irish water domestic customer handbook requirements

An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities

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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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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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• 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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• 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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• 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

1. Introduction ................................................................................ 13

1.1 Background ......................................................................................................... 13

1.2 Domestic Customer Handbook .......................................................................... 13

1.3 Purpose of this Paper ......................................................................................... 14

1.4 Structure of this Paper ....................................................................................... 14

2. Review of the Domestic Customer Handbook .......................... 16

2.1 Objectives of the Review .................................................................................... 16

2.2 Legislative Remit and Strategic Objectives ...................................................... 17

2.3 Context of the Review ........................................................................................ 18

2.3.1 Quarterly Reports .......................................................................................... 18

2.3.2 CRU Monitoring ............................................................................................. 19

2.3.3 Compliance .................................................................................................... 19

2.4 Consideration of Principles-based vs. Prescription ......................................... 19

2.5 Related Documents ............................................................................................ 21

3. Consultation Proposals and Questions .................................... 23

3.1 Introduction ......................................................................................................... 23

3.2 Universal Amendments to all Codes – Consistency of Terms ........................ 23

3.3 Introduction Section ........................................................................................... 25

3.3.1 Implementation Dates of Handbook Requirements (Section 1.1) ................... 25

3.3.2 Overarching Principles (Section 1.2) .............................................................. 26

3.3.3 General Obligations (Section 1.3) .................................................................. 28

3.4 Customer Charter ............................................................................................... 28

3.4.1 General Requirements (Section 4.1) .............................................................. 29

3.4.2 Minimum Commitments where Charter Payments Apply (Section 4.2)........... 33

3.4.3 Water and Wastewater Quality (Section 4.3) ................................................. 38

3.5 Code of Practice on Communication with Domestic Customers .................... 38

3.5.1 Customer Information Requirements (Section 5.1) ........................................ 39


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3.5.2 Customer Communication During Supply Interruptions and Poor-Quality

Supply Periods (Section 5.3) ........................................................................................ 40

3.5.3 Customer Communication Through Printed Material (Section 5.4) ................. 43

3.5.4 Customer Communication by Telephone (Section 5.5) .................................. 43

3.5.5 Customer Contact by SMS (Section 5.8) ........................................................ 44

3.5.6 New Customers (Section 5.9) ........................................................................ 44

3.5.7 Introducing New Sections to the Code (Sections 5.10 – 5.12) ........................ 47

3.6 Code of Practice on Metering for Domestic Customers ................................... 51

3.6.1 General Requirement (Section 6.1) ................................................................ 51

3.6.2 Installation of new meters (Section 6.2) ......................................................... 51

3.6.3 Meter Ownership and Meter Access Post Installation (Section 6.3) ............... 54

3.6.4 Meter Testing (Section 6.4) ............................................................................ 55

3.7 Code of Practice on Billing for Domestic Customers ....................................... 56

3.7.1 General Customer service in relation to billing (Section 7.1) .......................... 56

3.7.2 Information on the Bill (Section 7.2) ............................................................... 62

3.7.3 Presentation of information on Charges (Section 7.3) .................................... 65

3.7.4 Payment Options (Section 7.4) ...................................................................... 65

3.7.5 Communication of Information on Charges (Section 7.5) ............................... 67

3.7.6 Closing Account & Issuing Final Bill (Section 7.6) .......................................... 67

3.7.7 Arrears & Arrangements for Identifying and Dealing with Customers in

Financial Difficulty (Section 7.7) ................................................................................... 68

3.7.8 Payment Plans (Section 7.8) .......................................................................... 70

3.7.9 Dealing with Premises with No Named Customer (Section 7.9) ..................... 71

3.8 Code of Practice on Vulnerable Customers ...................................................... 72

3.8.1 Required provision by Irish Water for Vulnerable Customers (Section 8.2) .... 72

3.8.2 Required Provision by Irish Water for Priority Services Customers (Section 8.3)

73

3.9 Code of Practice on Network Operation for Domestic Customers .................. 74

3.9.1 Information Provision on Water/Wastewater Connections (Section 9.1) ......... 75

3.9.2 Unplanned Network Interruptions (Section 9.4) .............................................. 75

3.9.3 Customer Asset Flooding (Section 9.5) .......................................................... 76

3.9.4 Water Pressure (Section 9.6) ......................................................................... 77

3.9.5 Out of Service Hours (Section 9.7) ................................................................. 77

3.10 Code of Practice on Complaint Handling for Domestic Customers ................ 78

3.10.1 General Obligations in Complaints Handling (Section 10.2) ........................... 78


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3.11 Terms and Conditions ........................................................................................ 86

4. Conclusions and Next Steps ..................................................... 88


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1. Introduction

1.1 Background

The Water Services Act (No. 2) 20131 conferred on the CRU the role of economic regulator of

Irish Water and includes the provision for the CRU to regulate the customer service levels

provided by Irish Water. The CRU, therefore, has a key role in protecting the interests of water

and wastewater customers of Irish Water and ensuring that customers receive a high quality of

service. One way this is achieved is through the Irish Water Domestic and Non-Domestic

Customer Handbooks.

1.2 Domestic Customer Handbook

The CRU protects the interests of water and wastewater customers, and ensures that Irish

Water provides customers with a high-quality water and wastewater service, through its

Customer Handbook, which sets out several customer-related requirements and obligations to

which Irish Water must adhere. The Customer Handbook was first published in 2014 shortly

after Irish Water was established and CRU’s economic regulation role began. At the time, the

“Customer Handbook” set out obligations relating to both domestic and non-domestic

customers. In 2018 the Handbook was divided into two separate documents, i.e. “Domestic

Customer Handbook” and “Non-Domestic Customer Handbook”. At that point, the content of

the Domestic Handbook remained unchanged, so this is the first comprehensive review of the

Domestic Customer Handbook since 2014. At a high level, the current version of Domestic

Customer Handbook contains the following sections:

• An ‘Introduction’ section outlining the CRU’s role under the legislation and setting out

“Overarching Obligations” that aim to provide a high-level overview of the CRU’s

expectations from Irish Water in its customer services performance.

• A Domestic Customer Charter that sets out commitments for Irish Water to follow in

its customer services operation. Under this section, a customer is entitled to a charter

payment of €10 for each time Irish Water breaches any commitment set out in this

section.

• Codes of Practice are sections within the handbook that set out requirements which

Irish Water must adhere to in respect to its communication with customers, metering,

billing, dealing with vulnerable customers, network operations and complaint

handling.

1 http://www.irishstatutebook.ie/eli/2013/act/50/enacted/en/html


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• A Terms and Conditions section setting out content which Irish Water must include in

its Terms and Conditions and outlines the CRU’s review process of those Terms and

Conditions.

1.3 Purpose of this Paper

The CRU is consulting on its proposed amendments to the current requirements of the

Domestic Customer Handbook. The CRU has reviewed the Handbook for the following

reasons:

• To ensure the Handbook reflects all customer-related requirements brought about by

legislation enacted since the Handbook was last published. In particular, the review is

necessary following the suspension of domestic water charges in 2016 and the

subsequent introduction of Excess Use Charges under the Water Services Act 2017;

• To ensure the Handbook remains fit-for-purpose and to update it to reflect the

experiences of customers. This has been informed by the CRU’s monitoring of Irish

Water’s performance in relation to customer service since Irish Water was

established;

• To refresh the Handbook following Irish Water’s first five years in operation and to

reflect water policy developments;

• To reflect best regulatory practice and developments in other jurisdictions;

• To generally update and improve clarity and transparency of the Domestic Customer

Handbook.

1.4 Structure of this Paper

This consultation paper as structured as follows:

• Section 1 provides readers information on the content of the existing Customer

Handbook, provides the purpose of the paper and notifies interested parties of how

they may respond to the paper;

• Section 2 outlines the objectives of the Handbook review, the legislative background

and the context of the review;

• Section 3 describes the CRU’s proposed changes to the Domestic Customer

Handbook and outlines the CRU’s consultation questions;

• Section 4 provides conclusions of this paper and next steps.


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1.5 Responding to this Paper

Interested parties are invited to respond to this consultation paper by close of business on 22

May 2020. In responding to this paper, respondents are asked to note the following:

• Proposed amendments to the Domestic Customer Handbook relate to Domestic

Customers only;

• All current and proposed requirements are “minimum” requirements to which Irish

Water must adhere;

• The CRU recommends that respondents read the tracked changes of the Domestic

Customer Handbook published alongside this consultation paper.

Submissions on any of the points listed in this paper should be clear and specific, with analysis

or rationale to support the views provided. Unless marked confidential, all responses may be

published on the CRU’s website. Respondents may request that their response is kept

confidential.

The CRU shall respect this request, subject to any obligations to disclose information.

Respondents who wish their responses to remain confidential should mark the document as

so and include the reasons for confidentiality. Responses from identifiable individuals will be

anonymised before publication on the CRU’s website unless the respondent explicitly requests

their personal details to be published. Our privacy notice sets out how the CRU protect the

privacy rights of individuals and can be found 2here .

Submissions to this paper should be forwarded, preferably in electronic format, to

[email protected] alternatively, customers may submit a postal response to:

Water Division,

Commission for Regulation of Utilities,

The Exchange,

Belgard Square North,

Tallaght,

D24PXW0.

2 https://www.cru.ie/privacy-statement/

https://www.cru.ie/privacy-statement/

mailto:[email protected]



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2. Review of the Domestic Customer

Handbook

2.1 Objectives of the Review

The CRU’s objectives in reviewing the Domestic Customer Handbook are as follows:

• To reflect legislative changes since the last publication of the Domestic Customer

Handbook, principally the enactment of the Water Services Act 2017, and the CRU’s

subsequent Excess Use Charges decision. The discontinuation of domestic water

charges in 2016 and the recent decision to approve Excess Use Charges for

domestic customers require the Handbook to be updated. This is particularly relevant

to the Code of Practice on Communication for Domestic Customers, Code of Practice

on Billing for Domestic Customers and Terms and Conditions.

• To respond to trends noted from Irish Water’s compliance and quarterly reports. The

CRU has monitored Irish Water’s compliance with the Domestic Customer Handbook

since 2015. Irish Water also issues quarterly reports to the CRU outlining its

performance in areas including customer complaints, vulnerable customers and

water quality. The CRU reviews this information and can determine areas in which

Irish Water is performing well and areas where improvement may be required.

• To respond to trends noted from the CRU’s customer care team, which provides a

dispute resolution service in instances where a customer has complained to Irish

Water and the complaint requires referral to the CRU.

• To maintain pace with latest developments and approaches to customer services

requirements in other jurisdictions. The CRU has considered approaches taken in

other jurisdictions and in other sectors in proposing changes.

• To clarify requirements and make editorial changes to reflect the evolution of the

Customer Handbook. The review provides the CRU with an opportunity to change

the wording of some requirements based on the experience of its application over the

past five years. The need for such improvements was identified through the CRU’s

experience of monitoring Irish Water’s compliance with the Handbook and its

communications with customers and with Irish Water since the Handbook was first

published.

• To incorporate Irish Water’s interactions with customers through its First Fix Free

Scheme which was approved by the CRU after the Domestic Customer Handbook

was published in 2014.


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• To provide assurance to customers that Irish Water has adequate plans in place in

the case of an emergency, for example, in the event of unplanned interruptions or

extreme weather conditions.

2.2 Legislative Remit and Strategic Objectives

The Water Services (No. 2) Act 2013 sets out the CRU’s functions as economic regulator of

Irish Water. Section 39 of the Act directs the CRU to protect the interest of customers and to

ensure that Irish Water performs its functions sustainably and in an economic and efficient

manner.

The Act provides the CRU with further powers in Section 32, which specifies that the CRU

must ensure that Irish Water provides adequate water and wastewater services to customers

through established Codes of Practice. Under legislation, these Codes of Practice should, in

particular, relate to Irish Water’s approach regarding communication with customers, billing,

metering, vulnerable customers and network operations.

Moreover, under section 32 (3), Irish Water is required by the CRU to prepare separate Codes

of Practice, which must, at a minimum, reflect the customer service requirements set out by

the CRU in the Irish Water Domestic Customer Handbook. Irish Water must submit each Code

of Practice for approval by the CRU. Under Section 32.3(b)3 of the Water Services (No.2) Act

2013 the CRU has the authority to approve or refuse to approve the Codes of Practice

developed by Irish Water.

Once the Code of Practice are approved, if Irish Water fails to meet the customer service

standards outlined in Irish Water’s Codes of Practice, the CRU has the authority to require

Irish Water to comply with the Codes of Practice or provision of a Code of Practice under

Section 32(5) of the Water Services (No.2) Act 2013.

The CRU was given further legislative powers under the Water Services Act 2017. This was

enacted in November 2017, amending the Water Services Act 2007 and the Water Services

(No.2) Act 2013. This Act provided the basis for the introduction of Excess Use Charges for

domestic water customers and the changes it brought about are reflected in the updates

proposed to the Handbook.

Under the CRU’s 2019 – 2021 Strategic Plan4, one of the CRU’s objectives is to “Proactively

and transparently place the public interest at the centre of the CRU’s policy development.

Ensure that the customer’s voice is heard and reflected in CRU’s decisions”.

The desired outcomes related to this objective are outlined in Figure 1 below.

3 http://www.irishstatutebook.ie/eli/2013/act/50/enacted/en/print#sec32 4https://www.cru.ie/wp-content/uploads/2019/03/CRU19030a-CRU-Strategic-Plan-2019-2021-English-Version.pdf

http://www.irishstatutebook.ie/eli/2013/act/50/enacted/en/print%23sec32

https://www.cru.ie/wp-content/uploads/2019/03/CRU19030a-CRU-Strategic-Plan-2019-2021-English-Version.pdf


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Figure 1: CRU’s Strategic objective and desired outcomes

A key outcome of this objective is for utility customers to have “…greater awareness of their

rights”. By consulting on proposed amendments to Irish Water’s Domestic Customer

Handbook the CRU achieves the objective of raising awareness of the rights of domestic

customers in respect of the service levels they can expect to receive from Irish Water. This

consultation also seeks their views as to how Irish Water’s service levels can be improved,

which will carefully be considered by the CRU before a decision is made on the Handbook,

thereby placing the “…customer voice in CRU decision making…”.

Further information on the CRU’s role and relevant legislation can be found on the CRU’s

website at www.cru.ie.

2.3 Context of the Review

The review of the Domestic Customer Handbook considers a wide range of issues regarding

the service Irish Water provides to customers. In this section, the CRU notes the sources the

CRU availed of, to develop its proposals:

2.3.1 Quarterly Reports

As set out in the Domestic Customer Handbook, Irish Water is required to submit quarterly

reports to the CRU outlining Irish Water’s performance regarding customer services. These

reports include information on complaints, vulnerable customers, planned and unplanned

interruptions water restrictions and boil water notices.

In addition, the CRU’s Customer Care team publishes quarterly reports which include

information on numbers of more complex complaints that could not be resolved by Irish Water

(and electricity and gas suppliers) and were referred to the CRU. These reports allow the CRU

to identify the types of complaints that Irish Water receives and to compare Irish Water’s

performance in complaint handling against electricity and gas suppliers. The CRU has used

the findings of these reports to note areas where customer protection could be strengthened.

http://www.cru.ie/


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2.3.2 CRU Monitoring

As part of ongoing policy developments since 2014, Irish Water has reported to the CRU on a

wide range of areas. These include quarterly reports on the operation of the First Fix Free

Scheme, six-monthly reports on customer service and environmental metrics under the

Performance Assessment Framework and its consumption data accumulated through regular

meter readings. Irish Water has also regularly reported on its delivery of capital projects, which

is published annually by the CRU. The CRU has also carried out compliance audits on aspects

of the domestic customer handbook.

This work has enabled the CRU to gain an understanding of how Irish Water delivers for

customers and has informed this review of the Handbook. The CRU has complemented data

received from Irish Water with analysis of approaches that other regulators are undertaking in

regulating customer services operation of water utilities. The CRU has also reviewed best

practice regulation, recent developments in this area and advantages and disadvantages of

different approaches to customer service requirements.

2.3.3 Compliance

The CRU monitors the compliance of regulated entities with their obligations under the

relevant primary and secondary legislation, licences, codes, and safety frameworks across the

various sectors regulated by the CRU. As part of its overall approach to compliance, the CRU

monitors Irish Water’s compliance with the Customer Handbook.

The CRU will assess Irish Water’s compliance with particular aspects of the Customer

Handbook requirements on an ongoing basis, as well as conducting an annual audit on the

Handbook requirements. The aim of these compliance checks is to protect consumers by

ensuring that Irish Water has in place processes and procedures which meet the requirements

of the Customer Handbook. The results of these checks will be published on the CRU website,

to increase transparency and provide confidence to Irish Water’s customers that Irish Water is

meeting its obligations.

2.4 Consideration of Principles-based vs. Prescription

The Domestic Handbook currently takes a fairly prescriptive approach to describing the

standards and service levels that Irish Water should meet, in order to demonstrate a high

standard of customer service.

When reviewing the Domestic Customer Handbook requirements, the CRU noted that some

sectors e.g. electricity and water sectors in the UK have moved towards a ‘principles-based’

approach to regulation. The CRU considered the merits of applying a more principles-based

approach to setting the customer service standards which Irish Water must provide to its

customers. This approach would mean moving away from reliance on detailed, prescriptive


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rules and relying more on high-level, broadly stated rules or principles to set the standards by

which regulated firms must conduct their business or provide services to customers. This

approach would focus on the overall goal or outcome itself and allows a utility autonomy in

how it seeks to achieve it.

For example, instead of prescriptively listing 20 separate pieces of information that are

required to be placed on a customer’s bill, a principles-based approach would replace such a

prescriptive list with a general principle that there should be sufficient information provided on

a customer’s bill to allow them to understand their charges and easily engage with the utility

should they have any concerns or queries.

The merits of a principles-based approach are as follows:

a) affords the utility the flexibility to offer their customers services that are better tailored to

their individual needs and may facilitate innovation in service provision;

b) may allow the utility to offer services in a more cost-effective way;

c) encourages the utility to take more ownership of, and have the freedom to evaluate,

what standards of service it should provide to its customers (as opposed to just

following prescriptive rules set by a regulator);

d) focuses on the outcome and allows the utility to be responsible for how they achieve

compliance;

e) encourages the utility to communicate with consumers and better understand their

needs;

f) a ‘hands-off’ approach affords greater trust in the utility and ensures that the regulator

may not have to maintain involvement in every nuance and detail of the utility’s

interactions with its customers.

This approach has been adopted internationally, for example by the water regulator in England

and Wales (Ofwat5).

However, having carefully considered the merits of introducing this approach, the CRU is of

the view that it is not appropriate to adopt a more principles-based approach at this point in

time for the following reasons:

• Irish Water is a relatively new utility compared to other utilities where a principles-

based approach has been implemented. This approach is more common in regulated

sectors that are more mature (and often have competitive markets), where regulation

5 https://www.ofwat.gov.uk/wp-content/uploads/20/03/CPCoP-v1.2.pdf

https://www.ofwat.gov.uk/wp-content/uploads/20/03/CPCoP-v1.2.pdf


21

of the service providers has existed in excess of 20 years and there are long-

established compliance and enforcement frameworks;

• Irish Water is the sole provider of public water and wastewater services in Ireland.

The principles-based approach may be more appropriate in a competitive market

where interpretations of customer service requirements may vary, and customers

have a choice of service provider.

• Adopting a more principle-based approach may create difficulty for enforcement and

auditing compliance with the Codes of Practice as divergent views of what particular

principles mean in practice in terms implementing services for customers may arise;

• Additionally, as principles may be open to interpretation, investigating and

responding to customer complaints may be more difficult and slow down the

resolution of such complaints.

Notwithstanding the decision to retain the prescriptive approach, the CRU has also proposed

to add overarching principles (Section 1.2 of the Handbook) which are intended to guide how

Irish Water should interact with customers. These principles are similar to those contained in

the CRU’s Energy Suppliers Handbook. They are intended as a general guidance and do not

lessen the prescriptive requirements of Irish Water under the various sections of the

Handbook.

As this Handbook is an evolving document, it is kept under review by the CRU to ensure that

the service standards remain appropriate as developments and policies in the water sector are

implemented over time. The move to a more principle-based approach will be considered once

again during the next review of the Handbook.

2.5 Related Documents

In order to provide context to this consultation paper, the following list of documents are

provided, which contain CRU consultations and decisions made in relation to the Domestic

Customer Handbook:

• Irish Water Domestic Customer Handbook with Tracked Changes (CRU/20/040);

• CRU approved Irish Water Domestic Customer Handbook – 14 November 2017

(CRU/17/319);

• Irish Water Customer Handbook (CER/15/010);

• CER Decision Paper on The Irish Water Customer Handbook (CER/14/363);

• Draft Irish Water Customer Handbook (CER/14/087);

• CER Consultation Paper on The Irish Water Customer Handbook (CER/14/086).


22

The CRU also has a number of documents related to the Non-Domestic Customer

Handbook, upon which it is also currently consulting:

• CRU Consultation Paper – Irish Water Non-Domestic Customer Handbook

Requirements (CRU/20/035);

• Irish Water Non-Domestic Customer Handbook (CRU/200/36).

Information on the CRU’s role and relevant legislation can be found on the CRU’s website at

www.cru.ie.

http://www.cru.ie/


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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


24

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.


25

‘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?


26

• 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.


27

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.


29

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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31

• 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:


32

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.


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.


33

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


34

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.


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


35

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.


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:


36

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.


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.


37


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.


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.


38

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.


39


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.


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


40

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.


41

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


42

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:


43

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.


44

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.


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.


45

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.


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


46

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:


47

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.


provision of Terms and Conditions to customers? Please provide rationale for

your answer.


48

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:


49

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:


50

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.


51

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 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.


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


52

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


53

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:


54

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.


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.


55

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.


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



56

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.


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.



57

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.


58

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


59

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:


60

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


61

information Irish Water will require to verify the change.

The exact wording of the new requirement is outlined below:

CRU Questions


how Irish Water must charge customers? Please provide rationale for your

answer.


household allowances and medical exemptions? Please provide rationale for your

answer.


wastewater charges? Please provide rationale for your answer.


calculation of charges? Please provide rationale for your answer.


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.


customers that request to be recategorized as a ‘domestic’, ‘mixed-use’ or

“Domestic” customer? Please provide rationale for your answer.


62

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


63

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:


64

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.


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


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.


charging information that must be included on the customer’s bill? Please provide



historical data that Irish Water must include on customer’s bills? Please provide



65

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”.


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.


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.


CRU Questions

42. Do you agree with the CRU’s proposed to remove a requirement in this section


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.


67

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”.


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


Water notifying customers of charges applicable to them? Please provide



68

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


69

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.


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.


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.


70

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.


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.



71

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.


customer who wish to avail of payment plans? Please provide rationale for your

answer.


72

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?


73

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.


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



74

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?


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?


75

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.

3.9.2 Unplanned Network Interruptions (Section 9.4)

This section sets out a requirement relating to timeframes for when Irish Water must restore

customer’s supply in the case of unplanned interruption.

Introducing a new requirement concerning Irish Water’s preparedness for emergency

events

The CRU proposes to add a new requirement that obliges Irish Water to inform customers

how they are prepared for emergency events. This is a common practice in other jurisdictions

and the CRU considers it a useful customer protection measure. One of the objectives of

reviewing the Handbook is to be consistent with the most recent regulatory developments.

Such information is readily available for customers of UK water utilities. The CRU considers

that it will be to customer’s benefit if the steps that Irish Water takes to ensure continuity of

supply are accessible for customers, for example, on the Irish Water’s website. This is

arguably now more relevant than ever due to climate change and the need to protect

customers during extreme weather events as experienced in Ireland in the last number of

years.



76

3.9.3 Customer Asset Flooding (Section 9.5)

This sub-section of the Handbook outlines Irish Water’s obligations in respect to a flooding of a

customer’s premises originating from an Irish Water asset.

Splitting of lengthy requirement relating to flooding at a customer’s premises

This subsection sets out a requirement relating to a situation where a customer’s premises is

affected by flooding. It states that where flooding occurs at a customer’s premises, and it is

assumed to originate from Irish Water’s asset, Irish Water will attend the affected premises

within four hours of the notification to attempt to stop the flooding. It also states that where it

can be proven that an Irish Water asset had failed and caused damage to a property then Irish

Water shall be obliged to engage with the customer to agree how to resolve or ameliorate the

damage. This requirement also explains that exceptions to this requirement exist where failure

of an asset is due to extreme or severe weather events which cause reasonable design

capacity of Irish Water assets to be exceeded. The CRU is proposing to retain this

requirement but split it into three separate requirements to make it clearer and easier to read.

As splitting of a lengthy requirement is an editorial change only, the CRU is not consulting on

splitting of this requirement.

Distinguishing between internal and external asset flooding

Currently where a customer informs Irish Water of asset flooding, Irish Water is required to

attend the scene within four hours. The requirement, however, does not distinguish between

internal asset flooding and external asset flooding. The CRU proposes to now distinguish

between internal and external flooding and extend the duration within which Irish Water must

attend an external asset flooding to 24 hours. This is consistent with utilities in other

jurisdictions who distinguish between the two scenarios. It acknowledges that while an

external flooding incident is serious, it may not carry the same degree of urgency as an

internal incident.


CRU Questions


Irish Water’s preparedness for emergency events? Please provide rationale for

your answer.


77

3.9.4 Water Pressure (Section 9.6)

This section sets out one requirement stating that in instances where a customer is

experiencing reduced water pressure, a customer can request that Irish Water investigates the

reduced pressure. This requirement includes a number of obligations on Irish Water, including

supplying the customer with information as to the likely cause of the pressure reduction,

carrying out an investigation, highlighting if the cause is due to a leak on the customer’s asset,

providing information to the customer if the cause is due to Irish Water activity or Irish Water’s

assets and giving advice within 10 working days as to how it intends to rectify the situation.

Splitting of lengthy requirement relating to reduced water pressure

The CRU is proposing to split this requirement into three separate requirements, to make the

requirements shorter, clearer and easier to read. In addition to this, the CRU proposes to

amend the text in this requirement to give a clear understanding of what the requirement

means as the previous wording could be interpreted in two different ways. As splitting of

lengthy requirement is an editorial change only, the CRU is not consulting on this amendment.

3.9.5 Out of Service Hours (Section 9.7)

This section sets out one requirement which obliges Irish Water to provide details of the

services it can provide for customers reporting an emergency. It also obliges Irish Water to

provide customers with a phone number available to customers 24 hours a day.

CRU Questions


customer’s asset flooding? Please provide rationale for your answer.


78

Amending a requirement relating to information Irish Water must provide to customers

on emergency reporting

The CRU proposes amending the requirement which obliges Irish Water to provide details of

the services for customers reporting an emergency by adding that Irish Water must provide

this information to customers through a range of appropriate communication channels. The

CRU considers this an important customer protection measure.


3.10 Code of Practice on Complaint Handling for Domestic

Customers

The Code of Practice on Complaint Handling for Domestic Customer outlines general

obligations which customers must follow when handling customer’s complaints. It also sets out

requirements on how Irish Water should monitor, resolve and report on complaints to the CRU.

This section provides a summary of amendments the CRU is proposing to introduce to the

existing Complaints Handling Code of Practice Handbook requirements.

The full list of the CRU’s proposed amendments to the customer service requirements is

detailed in the Irish Water Domestic Customer Handbook (CRU/20/040), which is published

alongside this document.

3.10.1 General Obligations in Complaints Handling (Section 10.2)

This section sets out the general requirements that Irish Water must follow during complaints

handling. The requirements cover issues such as obliging Irish Water to provide customers

with a clear process to follow when they wish to make a complaint, making every effort to

resolve customer’s complaints and ensuring that when a customer is not sure of the complaint

resolution process, that Irish Water directs them to the Code of Practice on Complaints

Handling.

Introducing a new requirement relating to clarification on complaint escalation to the

CRU Questions


Water’s out of hours service? Please provide rationale for your answer.


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CRU

For customers who wish to escalate their complaint to the CRU once they have completed

Irish Water’s complaint handling process (both the initial and escalation stage), under

legislation, the customer must be a registered customer of Irish Water for the CRU to accept

the complaint and offer a dispute resolution service.

The CRU is proposing to introduce a new requirement which requires Irish Water to facilitate

the registration of customers at the point that the customer first makes the complaint to Irish

Water. In the instance where the customer does not wish to register, Irish Water must explain

to the customer that in the event the customer may want to escalate the complaint to the CRU

once it has completed Irish Water’s complaints handling process, they will be unable to do so.


Adding clarity to requirements regarding Irish Water’s complaint handling process

The CRU proposes amending a requirement which obliges Irish Water, within their Codes of

Practice to provide a step-by-step easy to follow process for customers when they wish to

make a complaint. To add clarity to the requirement, the CRU proposes to clarify that in this

requirement the CRU refers to the “Code of Practice” as the Code of Practice on Complaints

Handling.

Also, for the requirement that specifies that Irish Water must appropriately attempt to resolve

complaints as soon as possible in-house, the CRU proposes to add that Irish Water must

appropriately attempt to resolve complaints as soon as possible in-house “before referring a

customer to the CRU”. The CRU considers that this amendment will clarify that customers can

escalate a complaint further if it cannot be resolved by Irish Water. Within this requirement the

CRU also proposes to remove the word “appropriately” from the requirement as it seems that

the word “appropriately” could cause confusion as to what is expected from Irish Water.

As both amendments are editorial changes only, the CRU is not consulting on those

amendments.


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Amending a requirement relating to making customers with a complaint aware of Irish

Water’s Code of Practice on Complaints Handling

Under the Handbook, Irish Water is required to refer a customer to Irish Water’s Code of

Practice on Complaint Handling when it is requested by the customer or where the customer is

unsure of the complaints process. However, the Customer Care team within the CRU, who

deals with complaints that are escalated to the CRU, have identified that in some instances

Customers are not fully aware of Irish Water’s complaints process. The CRU is therefore

proposing to amend this requirement so that Irish Water refers a customer to its Code of

Practice in all cases where a complaint is raised, not just when it is requested by the customer

or where the customer is unsure of the complaints process. This will ensure that all customers

that raise a complaint with Irish Water are fully informed of each stage of Irish Water’s

complaint process and Irish Water’s response times.

The rationale for amending this requirement is for it to cover a broader scope under which

customers could initiate a complaint to Irish Water, thus offering additional protection for

customers.



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Within this requirement the CRU also proposes to add that Irish Water where requested must

provide the Code of Practice to customers in an accessible format. The CRU considers that

the addition of this sentence is an important protection measure for vulnerable customers.

Restructuring a section relating to different stages of Irish Water’s complaint

resolution process

Currently, Irish Water’s complaints resolution process is made up of two stages, Stage one is

where customers can lodge a complaint with Irish Water and can expect a final decision on the

complaint within two months. If customers are not satisfied with how Irish Water resolved their

complaint, customers can escalate their complaint to a more senior level within Irish Water. At

that point the complaint moves to what is considered “Stage 2” of the process. Once Stage 2 is

completed and if the complaint is not resolved, Irish Water must refer customers to the CRU

so that if they are not happy with the outcome of the complaint resolution at Stage 2, they can

escalate the complaint further to the CRU.

To reflect on this issue the CRU proposes to add clarity to this section by adding some

subheadings that will clarify which complaints refer to which stage of the complaints resolution

process. As restructuring of this section is an editorial change only, the CRU is not consulting

on this amendment.

Stage 1 – Irish Water’s Initial Complaint Process

Amending a requirement relating to timeframes for resolving customer’s complaints

The CRU proposes to amend a requirement which obliges Irish Water to provide customers

with a resolution or a plan for resolution of their complaint within five working days. The CRU

proposes to clarify in the requirement that Irish Water must provide customers with a

resolution or a plan on how to resolve a complaint within five working days “after the complaint

was lodged with Irish Water”. This proposed amendment aims to add clarity as to what is

CRU Questions

57. Do you agree with the CRU’s proposal to Introduce a new requirement relating to

clarification on complaint escalation to the CRU? Please provide rationale for

your answer.


directing customers that are unsure of Irish Water’s complaints handling process

to Irish Water’s Code of Practice? Please provide rationale for your answer.


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expected of Irish Water under this requirement.


Adding clarity to a requirement regarding decision to Stage one of Irish Water’s

complaints handling process

The CRU also proposes to amend a requirement that obliges Irish Water to provide a

customer with a final decision on their complaint within two months. The CRU proposes to

clarify that Irish Water must provide customers with a final decision on their complaint within

two months “after the complaint was logged with Irish Water”. The CRU also proposes to

remove the word “final” from the requirement to avoid confusion and to clarify that this

requirement refers to a decision made at the end of Stage 1 which might not be a final

decision for customers that wish to escalate their complaint to Stage 2 of Irish Water’s

complaint resolution process. As adding clarity to this requirement is an editorial change only,

the CRU is not consulting on this amendment.

Introducing a new requirement relating to providing customers with an update on the

progress of their complaint

The CRU noted from Irish Water’s Domestic Customer Handbook Quarterly reports that there

was room for improvement regarding how Irish Water engages with customers throughout its

complaint resolution process.

Again, as mentioned in section 3.4.2 of this paper on customer charter commitments, the CRU

noted that a high number of customer complaints relate to “General Case – Follow Up”.

Also, according to the CRU’s monitoring of complaints that get escalated to the CRU, there

was a complaint where a customer wished to log a formal complaint with the CRU but was

having trouble in proceeding through Irish Water’s complaints process. The customer advised

the CRU that Irish Water was not following their own published complaints process and was

delaying issuing the final decision on this complaint, which ultimately delayed the customer

from escalating the complaint to the CRU.

To reflect on the above and to ensure that customers are kept up to date regarding the

progress of their complaint, the CRU is proposing to introduce a requirement that Irish Water

must contact a customer if their complaint remains open after 10 working days, with an update


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on the complaint progress.


Introducing a new requirement relating to providing customers with information on

how they can escalate their complaint

The CRU Customer Care Team (CCT) has noted that a significant number of customers

attempt to lodge their complaint with the CRU although they have not completed Stage 2 of

Irish Water’s complaints resolution process. The CRU noted that this is because Irish Water

does not make it clear to customers that there is also a second stage (Stage 2) of the

complaints process that they must complete if they wish to escalate the complaint further to

the CRU.

To ensure that customers are provided with information with how they can escalate their

complaint if they are not satisfied with the outcome of the initial stage of Irish Water’s

complaints process, the CRU is proposing to add the following change to the Handbook:


CRU Questions


timeframes for resolution of customers complaints? Please provide rationale for

your answer.


Irish Water providing customers with an update on the progress of their

complaint? Please provide rationale for your answer.


informing customers of how they can escalate their complaint further? Please



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Stage 2 – Irish Water Escalation Complaints Process

Introducing a new requirement relating to a timeframe on escalation of customers’

complaints

Irish Water, within its Codes of Practice, has committed that if a Customer wishes to escalate

their complaint to Stage 2 of Irish Water’s resolution process that Irish Water will provide

customers with a decision on this complaint within 10 working days. This particular timeframe

is not covered by the existing Handbook requirements because it was a subject to an

agreement between Irish Water and the CRU after the publication of the Handbook in 2014.

The CRU notes that Irish Water is not currently meeting this target for resolving complaints

that go to Stage 2 of their complaints resolution process. This is evident in Irish Water’s

Domestic Customer Handbook quarterly reports which indicate that a high number of

complaints are open for longer than 70 days, e.g. over 250 in 2019, 500 in 2018 and 100 in

2017. In addition, a high number of complaints are categorised as “Timeliness of Complaints”,

e.g. over 100 in 2019, 1,000 in 2018 and 550 in 2017.

Considering that Irish Water has committed to respond to customer’s complaints within 70

days (60 days for Stage 1 and 10 days for Stage 2) it appears that this is an area where an

improvement in customer service performance is required.

Also, as reported in the CRU’s Customer Care’s Quarterly reports the CRU understands that

some customers have experienced difficulties in moving a complaint through the different

stages and not being aware of whether or not the complaint has been escalated. To address

this, the CRU proposes to add the following requirement:

Adding clarity to a requirement relating to Unresolved Complaints

The CRU proposes to amend a requirement that, in the case where a complaint was

unresolved other than ones relating to water quality or pollution incidents that Irish Water will

direct complaints to Codes of Practice applicable to Irish Water. The CRU proposes to replace

the word “complaint” with “a Customer” to clarify that Irish Water must refer all “Customers “not

“complaints”. The CRU also proposes to amend “Codes of Practice applicable to Irish Water”

with “all applicable Codes of Practice”. As this amendment is an editorial change only, the

CRU is not consulting on this amendment.


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Escalation to the CRU on completion of Stage 1 and 2 of Irish Water’s

Complaints Process

Restructuring and adding clarity to a requirement relating to information that Irish

Water must provide in their Code of Practice on complaint handling

The CRU proposes to restructure the requirement which obliges Irish Water in its Code of

Practice, to outline details on how customers can contact the CRU and specifies the

information that Irish Water must communicate to customers in doing so. To add clarity to the

requirement the CRU proposes to list out the information that Irish Water must include in its

communications with Irish Water in bullet points.

Within same requirement, the CRU proposes to add that Irish Water should only refer a

Customer to the CRU if it has completed Stage 2 of Irish Water’s complaint resolution process.

As the above amendments are editorial changes only, the CRU is not consulting on those

amendments.

Adding clarity to a requirement relating to Irish Water referring customers to the CRU

The CRU proposes to amend a requirement that obliges Irish Water to inform customers in

writing of the closure of their complaint. In this communication, Irish Water must provide

contact details of the CRU’s Customer Care Team if they wish to escalate their complaint.

The CRU proposes clarifying in the requirement that Irish Water must provide customers

with details of CRU’s Customer Care Team if they wish to escalate their complaint “to the

CRU”. As this amendment is an editorial change only, the CRU is not consulting on this

amendment.

Implementation of CRU final Decision

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

To ensure that Irish Water has implemented the CRU’s final decision on a complaint which

was escalated to the CRU by a customer, the CRU is proposing to introduce a new

requirement obliging Irish Water to respond to the CRU within three weeks from the date of the

CRU’s final decision (or by a date specified by the CRU in its decision) confirming that the

CRU’s final decision has been implemented. This will benefit customers by ensuring that Irish

Water implements the CRU’s final decision on their complaint in a timely manner.



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3.11 Terms and Conditions

Terms and Conditions section of the Handbook obliges Irish Water to maintain a set of Terms

and Conditions. This section sets out the minimum content Irish Water must include in its

Terms and Conditions and sets out the CRU’s review process for same.

Introducing a new requirement on how Irish Water provides customers with Terms and

Conditions

The CRU proposes to lift the obligation on Irish Water to issue its Terms and Conditions to

each customer individually, and instead, oblige Irish Water to make the Terms and Conditions

available for customers on its website. The CRU therefore proposes to introduce a new

requirement into this section that obliges Irish Water to make its Terms and Conditions

available on their website.


Removing a requirement relating to the information that Irish Water must provide to

customers in their Terms and Conditions

As mentioned above, the CRU proposes to lift the obligation on Irish Water to issue its Terms

CRU Questions

62. Do you agree with the CRU’s proposal to Introduce a new requirement relating to

a timeframe on escalation of Customers’ complaints? Please provide rationale for

your answer.


Irish Water responding to the CRU with a confirmation of Irish Water

implementing the CRU’s Final Decision on a complaint? Please provide rationale

for your answer.


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and Conditions to each customer individually, and instead, oblige Irish Water to make their

Terms and Conditions available on its website. To reflect this, the CRU proposes to remove a

requirement which, within its Terms and Conditions, obliges Irish Water to include a letter

addressed to each customer to specify to whom the Terms and Conditions are referring.


Amending a requirement relating to information that Irish Water must include in their

Terms and Conditions

The CRU proposes to amend the requirement that obliges Irish Water in its Terms and

Conditions, to set out details of how the Customer will be billed, and the terms associated with

payment of bills. The requirement also specifies in brackets that billing frequency must be set

out in Irish Water’s standard Terms & Conditions or the additional Terms & Conditions

associated with the applicable tariff. To reflect the CRU’s decision on Excess Use Charges,

the CRU proposes to remove the sentence relating to billing frequency as it is no longer

applicable.


CRU Questions

64. Do you agree with the CRU’s proposal to amend a requirement on how Irish

Water provides customers with Terms and Conditions? Please provide rationale

for your answer.


information that Irish Water must include in their Terms and Conditions? Please



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4. Conclusions and Next Steps

The CRU is of the view that this review will refresh the Handbook and make it fit-for-purpose,

reflecting CRU policy decisions and legislative updates over the past six years. The proposed

updates also appropriately reflect the findings of CRU’s compliance monitoring and quarterly

reports and ensure consistency with recent regulatory developments in other jurisdictions. It

also offers greater protections to customers in the event of a breach of a charter commitment

and reflects the CRU’s recent decision on Excess Use Charges.

As part of the review the CRU proposes to introduce, remove and amend requirements in

different sections of the Handbook. The CRU will take into consideration feedback from

interested parties before considering its decision. The CRU also made some minor

amendments to the Handbook that aim to improve the consistency of language throughout the

document and increase its clarity and transparency. While these minor amendments are not

open for public consultation, the CRU considers it important for readers to note them and

understand how they impact the Handbook.

Following the eight-week consultation period, the CRU will analyse responses submitted to the

CRU by interested parties and will aim to publish its decision on the Domestic Customer

Handbook Review in Q2 2020.

CRU Disclosure Requirements

Unless marked confidential, all responses from companies or organisations may be fully

published on the CRU’s website. Respondents may request that their response is kept

confidential.

The CRU shall respect this request, subject to any obligations to disclose information.

Respondents who wish to have their responses remain confidential should clearly mark the

document to that effect and include the reasons for confidentiality.

Responses from identifiable members of the public will be anonymised prior to publication on

the CRU website unless the respondent explicitly requests their personal details to be

published.

The CRU privacy notice sets out how we protect the privacy rights of individuals and can be

found here.



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