Castle Water CEO John Reynolds sets out the details of Ofwat’s decision that water charges are now payable by all customers who temporarily closed during the lockdown

  • If you have closed during the lockdown and haven’t told us you have reopened, you will shortly receive a bill for the period from 1 August, the latest date Ofwat permits us to treat you as having been closed.
  • If your water consumption has reduced, you should send us two meter readings one month apart, so that we can charge you based on this lower consumption – we will take your new usage into account on your subsequent bill.
  • Our initial invoices may be for a shorter period than normal so that we can reflect your new usage as early as possible when we produce subsequent bills.
  • From 1 August, your charges can be reduced if you are “vacant”, but not just closed – the criteria required by Ofwat for this are set out below, which include there being no stock or furniture present.
  • You can pay by monthly direct debit to spread the payments over a longer period.

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Managing your water charges - meter reading and Reassessment

You may be able to reduce your water charges:

  • Take meter readings if your consumption has reduced. It is possible to establish a revised level of charging by providing us with two meter-readings one month apart, which will ensure your bill reflects current consumption and not pre-COVID levels (we will take as many meter readings as we can ourselves, but realistically we can’t read all the meters in the first few months after the end of the lockdown). You can submit meter readings. Ofwat has stated that: Where meters cannot be read, Retailers should continue to work with customers to request a meter read if it is safe to do so.
  • Send meter readings before you receive your next bill: we use the most up to date meter readings to produce bills. If you want to provide a new meter reading, you should send this at least 10 days before you expect your next bill. We send most bills at six-monthly intervals.
  • Tell us what date you moved back in. We want to bill you correctly – you can update us on the dates you were temporarily closed.
  • Complete a Reassessment application. If you have Assessed charges and have changed numbers of FTE staff, opening hours or other operational aspects of your business, you may be able to apply for a Reassessment by completing an application.

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Ofwat’s consultation

Ofwat commenced on 9 July consultation on Covid-19 and the business retail market and published the results of on 30 July, which came into effect on 1 August. Ofwat has decided that no customer can be treated as being closed due to Covid-19 after 31 July, and has drawn a distinction between being closed and being unoccupied:

while we are aware of legislation requiring businesses or parts of businesses to close and enabling restrictions to be imposed on the occupiers of premises, we are not aware of any legislation that has prohibited premises from being occupied

To be treated as being vacant, customers must conform with the definition in the Codes (CSD 0104, clause 3.1.4):

A premises is considered to be Vacant Premises if all of the following criteria are met:

(a) there is no physical occupation by any person, for any purpose, other than for the sole purpose of providing security services for the premises, for example as a security guard;

(b) the premises is not open or available to the public or visitors;

(c) there is no stock left in the premises, except where these items have been abandoned by a former tenant and the premises is not in use;

(d) there are no moveable items left on the premises such as furniture, equipment tools or moveable equipment or machinery;

and (e) any fixtures and fittings have been abandoned by a former tenant and the premises is not in use

Ofwat will not reinstate reduced charges for temporary closures where there is a local lockdown.