined below:
Introducing a section on exemptions due to Medical Need
Under this section, Irish Water is required to inform customers how they can apply for an
exemption from Excess Use Charges due to a medical need and specifies the minimum
information Irish Water must provide to customers regarding same.
The exact wording of the CRU’s proposed requirements is outlined below:
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CRU Questions
21. Do you agree with the CRU’s proposal to introduce a new section to the Code
relating to customer notification and communication on Excess Use Charges?
Please provide rationale for your answer.
22. Do you agree with the CRU’s proposal to introduce a new section relating to
household allowances? Please provide rationale for your answer.
23. Do you agree with the CRU’s proposal to introduce a new section relating to
exemptions due to medical need? Please provide rationale for your answer.
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3.6 Code of Practice on Metering for Domestic Customers
Section 6 of the Handbook outlines the minimum standards of service a domestic customer
can expect regarding the minimum requirements Irish Water must follow when metering a
domestic customer. Specifically, the requirements outline the procedures Irish Water must
take when installing a new meter, testing for suspected faulty meters, the maintenance of
meters, and the repair/replacement of meters that are faulty.
The full list of the CRU’s proposed amendments to the customer service requirements within
the Code of Practice on Metering are detailed (via track changes) in the Irish Water Domestic
Customer Handbook (CRU/20/040), which is published alongside this paper.
Below is a description of the CRU’s principal proposed amendments to this Code.
3.6.1 General Requirement (Section 6.1)
This section sets out a requirement that oblige Irish Water to set out in its Code of Practice on
Metering, information on Irish Water’s communications with customers in advance of installing
new meters, testing for suspected faulty meters and the maintenance or repair/replacement of
meters that may malfunction. The requirement also clarifies that by “meter” the CRU refers to
meters installed by Irish Water and does not refer to any meters that were previously installed
by Local Authorities.
Adding clarity to a requirement relating to information that Irish Water must include in
its Code of Practice on Metering
In the above-mentioned requirement, the CRU proposes to replace the term “procedures it will
take” with “procedures it will follow”. The CRU is of the view that this wording will better reflect
what the CRU expects from Irish Water in this requirement. As this amendment is an editorial
change, the CRU is not consulting on this amendment.
3.6.2 Installation of new meters (Section 6.2)
This section sets out requirements which Irish Water must follow regarding meter installation.
These requirements cover issues such as timeframes for notification of meter installation,
location of meter installation and measures that Irish Water must undertake if an installation of
a meter has caused damage to customer’s premises.
Amending a requirement relating to the Notification Period of the Installation of a New
Meter
In 2014 the CRU approved requirements around the installation of new meters, one of which
specifically concerned the notice period Irish Water must provide to a customer before it
installs a meter at a premises. As all the meter installations were initiated by Irish Water, the
requirement specified that Irish Water must give at least two weeks’ notification in advance of
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the installation, provide information to the customer regarding the meter installation process,
and then another notification two days prior to the anticipated installation date.
This was written to address a situation where Irish Water would be undertaking large meter
replacement programmes in particular geographic locations where it would be important that
affected customers were given two weeks notification of the programme being rolled out in
their area, as well as a two-day notification of the meter installation date at their actual
premises. However, as current water meter installation by Irish Water is either; for newly
constructed buildings, the replacement of existing meters identified by Irish Water during its
operational and maintenance activities of the network (for example, the identification of faulty
or under-recording meters), or at the request of a customer for a meter, Irish Water has
proposed removing the requirement to provide a two-week advance notification of such
installation programmes. The two-week requirement was introduced at a time when there was
a large-scale metering programme in operation. Metering now is done on a more ad-hoc basis
and the CRU considers the shorter notification period is more sensible in such circumstances.
Given the above, the CRU is proposing to amend the requirement to remove the two-week
notice but retain the requirement that Irish Water must give notification at least two days in
advance of the meter installation date. This proposed amendment will also allow Irish Water to
replace any faulty meters more quickly than before and will allow Irish Water to rectify any over
or under recording of consumption for the customer.
This proposed change is shown below (via tracked changes) to the Handbook:
Amending a requirement on damage to customer’s property caused by meter
installation
As noted in Section 3.3.2, the CRU proposes to amend the requirement that requires Irish
Water to cover the cost of damage to customers’ property during meter installation.
The CRU proposes to add to this requirement a proviso that Irish Water must remedy the
damage “to the extent reasonably practicable” and that they will remedy the damage if it was
caused by a “direct” result of meter installation. This wording is intended to reflect that while
Irish Water is expected to remedy damage and return a customer’s property to the exact
condition that it had been in prior to the works being carried out, there may be some occasions
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where, despite its best efforts, e.g. restoring concrete to the exact colour that it was prior to the
works, this may not be possible.
Please see below the exact wording of the CRU’s proposed amendment to this requirement:
Adding clarity to a requirement relating to meter installation
The CRU also proposes to make a minor editorial change to the above requirement. Currently
the requirement obliges Irish Water to during meter installation programmes, give at least two
days’ notification and meter installation information. The CRU proposes to add that Irish Water
must give at least two days’ notification to “Customers”. The CRU considers it important to
identify the party to which the requirement refers thus adding clarity to the requirement. As
adding clarity to a requirement relating to meter installation is an editorial change, the CRU is
not consulting on this amendment.
Introducing a new requirement relating to requesting a meter by unmetered
Customers
For unmetered customers, the CRU is proposing to require Irish Water to facilitate the
metering of unmetered customers.
The exact wording of the proposed requirement is as follows:
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With the onset of excess use charges, the CRU is of the view that some customers may wish
to have a meter installed in order to avoid the maximum charge if they are liable for Excess
Use Charges. The CRU is of the view that by requiring Irish Water to facilitate the metering of
unmetered customers, unmetered customers would benefit as it would allow them to monitor
their usage. A meter is a means of monitoring usage and increasing awareness around
conservation.
3.6.3 Meter Ownership and Meter Access Post Installation (Section 6.3)
This section sets out requirements relating to meter ownership and meter access, in particular
it covers:
• Operational requirements and responsibility for maintenance of meter equipment;
• Clarification of meter ownership; and
• Responsibility for meter inspections and meter testing.
Adding clarity to a requirement relating to meter inspections
The CRU also proposes a minor amendment to a requirement which entitles customers to
open their meter box and “inspect” their meter. The CRU is of the view that the word “inspect”
does not reflect the objective of the customer and that the word “read” is a more appropriate
word to use in this requirement. The CRU also believes that this amendment will make this
document more customer-facing. As this is an editorial change, the CRU is not consulting on
this amendment.
CRU Questions
24. Do you agree with the CRU’s proposal to amend a requirement relating to the
Notification Period of the Installation of a New Meter? Please provide rationale for
your answer.
25. Do you agree with the CRU’s proposal to amend a requirement relating to
damage to customer’s property? Please provide rationale for your answer.
26. Do you agree with the CRU’s proposal to introduce a new requirement relating to
customers requesting to have a meter installed on their premises? Please provide
rationale for your answer.
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Introducing a new requirement relating to assistance in Locating customer’s Meter
The CRU is proposing to introduce a new customer service requirement that Irish Water will
assist customers to locate their meter where customers are unable to do so. In some
instances, customers may find it difficult to locate their meter for a variety of reasons, for
example when buying a property, the new owner may not know where their pipework connects
to the public water supply network.
It is important that a customer can locate their meter so that they can read the meter, monitor
their consumption and in some instances identify the existence of a leak on the customer’s
pipework, or internal plumbing. It is particularly important that a customer knows where their
meter is, especially if Irish Water is billing and the customer is required to pay on the basis of
their meter reads or estimated reads. As the meter is the asset of Irish Water it is appropriate
that the obligation to identify the location of the meter rests with Irish Water.
The exact wording of the proposed requirement is as follows:
3.6.4 Meter Testing (Section 6.4)
This section sets out obligations that Irish Water must follow with respect to meter testing.
More specifically the requirements cover areas such as facilitating a meter test upon
customer’s request, charging customers for meter testing and providing customers with
refunds for meter testing if a meter is found to be faulty.
Adding clarity to a requirement relating to charging customers for meter testing
The CRU proposes to amend a requirement that states that Irish Water may impose a cost
reflective regulated charge on a customer for meter testing. To add clarity to the requirement,
the CRU proposes to also state that such charge is set out in the Irish Water’s Water Charges
Plan. The CRU considers this addition helpful for customers who wish to see the charge they
may face for meter testing. As adding clarity to this requirement is an editorial change, the
CRU is not consulting on this amendment.
CRU Questions
27. Do you agree with the CRU’s proposal to introduce a new requirement that
obliges Irish Water to assist customers in locating their meters? Please provide
rationale for your answer.
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3.7 Code of Practice on Billing for Domestic Customers
The Code of Practice on Customer Billing for Domestic Customers outlines general
requirements on the information that Irish Water must include on the bill and how Irish Water
should present information on water and wastewater charges. It sets out requirements on
payment options which Irish Water must offer to the customers, how Irish Water must charge
customers and how Irish Water should approach customers who wish to close their account or
are in financial difficulties.
This section provides a summary of the principal amendments the CRU is proposing to make
to the existing Billing Code of Practice Handbook requirements.
The full list of the CRU’s proposed amendments to the Billing Code of Practice customer
service requirements are detailed in the Irish Water Domestic Customer Handbook
(CRU/20/040), which is published alongside this paper.
3.7.1 General Customer service in relation to billing (Section 7.1)
The existing “General customer service in relation to billing” section outlines the minimum
requirements Irish Water must offer its domestic customers, for such things as ensuring all bills
are calculated accurately and that meters are read quarterly, and sets out rules around late
billing.
Introducing a new requirement relating to how Irish Water must charge customers
The CRU proposes to introduce a new requirement that obliges Irish Water to charge
customers in line with legislation, that the charges must be equitable across customers and
that charges should be clear and easy to understand.
The exact wording of the proposed requirement is as follows:
Introducing a new Requirement to reflect the CRU’s decision on Excess Use Charges
The CRU proposes to introduce a new requirement that obliges Irish Water to apply the
required Allowances (due to household size) and appropriate Exemptions (due to medical
need) to a Customer’s bill, as required. The aim of this additional requirement is to reflect the
CRU’s decision on Excess Use Charges, thus introducing an additional protection measure for
customers that are eligible for additional allowances and for exemptions.
The exact wording of the proposed requirement is as follows:
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Amending a requirement relating to wastewater charges
The current requirement obliges Irish Water to charge customers for wastewater based on the
direct volume equivalent of their metered water consumption or a fixed charge for unmetered
customers in accordance with the CRU’s approved Water Charges Plan. To reflect the CRU’s
decision on Excess Use Charges, i.e. that domestic customers only pay for water and
wastewater services for volumes in excess of the domestic allowance, the CRU proposes to
add that this requirement will only apply in cases where a customer is liable for Excess Use
Charges.
The exact wording to the proposed amendment is as follows:
Reordering a requirement relating to how Irish Water should charge customers
The CRU proposes to reorder a requirement which obliges Irish Water to charge all domestic
customers in line with the CRU’s decision on Water Charges Plan. Currently this requirement
does not have a number, does not belong to any section and was positioned directly under the
heading “Code of Practice on Billing for Domestic Customers”. The CRU proposes to move
this requirement into the section “General Customer Service in Relation to Billing”. The CRU
believes that this will add clarity to the Code and that it is more appropriate for it to be located
in this section. As reordering of this requirement is an editorial change, the CRU is not
consulting on this amendment.
Amending requirements relating to billing calculations
The CRU proposes to amend the requirement which obliges Irish Water to calculate all bills
accurately based on either actual meter reads calculated by Irish Water or customer meter
reads. The CRU proposes to make this requirement more general and state that Irish Water
must calculate all bills accurately, based on meter reads where possible and issue bills
promptly. The CRU also considers this more appropriate as this requirement is located in
section “General Customer Services in Respect to Billing” and for this reason it should be
general in nature.
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The exact wording of the proposed amendment is as follows:
Amending a requirement relating to frequency of billing and meter readings
The CRU proposes to amend the requirement which obliges Irish Water to issue and read
customer’s bills quarterly with exceptions to the first and final bills to new customers. The CRU
proposes to remove the word “to issue” bills. In line with the CRU’s decision on Excess Use
charges, Irish Water will no longer issue bills quarterly. For the same reason, the CRU
proposes to remove the sentence that refers to “first and final bills for new customers”.
The exact wording of the proposed amendment is as follows.
Amending a requirement Relating to billing methods and billing timeframes
The CRU also proposes to amend a requirement which obliges Irish Water to calculate all bills
with exception of the first bills issued in 2015, based on quarterly cycles and to issue all bills
no later than one month after a quarterly cycle except in situations where the meter read
appears erroneous. In the case where the meter read is affecting the bill, Irish Water must
make every effort to issue a revised bill to a customer. The CRU proposes to amend the
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requirement where Irish Water is required to issue bills one month after a quarterly read has
been taken, to “four weeks” after the final quarterly read has been taken. This is aimed at
allowing more time for Irish Water to issue bills to customers and to reflect Excess Use
Charges and the fact that bills will be issued annually rather than quarterly. Lastly the CRU
proposes to add to the requirement that Irish Water will issue such bills to all customers that
are liable for Excess Use Charges to reflect current charging policy.
The exact wording of the proposed amendment is as follows:
Removing requirements to reflect the CRU’s decision on Excess Use Charges
The CRU proposes to remove the following requirements from this section:
• The CRU proposes to remove a requirement that obliges Irish Water to charge
unmetered customers quarterly in line with their fixed charge. The CRU also
proposes to remove a requirement that obliges Irish Water to apply an estimated
charge in circumstances where Irish Water is unable to read a meter and apply a fix
charge for customers that are unmetered.
• The CRU proposes to remove a requirement stating that where two consecutive bills
were issued to customers, that Irish Water will visit the meter and determine reasons
for this, determine the correct reading and calculate whether a customer was
underpaying or overpaying for their water or wastewater.
The CRU is of the view that these requirements are no longer relevant as customers will now
only be charged, when they use more water than their annual household allowance.
The exact wording of the removed requirements is as follows:
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Splitting of a lengthy requirement relating to billing errors
The CRU proposes splitting one lengthy requirement in this section. This requirement states
that in the case where an error was discovered on a customer’s bill, that Irish Water will
determine whether a customer was overpaying or underpaying for their water or wastewater. If
a customer was underpaying, a customer is required to pay their outstanding bill for the past
12 months and where a customer was overpaying for water or wastewater, Irish Water is
required to refund the overpaid amount to the customer. The requirement also states that if a
customer has constantly been in arrears with Irish Water and has not engaged with Irish
Water, the customer will not be covered by such protection.
The CRU is of the view that splitting this requirement will make the requirement clearer and
easier to understand by customers. As the splitting of a lengthy requirement is an editorial
change, the CRU is not consulting on this amendment.
Adding clarity to a requirement relating to billing errors
For the same requirement (relating to billing errors), the CRU proposes to also add that in the
case where a billing error was discovered that Irish water will determine whether a customer
was underpaying, overpaying or “was in fact liable for a charge”. The addition of this
requirement will give additional protection to customers who might have been liable or not
liable for a charge. Again, as this is an editorial change, the CRU is not consulting on this
amendment.
Introducing a new requirement for customers that request to be recategorized as a
‘domestic’, ‘mixed-use’ or “Domestic” customer premises
The CRU is aware that there are customers of Irish Water questioning whether their premises
is categorised correctly for the purposes of charging liability. For example, a customer may
consider that they are a ‘domestic’ rather than a ‘non-domestic’ or ‘mixed-use’ connection. To
facilitate a customer requesting to change the categorisation of their premises, the CRU is
proposing to introduce a new requirement which requires Irish Water to facilitate a customer
requesting to change a customer’s categorisation from non-domestic to domestic or mixed-
use, and vice versa. This will benefit customers by ensuring that a customer is aware of what
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information Irish Water will require to verify the change.
The exact wording of the new requirement is outlined below:
CRU Questions
28. Do you agree with the CRU’s proposal to introduce a new requirement relating to
how Irish Water must charge customers? Please provide rationale for your
answer.
29. Do you agree with the CRU’s proposal to introduce a new requirement relating to
household allowances and medical exemptions? Please provide rationale for your
answer.
30. Do you agree with the CRU’s proposal to amend a requirement relating to
wastewater charges? Please provide rationale for your answer.
31. Do you agree with the CRU’s proposal to amend a requirement relating to
calculation of charges? Please provide rationale for your answer.
32. Do you agree with the CRU’s proposal to amend a requirement relating to
frequency of billing and meter readings? Please provide rationale for your answer.
33. Do you agree with the CRU’s proposal to amend a requirement relating to billing
methods and billing timeframes? Please provide rationale for your answer.
34. Do you agree with the CRU’s proposal to remove requirements to reflect the
CRU’s decision on Excess Use Charges? Please state which requirement you are
referring to and please provide rationale for your answer.
35. Do you agree with the CRU’s proposal to introduce a new requirement relating to
customers that request to be recategorized as a ‘domestic’, ‘mixed-use’ or
“Domestic” customer? Please provide rationale for your answer.
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3.7.2 Information on the Bill (Section 7.2)
This section sets out requirements which Irish Water must follow in regard to information Irish
Water provides on customers’ bills. This covers areas such as the customer’s name and
address, the period covered by the bill, meter number and Irish Water’s emergency reporting
number.
Introducing a new requirement relating to information that Irish Water must provide
on customer’s bill
The CRU proposes introducing a new requirement that ensures the information in bills issued
to customers by Irish Water is complete, accurate transparent and not misleading. This
requirement is aimed at capturing the CRU’s overall expectation of the information that Irish
Water should include on a bill thus adding clarity to this section.
The exact wording of the CRU’s proposed requirement is as follows:
Removing a requirement to reflect on the CRU’s decision on Excess Use Charges
The current requirement sets out a list of information that must be included on Irish Water’s
bill. The CRU proposes to remove an obligation on Irish Water to include “billing frequency” on
the bill. In line with the CRU’s decision on Excess Use charges, customers will no longer be
charged at regular intervals and for this reason the CRU considers this requirement no longer
applicable.
The exact wording of the removed requirement is as follows:
Amending a requirement relating to Irish Water providing a meter number on the bill
The CRU proposes to amend a requirement that obliges Irish Water to include on their bill, a
customer’s meter number. The CRU proposes to replace the obligation on Irish Water to
include a “meter number” on their bills with an obligation to include a Water Meter Point of
Reference (WPRN). The CRU believes that this is a better point of reference for both
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customers and Irish Water as the WPRN seems to be more commonly referenced by Irish
Water and could assist customers better if they experience billing issues.
The exact wording of the CRU’s proposed amendment to the requirement is as follows:
Amending a requirement relating to charging information that must be included on
the bill
The CRU proposes to amend a requirement that oblige Irish Water to include on their bill, a
clear breakdown of charges, volume of water consumed, and wastewater discharged;
including any applicable rebates, allowances and penalties for those customers who are
metered but capped at the appropriate charge. Within this requirement, the CRU proposes to
replace the word “penalty” with “exemptions “to reflect the CRU’s decision on Excess Use
Charges thus introducing an additional protection measure for those that are eligible for
medical use exemptions under Excess Use Charges.
The exact wording of the CRU’s proposed amendment to the requirement is as follows:
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Amending a requirement relating to historical data that Irish Water must include on
bills
The CRU proposes to amend a requirement which obliges Irish Water, for all bills issued after
2015, to display historical consumption/wastewater discharge data for the previous 12 months
(where data is available). This is to include a concise outline of the volume of water consumed
and may also contain information on the volume of wastewater discharged, unit price, standing
charge and discounts/allowances provided. The CRU proposes to remove the first sentence
relating to “all bills issued after 2015” and to remove the tern “standing charge”. The CRU
considers that in line with the CRU’s decision on Excess Use Charges, this wording is no
longer applicable.
The exact wording of the CRU’s proposed amendment is as follows:
CRU Questions
36. Do you agree with the CRU’s proposal to amend a requirement relating to the
information that Irish Water must provide to customers on their bills?
37. Do you agree with the CRU’s proposal to remove a requirement from this section
to reflect the CRU’s decision on Excess Use Charges? Please provide rationale
for your answer.
38. Do you agree with the CRU’s proposal to amend a requirement relating to Irish
Water providing a meter number on the customer’s bill? Please provide rationale
for your answer.
39. Do you agree with the CRU’s proposal to amend a requirement relating to
charging information that must be included on the customer’s bill? Please provide
rationale for your answer.
40. Do you agree with the CRU’s proposal to amend a requirement relating to
historical data that Irish Water must include on customer’s bills? Please provide
rationale for your answer.
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3.7.3 Presentation of information on Charges (Section 7.3)
This section sets out requirements relating to the information that Irish Water must provide to
customers regarding charges, i.e. obligations on how and where Irish Water must display
information on charges.
Amending a requirement that obliges Irish Water to display capped and fixed charges
to customers
There currently exists a requirement for Irish Water to display capped and fixed charges to
customers. To reflect the CRU’s decision on Excess Use Charges, the CRU proposes,
replacing the term “capped and fixed charges” with the term “any applicable charges”.
The exact wording of the CRU’s proposed amendment is outlined below:
3.7.4 Payment Options (Section 7.4)
This section sets out requirements which relate to various payment options that Irish Water
must offer to customers. The CRU proposes the following amendments:
Removing requirements to reflect the CRU’s decision on Excess Use Charges
The CRU proposes to remove a requirement that obliges Irish Water to offer customers an
option to pay their bills more frequently than quarterly. The aim of removing this requirement is
to update this section to reflect on the CRU’s decision on Excess Use Charges.
The exact wording of the CRU’s proposed amendment is as follows:
CRU Questions
41. Do you agree with the CRU’s proposed amendment to a requirement in this
section regarding capped and fixed charges? Please provide rationale for your
answer.
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Removing a requirement relating to customers who pay their bill by direct debit
The CRU proposes to remove a requirement which relates to Irish Water providing notification
to customers who pay by direct debit. The requirement obliges Irish Water to provide this
notification in line with the Single European Payment Area (SEPA) standards for notification of
direct debits. The CRU is of the view that it is not appropriate to list out specific organisations
and this requirement was too prescriptive.
The exact wording of the removed requirement is as follows:
CRU Questions
42. Do you agree with the CRU’s proposed to remove a requirement in this section
to reflect the CRU’s decision on Excess Use Charges? Please provide rationale
for your answer.
43. Do you agree with the CRU’s proposal to amend a requirement relating to an
option for customers to pay by direct debit? Please provide rationale for your
answer.
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3.7.5 Communication of Information on Charges (Section 7.5)
This section sets out requirements relating to how Irish Water must notify customers of
change to charging structure and information that Irish Water must include when issuing pro-
rating bills to customers.
Amending a requirement relating to Irish Water notifying customers of charges
applicable to them
The CRU proposes to amend a requirement that obliges Irish Water to notify customers of
charges applicable in line with the customer’s Terms and Conditions. Considering the CRU’s
proposal to now require Irish Water to display their Terms and Conditions to customers on
their website instead obliging Irish Water to issue Terms and Conditions to each customer
individually, the CRU proposes to replace the word “Terms and Conditions” with the word
“Water Charges Plan”.
The exact wording of the CRU’s proposed amendment is as follows:
3.7.6 Closing Account & Issuing Final Bill (Section 7.6)
This section of the Code outlines areas such as the type of reads Irish Water must offer a
customer when the customer wishes to close its account and that Irish Water must issue a
final closing bill to the customer no later than six weeks from the date the account was closed.
It is important that customers contact Irish Water when they wish to close their account to
make sure that they are not registered for a service that they will be no longer using.
Adding clarity to a requirement relating to closure of account by a customer
The CRU proposes to amend a requirement that obliges Irish Water, upon request from the
Customer, to close customer’s account with exception to cases where there is outstanding bill
or a requirement on a customer to collect a final closing read. The CRU proposes to add to the
requirement that an exception can apply “where a meter read has not been accepted by a
CRU Questions
44. Do you agree with the CRU’s proposal to amend a requirement relating to Irish
Water notifying customers of charges applicable to them? Please provide
rationale for your answer.
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Customer”. This amendment aims to add clarity to the CRU’s expectations of Irish Water with
respect to Customer’s account closure. As adding clarity to this requirement is an editorial
change, the CRU is not consulting on this proposal.
Adding clarity to a requirement relating to issuing a final bill to customers
The CRU proposes to amend a requirement that obliges Irish Water, where a Customer has
closed their account, to issue the final closing bill to the customer not later than six weeks from
the effective date of account closure. To add clarity to the requirement, the CRU proposes to
replace the sentence that Irish Water must issue a final bill to the customer after “the effective
date of account closure” with “date where a Customer contacts Irish Water to close their
account”. As adding clarity to this requirement is an editorial change, the CRU is not consulting
on this amendment.
3.7.7 Arrears & Arrangements for Identifying and Dealing with Customers in
Financial Difficulty (Section 7.7)
The Handbook provides several requirements relating to Irish Water’s obligations regarding its
arrangements for customers that are in payment arrears and financial difficulty.
Adding clarity to a requirement relating to information Irish Water must include in its
Code of Practice on Billing
The CRU proposes to amend a requirement that obliges Irish Water to include within their
Codes of Practice a section outlining how Irish Water should deal with customers with financial
difficulties. The CRU proposes to amend this requirement so that it does not refer to
information that Irish Water must include in their Code of Practice on billing but instead obliges
Irish Water to have an established process for dealing with customers in financial difficulty.
Currently, the requirement is indirect and might cause confusion as to what is expected from
Irish Water. This amendment aims to add clarity to this requirement. As adding clarity to this
requirement is an editorial change, the CRU is not consulting on this amendment.
Amending terminology in a requirement relating to Irish Water dealing with customers
that have a difficulty paying their bill
The CRU proposes amending a requirement that obliges Irish Water to advise Customers to
contact them at an early stage if they are having difficulty making payment on their bill. The
CRU proposes amending the word “experiencing” with the word “having, as this is more
accessible terminology for customers. As amending terminology in this requirement is an
editorial change, the CRU is not consulting on this amendment.
Adding flexibility to a requirement relating to customers choosing a third party when
paying their bills
The CRU proposes amending a requirement that offers customers an opportunity to choose a
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third party to represent them when dealing with Irish Water regarding their bills. Within this
requirement, the Handbook currently provides examples of different third-party
representatives. The CRU proposes removing these examples to keep this requirement as
broad as possible.
The exact wording of the CRU’s proposed amendment is as follows:
Adding flexibility to a requirement relating to customers that are having difficulty
paying their bills
The CRU proposes to amend the requirement which obliges Irish Water, where circumstances
warrant it, to be proactive in recommending Customers seek guidance to their local MABS
office or other relevant organisations. Similar to the above, the CRU proposes to replace the
reference to “MABS or other relevant organisations” with “third party representatives” as the
CRU is not in favour of any particular organisation.
The exact wording of the CRU’s proposed amendment is as follows:
CRU Questions
45. Do you agree with the CRU’s proposal to add flexibility to a requirement relating
to customers who wish to nominate a third party when paying their bill? Please
provide rationale for your answer.
46. Do you agree with the CRU’s proposal to add flexibility to a requirement relating
to customers who are having difficulty paying their bill? Please provide rationale
for your answer.
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3.7.8 Payment Plans (Section 7.8)
This section sets out requirements that Irish Water must follow when arranging a payment plan
with customers. Requirements in this section range from obliging Irish Water to offer payment
plans to customers that are in financial difficulties, listing out factors that Irish Water must
consider when developing a payment plan and information that Irish Water must communicate
to customers if they have signed-up for a payment plan.
Adding flexibility to a requirement relating to payment plans
The CRU proposes to amend the requirement which obliges Irish Water to assist customers in
financial difficulties by developing a payment plan. Irish Water will engage with a
representative acting on behalf of a customer e.g. MABS or any other recognised charity or
Social Welfare agent. The CRU proposes to remove the examples of specific representatives
that can act on behalf of customers as it considers that it is more beneficial for the customer to
leave this open-ended in terms of the charitable body or other advisor it may wish to avail of.
This amendment also aims to clarify that the CRU is not promoting any one organisation.
The exact wording of the CRU’s proposed amendment is as follows:
Amending a requirement relating to customers availing of a payment plan
The CRU proposes to amend the requirement which in case where Irish Water has arranged a
payment plan with a customer, Irish Water will provide the customer with details of the
payment plan and any associated terms through a range of appropriate communication
channels. The CRU proposes to replace the term “appropriate communication channels with
the term “in writing”. The CRU is of the view that it is important for customers to receive any
information relating to their payment plan in writing and that receiving this information through
one communication channel is sufficient. This amendment my also lead to improved record
keeping and database management by Irish Water.
The exact wording of the CRU’s proposed amendment is as follows:
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3.7.9 Dealing with Premises with No Named Customer (Section 7.9)
The CRU is proposing to rename this section from “Dealing with premises with no registered
account holder” to “Dealing with premises with no named Customer”. The CRU is proposing to
make this change for the same reason as outlined within section 2.3.3 of this paper.
Throughout this subsection, the CRU is proposing to replace text referring to “registered” with
“set up an account” to more accurately describe Irish Water’s process of setting up an
account. As this amendment is an editorial change, the CRU is not consulting on this
amendment.
Adding clarity to a requirement relating to information that Irish Water must include in
their Code of Practice on Billing
Irish Water proposes to amend a requirement that obliges Irish Water to include a section in
their Code of Practice on the process for handling customers with no named account. Irish
Water proposes to clarify in the requirement that by “Code” the CRU refers to the “Code of
Practice on Billing”. Also, the CRU proposes to replace the word “process” with “way” as it
makes the requirement less technical and easier to understand by the general public. As
adding clarity to this requirement is an editorial change only, the CRU is not consulting on this
amendment.
Amending a requirement to reflect the introduction of Excess Use Charges
The CRU proposes to amend the requirement where, in a case where a customer closes its
CRU Questions
47. Do you agree with the CRU’s proposal to add flexibility to a requirement in this
section? Please provide rationale for your answer.
48. Do you agree with the CRU’s proposal to amend a requirement relating to
customer who wish to avail of payment plans? Please provide rationale for your
answer.
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account, Irish Water is obliged to notify an appropriate party at the premises that they are now
liable for a charge until the time when a new customer registers with Irish Water. As there are
no domestic water charges in place for all customers (only for customers that are excess
users) the CRU considers it no longer appropriate to state that an occupier may be liable for a
charge. The CRU therefore proposes replacing the term “liable for charges” with “inform
customer that they are an Irish Water identified customer”. For clarity, the CRU also proposes
to replace the word “appropriate party” with the word “occupier” to ensure that the notification
is directed to the current occupier of a premises.
The exact wording of the CRU’s amendment is as follows:
3.8 Code of Practice on Vulnerable Customers
The Code of Practice on Vulnerable Domestic Customers requires Irish Water to have in place
a register for priority services customers and special services customers. The code outlines
procedures that Irish Water must undertake when dealing with vulnerable customers on the
priority and special services register and sets out obligations to follow regarding customers
that have special communication requirements.
The CRU proposes to make an amendment and introduce new requirements to Codes of
Practice on Vulnerable Customers. Below we list our proposals in more detail.
3.8.1 Required provision by Irish Water for Vulnerable Customers (Section
8.2)
This section sets out requirements which oblige Irish Water to have in place a priority services
register (customers which are critically dependant on water), and a special services register
(customers who require additional support communicating with, or receiving services from,
Irish Water). The requirements also oblige Irish Water to ensure there is full public awareness
CRU Questions
49. Do you agree with the CRU’s proposal to amend a requirement to reflect the
introduction of Excess Use Charges?
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of those registers.
Introducing new requirements relating to Irish Water’s communication with vulnerable
customers
The CRU proposes to introduce two new requirements offering vulnerable customers the
opportunity to avail of alternative methods of communications and an opportunity to nominate
a third party to represent them. The CRU is of the view that the introduction of such
requirements will provide vulnerable customers with additional protection.
The exact wording of the CRU’s proposed requirements is as follows:
3.8.2 Required Provision by Irish Water for Priority Services Customers
(Section 8.3)
This section sets out requirements relating to Irish Water’s dealings with customers that are
registered on Irish Water’s priority services register. Such requirements cover issues such as
obligations to notify customers on priority services register of any planned or unplanned
interruptions. The requirements also specify the information that Irish Water must
communicate to customers during those interruptions.
Aligning a requirement with the GDPR legislation
Currently the requirement that states that Irish Water may require customers to demonstrate
their eligibility to be included on the priority customer services register does not refer to the
Data Protection Legislation. The CRU agrees with a proposal from Irish Water that if Irish
Water decides to request customers to provide a proof of their eligibility to be included on the
priority services register that Irish Water will do so in line with the Data Protection Legislation.
The exact wording of the CRU’s proposed amendment is outlined below:
CRU Questions
50. Do you agree with the CRU’s proposal to introduce two new requirements relating
to Irish Water’s communication with vulnerable customers? Please provide
rationale for your answer.
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Amending a requirement relating to Irish Water reporting to the CRU
The CRU proposes to amend a requirement that obliges Irish Water to report to the CRU on
the number of vulnerable customers it has on its register and the actions Irish Water is taking
to support such customers. To further strengthen the requirement, the CRU proposes to add to
the requirement that Irish Water must also report on actions that Irish Water has taken under
requirement 8.2.2 (actions that Irish Water has taken to ensure full public awareness of the
registers). The CRU considers this additional information important as it will provide the CRU
with better insight of how Irish Water is performing in this area.
3.9 Code of Practice on Network Operation for Domestic
Customers
The Code of Practice on Network Operations for Domestic Customers sets out requirements
on pipework ownership, planned and unplanned interruptions, customer asset flooding, low
water pressure and out of hours services.
This section provides a summary of the amendments the CRU is proposing to make to the
existing Network Operations Code of Practice Handbook requirements. The full list of the
CRU’s proposed amendments to the customer service requirements are detailed in the Irish
Water Domestic Customer Handbook (CRU/20/040), which is published alongside this
CRU Questions
51. Do you agree with the CRU’s proposal to align a requirement with the GDPR
legislation?
52. Do you agree with the CRU’s proposal to amend a requirement relating to Irish
Water reporting to the CRU about vulnerable customers? Please provide rationale
for your answer.
53. Do you believe the CRU should introduce any additional amendments to the Code?
If so, could you set out the amendments and your rationale for such amendments?
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consultation paper.
3.9.1 Information Provision on Water/Wastewater Connections (Section 9.1)
This section sets out one requirement relating to water and wastewater connections. Firstly,
this requirement states that in this Code, “connections” refer to Irish Water’s assets and
secondly, the requirement obliges Irish Water to have a Code of Practice that covers how
customers can access information on connecting to the network and the levels of service that
Customers can expect.
Adding clarity and transparency to a requirement relating to water and wastewater
connections
The CRU proposes to add a requirement number to this requirement as currently, this
requirement has no number. The CRU also proposes to add to the requirement that the Code
of Practice should include the level of services customers can expect “from Irish Water”. The
CRU is of the view that it is Important to identify the party to which the requirement refers thus
adding clarity to the requirement. In addition, to add transparency to the requirement, the CRU
proposes to move the first sentence of this requirement to the end. As these amendments are
editorial changes only, the CRU is not consulting on these amendments.