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FY2023 Annual Report · NatWest Group
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NORTHUMBRIAN 
WATER LIMITED 
ANNUAL 
PERFORMANCE 
REPORT 
For year ended 31 March 2023 

NORTHUMBRIAN WATER LIMITED ANNUAL PERFORMANCE REPORT 

14 July 2023 
PAGE 1 OF 211 

 
 
 
 
 
 
 
FOR NORTHUMBRIAN WATER LIMITED ANNUAL PERFORMANCE 
REPORT FOR YEAR ENDED 31 MARCH 2023 

CONTENTS  

BOARD STATEMENT 

CHIEF EXECUTIVE OFFICER’S WELCOME 

WATER FORUM STATEMENT 

WHO WE ARE 

VISION AND VALUES 

OUR PURPOSE 

OUR OUTCOMES 

OUR STAKEHOLDERS 

ASSURANCE SUMMARY 

INTRODUCTION 

OUR ANNUAL PERFORMANCE AT A GLANCE – SERVICE 

OUR PERFORMANCE AT A GLANCE – ENHANCEMENTS  

OUR 2022/23 PERFORMANCE IN DETAIL 

UNRIVALLED CUSTOMER EXPERIENCE:  

•  Our customers tell us we provide excellent customer service and resolve issues quickly 

•  Our customers say they feel informed about the services we provide and the importance of water 

•  Our customers say we are a company they trust 

•  Our finances are sound, stable and achieve a fair balance between customers and investors. 

AFFORDABLE AND INCLUSIVE SERVICES:  

•  Our  customers  say  our  services  are  good  value  for  money  and  we  work  hard  to  keep  water  and 

wastewater services affordable for all 

RELIABLE AND RESILIENT SERVICES:  

•  We are resilient and provide clean drinking water and effective sewerage services; now, and for future 

generations 

•  We always provide a reliable supply of water 

•  Our drinking water is clean, clear and tastes good 

•  Our sewerage service deals with sewage and heavy rainfall effectively 

LEADING IN INNOVATION:  

•  We are an innovative and efficient company 

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IMPROVING THE ENVIRONMENT:  

•  We help to improve the quality of rivers and coastal waters for the benefit of people, the environment and 

wildlife 

•  We take care to protect and improve the environment in everything we do, leading by example 

BUILDING SUCCESSFUL ECONOMIES IN OUR REGIONS:  

•  We are proud to support our communities by giving time and resources to their important causes  

•  We work in partnership with companies and organisations to achieve the goals that are most important to 

our customers  

14 July 2023 
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BOARD STATEMENT – OUR PURPOSE, VISION, AND PERFORMANCE 

This  statement  outlines  the  Board's  vision  for  Northumbrian  Water  Limited,  detailing  our  goals  for  delivering 

services to customers and stakeholders – both now and in the future. It also covers our performance in achieving 

these goals and how we structure management rewards to encourage the fulfilment of our aspirations. 

Guided by our Purpose and a long-term vision to become the leading provider of sustainable water and wastewater 

services nationwide, the Board sets ambitious goals for both itself and the company's employees. We strive to 

enhance our performance each year to meet and exceed our customers' high expectations. This entails consistently 

delivering exceptional service in our water and wastewater businesses while upholding the highest standards of 

environmental performance. 

At  the  core  of  our  mission  lies  the  drive  to surpass  existing  benchmarks.  We  recognise  the  significance  of  the 

current landscape, and we are keenly aware that it necessitates our unwavering  commitment to raising the bar 

even higher.  

How we set our aspirations  

The aspirations we set for the current price control period 2020-25 were developed through extensive engagement 

and consultation with customers and other stakeholders throughout our business planning process. Through this 

engagement, the company agreed updates to our Outcomes for customer service, the environment, and the way 

we manage the business. For each Outcome, we agreed challenging Performance Commitments (PCs) which we 

use to monitor and report on our performance.  

In this report, we set out our Outcomes and how we deliver these across our strategic themes, as well as through 

our Purpose and Values. We report on our performance against our Outcomes and PCs in this report.  

However, to drive the year-on-year performance improvements necessary to deliver our Vision of being national 

leader,  we  set  ourselves  tougher,  stretching  targets  within  the  business.  These  targets  are  reported  internally 

through a balanced scorecard of key  performance indicators which cover the full range of strategic themes that 

support our Vision. We re-set these targets each year, taking account of how other companies in the industry have 

performed and what our customers have told us about their priorities.  

We also work closely with the Water Forum, which brings together expertise from a wide range of stakeholders. 

Our  Independent  Non-Executive  Directors,  and  Executive  Directors,  regularly  attend  Forum  meetings  and 

workshops. This ensures that the Board directly understands the areas where Forum members are challenging us 

to improve performance and Outcomes for our customers and stakeholders.  

To  align  the  Executive  Leadership  Team’s  focus  with  the  business  Outcomes  we  want  to  attain,  performance-

related  elements  of  pay  are  dependent  upon  the  achievement  of  stretching  internal  targets  from  across  our 

balanced scorecard of performance measures. Both short-term and long-term incentive plans are structured with 

60% related to targets delivering benefits for customers and the environment and 40% related to financial targets. 

The Remuneration Committee Report is available within our Annual Report and Financial Statements and provides 

full, transparent detail on our directors’ remuneration policy and how remuneration in the year has been calculated.  

14 July 2023 
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Performance in 2022/23  

This report describes our performance in 2022/23 against our Performance Commitments (PCs) in detail.  

We’re delighted to have achieved our ambition to be in the top two companies for  C-MeX (securing the number 

one spot), the measure for customer experience and are very proud to have scored significantly above average in 

many categories in the 2022 Water Matters Report carried out by CCW in relation to satisfaction with value for 

money, trust and customers saying we care about the service we give.  

Thanks to an innovative approach to partner working and data sharing we are helping more vulnerable customers 

than even before. We acknowledge the impact of the current cost-of-living crisis, which has led to a growing number 

of individuals experiencing water poverty. Regrettably, we have not achieved our ambitious target in addressing 

this issue. While we are disappointed with this outcome, it is important to note that we have made significant efforts 

to  assist  more  people  and  have  heightened  our  focus  on  raising  awareness  about  the  available  support.  Our 

commitment  remains  steadfast  as  we  strive  to  innovate  and  proactively  tackle  the  challenges  arising  from  the 

broader socio-economic landscape.  

Although we have received positive feedback from customers regarding taste, odour, and discoloration, we are 

disappointed to have fallen short of our own rigorous water quality standards. Our goal remains to achieve industry-

leading levels of Compliance Risk Index (CRI), and we are actively implementing our long-term plans to meet this 

objective, working closely with the Drinking Water Inspectorate (DWI) to address any areas of concern.  

Last  year,  we  faced  an  extremely  demanding  operational  environment  due  to  the  hot  and  dry  summer, 

characterised by record-breaking temperatures in mid-July. These extreme weather conditions led to a substantial 

increase in burst mains and other asset failures, presenting significant challenges for our operations. 

Despite  our  best  efforts,  reducing  leakage  in  our  NW  region  became  exceptionally  difficult  under  these 

circumstances, and as a result, our performance in addressing mains bursts was adversely affected. We recognise 

the  importance  of  addressing  these  issues  and  are  committed  to  implementing  measures  to  improve  our 

performance in such challenging situations going forward by prioritising how we respond to such extreme weather 

events.  

We are on track for our ambitious goal to achieve Net-Zero status in relation to our operational greenhouse gas 

emissions by 2027 and are on track to achieve zero avoidable waste by 2025. 

While attaining the 4-star rating in the Environmental Performance Assessment (EPA) has become increasingly 

challenging, we are pleased to report that our environmental performance has shown continuous improvement. 

Our company consistently surpasses average standards, achieving a commendable 3-star rating, which places us 

among the leaders in the sector. 

Notably, we have achieved some of the lowest levels of serious pollution incidents compared to other companies. 

Additionally, an impressive 32 out of our 34 bathing waters have received good or excellent ratings, demonstrating 

our commitment to maintaining high standards of water quality. 

14 July 2023 
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We take pride in our strong environmental performance and will continue to prioritise sustainable practices and 

initiatives. Our goal is to ensure the long-term well-being of the environment while providing reliable services to our 

customers. 

We have achieved significant progress in our internal sewer flooding performance, with an improvement of more 

than 30% compared to last year's reported figures. This success can be attributed to the ongoing development and 

effectiveness of our sewer flooding tactical plan, which was initiated in 2019. 

We welcome the key role that the Water Forum play in providing challenge on behalf of our customers. As part of 

this process, we report to and discuss our performance with the Water Forum and they provide their independent 

commentary on pages 11-13.  

Looking to the future  

We  have updated  A  Vision  for  our  Coasts  and  Rivers,  to set  out  the  progress  we have made  against  the  nine 

pledges we have made to water quality and our programme of work to 2025 that will help us achieve our goals. 

They include reducing spills from our storm overflows to an average of 20 per year by 2025. 

We place great importance on actively listening to our customers and gaining a comprehensive understanding of 

their present and future expectations. To facilitate this, we have implemented a tailored customer research and 

engagement  program  specifically  designed  for  our  PR24  business  planning.  Through  this,  we  seek  to  gather 

valuable  insights  from  our  customers  regarding  crucial  aspects  of  our  future  plans,  including  our  long-term 

strategies.  

We’re pleased that the upcoming price review will focus on delivering greater environmental and social value as 

we already work hard to protect our rivers and beaches. In keeping with our commitment to our communities we 

have maintained our ambitious local spending goal of spending 60p in every £1 locally.  

As a Board, our unwavering commitment persists in our drive to become the national leader. We are dedicated to 

consistently providing exceptional service to our valued customers and other stakeholders, not just in the present, 

but also in the years to come. 

Signed on behalf of the Board of Northumbrian Water Limited:  

By order of the Board 

Andrew J Hunter 

Chairman 

Heidi Mottram 

CEO 

Alan Bryce 

Senior Independent 

Non-Executive Director 

14 July 2023 
PAGE 6 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Dominic Chan 

H L Kam 

Duncan Macrae 

Non-Executive Director 

Non-Executive Director 

Non-Executive Director 

Jacquie McGlade 

Bridget Rosewell 

Richard Sexton 

Independent Non-Executive Director 

Independent 
Director 

Non-Executive 

Independent Non-Executive 
Director 

Peter Vicary-Smith 

Independent Non-Executive Director 

14 July 2023 

14 July 2023 
PAGE 7 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CEO’S WELCOME 

Our vision is to be the national leader in the provision of sustainable water and wastewater services. We are a 

purpose-led organisation and our purpose shapes all our plans and activities. We set out ambitious goals for the 

2020-25  period,  reflecting  feedback  from  our  customers,  and  I  am  pleased  that  once  again  we  have  been 

successful in achieving a high proportion of the targets we report in our balanced scorecard. 

I am particularly delighted that we are first in the industry for customer service as we always strive to deliver an 

unrivalled  customer  experience.  We  have  also  continued  to  deliver  good  environmental  performance  with  no 

serious  pollution  incidents  and  further  reductions  in  sewer  flooding.  However,  we  recognise  that  customers’ 

expectations  are  increasing,  especially  in  relation  to  river  and  bathing  water  quality,  and  we  are  committed  to 

delivering  the  nine  ambitious  pledges  we  set  out  in  ‘A  Vision  for  our  Coasts  and  Rivers’  to  improve  our  water 

environment. 

Although our overall performance was strong, we were disappointed to fall short on water quality. We are working 

closely  with  the  Drinking  Water  Inspectorate  and  have  significantly  increased  our  investment  to  improve 

performance  in  this  area  to  the  same  level  as  our  customer  service  performance.  I  am  confident  that  with  our 

remarkable team, shared vision, right level of investment and relentless pursuit to be the national leader, we will 

continue to build upon the strong foundation we have laid. 

Customer 

I am thrilled to be able to say we are the industry leader for customer experience, achieving top place for C-MeX, 

Ofwat’s measure of customer service. This has been the result of a one team effort across our business to deliver 

world class service to our customers. I am also proud that we were joint top among water and sewerage companies 

(WASCs) for trust in CCW’s Water Matters report. 

We also know that it’s really important to our customers that we keep our services as affordable as possible. The 

past  three  years  have  seen  a  period  of  significant  economic  upheaval,  with  the  Covid-19  pandemic  and  high 

inflation creating a cost-of-living crisis. As a result we have seen more customers reaching out to us for financial 

support and have increased the number of customers receiving support by more than 50%. 

Our data sharing arrangement with the Department for Work and Pensions (DWP) is just one of the ways in which 

we’re taking proactive steps to identify customers who would benefit from support arrangements. We have clear 

plans  in place  to  both  expand,  and  increase  awareness  of, the  support  we  can  offer.  We  remain  committed  to 

having zero water poverty in our areas by 2030. 

Environment  

Our environmental performance remains strong and in North East England we have some of the lowest levels of 

pollution and cleanest rivers and beaches in the country. However, we know that customers and stakeholders are 

increasingly concerned about spills from storm overflows into rivers and the sea, and we know we need to do more.  

We have recently updated ‘A Vision for our Coasts and Rivers’ on our website, to set out the progress we have 

made against the nine pledges we have made in respect of our water environment and our programme of work to 

2025 that will help us achieve our goals. We are investing substantial amounts in the current regulatory price period 

towards reducing our use of storm overflows and upgrading our wastewater network and are already planning a 

14 July 2023 
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massive environmental programme of around £1.7bn over the next few years to stop storm overflow spills and 

improve the environment, adopting nature-based solutions wherever possible. 

This isn’t the only area where we are making improvements though and I was very pleased that we had no serious 

category  1  and  2  pollution  incidents  in  2022.  We  have  achieved  further  reductions  in  sewer  flooding  incidents 

continuing our trend of improvement in each year of this price control period. I was delighted that Bin the Wipe, one 

of  our  initiatives  which  has  been  pivotal  to  this  improvement,  has  now  been  adopted  across  the  industry  and 

launched as a national campaign, approved by Parliament. 

Water  

In discussions with our customers, they consistently tell us their top priority is good quality water and we are in the 

middle of a five-year plan with the Drinking Water Inspectorate to improving drinking water quality across both of 

our operating regions, involving an increase in our capital investment programme. However, these investments can 

take a few years to deliver results and we were disappointed to not hit the high standards we aim for in the DWI’s 

Compliance Risk Index measure of water quality, although we have achieved our best performance to date in our 

customer facing measures of the appearance, taste, and smell of water. 

Maintaining  resilient  water  supplies  is  another  priority  for  our  customers  and  work  is  underway  on  a  £155m 

investment programme to upgrade and futureproof the water supply network across the south of County Durham 

and into the Tees Valley. We were also pleased to gain support for the acceleration of investment to improve the 

resilience of water supplies in our Suffolk operating area. 

We had a mixed year weather-wise, with extreme conditions causing problems for our water network. The hot, dry 

summer saw record-breaking temperatures in mid-July 2022 resulting in a significant increase in burst mains and 

other asset failures. We then experienced a freeze/thaw event just prior to Christmas which caused further issues. 

Although  we  were  pleased  to  achieve  our  leakage  reduction  target  in  our  water-stressed  Essex  and  Suffolk 

operating areas, we were unable to drive leakage down sufficiently to achieve our target in our Northumbrian area, 

despite increasing resources significantly. 

We  are  continuing  to  drive  innovation  in  this  area  and  trialled  a  number  of  new  and  exciting  technologies  and 

techniques in the year. For example, we introduced a new ‘No Dig’ method of leakage repair and are now working 

to scale this up, and we’re also leading on the development of a new National Leakage Research and Test Centre. 

Innovation  

Innovation  is  one of  our  core values and  we  have been  working  for many years  to  create  a  thriving  innovative 

culture. It is always pleasing to see ideas being developed into practical use. One example of this is the National 

Underground Asset Register, an interactive, digital map of underground pipes and cables, which will revolutionise 

the way we install, maintain, operate, and repair our buried infrastructure. This idea came out of our Innovation 

Festival in 2018 and we were extremely proud to see this being launched by the Geospatial Commission in April 

2023, initially covering North East England, Wales and London ahead of a national roll out over the next two years. 

We are open to innovative ideas from any sources and, as well as continuing to have great success through the 

Ofwat Innovation Fund, we encourage ideas from our own people. One such idea is the use of microalgae to treat 

industrial effluent and generate biogas. This was successful in our internal InvestQuest  competition, and we are 

currently upscaling it for operational use. 

14 July 2023 
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Our People and the Communities we serve 

I firmly believe that the success of any company lies in the strength of its people, and I am surrounded by a team 

that embodies our core values and shares a common passion for excellence. We’ve embedded our TIDE (Together 

for Inclusion, Diversity and Equity) Strategy over the last year, fostering an environment where everyone's voices 

are heard, ideas are valued, and diverse viewpoints are respected. We were once again awarded Great Place to 

Work Certified Employer status, further increasing our already high internal engagement and trust scores, and our 

Living Well approach to wellbeing offering has been recognised nationally with several awards. 

We’ve  been  named  the  world's  ‘most  ethical'  water  company  for  the  twelfth  time  in  the  World’s  Most  Ethical 

Companies  list,  compiled  by  Ethisphere,  and  are  one  of  only  two  UK  companies  on  the  list.  For  the  second 

successive  year,  we  were  also  the  only  water  company  awarded  the  Good  Business  Charter,  which  involves 

demonstrating  good  practice  across  a  number  of  areas  including  employment  practices,  environmental 

responsibility, fair tax and procurement. 

Our annual report serves as a testament to our collective achievements, as we have strived to provide safe, clean, 

and  sustainable  water  solutions  to  our  communities  while  facing  the  increasing  effects  of  climate  change.  The 

impact of our work extends far beyond numbers and figures; it lies in the positive influence we have on our local 

economies, where we have achieved our goal of spending 60p in every £1 we spend locally, the environment, and 

the prosperity of the regions we serve. 

Looking forward  

We have completed three years of our current five-year price review period and have made significant progress 

towards  the  ambitious  goals we  set  in  Our  Plan.  We  will  continue  to  drive  this  forward over  the  coming  years, 

building on our strong foundations in areas such as customer service and environmental performance. Equally we 

must improve our performance across water quality and leakage and continue to invest in the resilience of our 

assets, as well as preparing for the challenges of the next period. 

Our planning for the period 2025-30 is well advanced, ahead of submission in October of this year. Our business 

is inherently long term, and we are developing our plan in the context of our long-term strategy to 2050 and the 

areas  where  we  will  need  to  make  new  investment  to  ensure  sustainable  water  supplies,  protecting  the  local 

environment, deliver Net Zero and maintain resilience. 

We make sure our customers are at the heart of every decision we take and have consulted extensively to ensure 

we understand what is important to our customers and stakeholders. We know that will be undertaking a huge 

increase  in  capital  investment,  including  to  address  storm  overflows,  which  will  need  to  be  funded  through  a 

combination of borrowing, shareholder equity and increases in customer bills. Getting the right balance between 

investing in our services, environmental improvements and the affordability of customer bills is not easy, and it’s 

important to us that the views of our customers inform those decisions. 

We  are  proud  of  our  achievements  to  date,  but  we  are  never  complacent  and  will  continue  to  invest  in  further 

improvements over the coming years. 

H Mottram CBE, CEO 

14 July 2023 
PAGE 10 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
  
WATER FORUM STATEMENT  

Each year, members of the Water Forum, which is Northumbrian Water Limited’s (NWL) Independent Challenge 

Group (ICG), have the opportunity to review the company’s results against the promises made to its customers in 

the 2020-2024 business plan it agreed with Ofwat.  

This review covers the 12 months to the end of March 2023: a period during which the water industry has often 

been under critical spotlight, and UK economy has experienced levels of inflation not seen in a generation, fuelling 

a cost-of-living crisis that affected residential and business customers alike. It has also been a period during which 

the impacts of climate change continued to be observed and felt by all. These factors are likely to continue to be 

extremely influential in the year ahead, so have been front of mind when considering the comments and challenges 

offered below.  

In parallel with our review of this year’s performance, we are providing independent challenge to NWL as it develops 

its  next  business  plan,  from  which  customers’  water  and  wastewater  prices  will  be  set  for  2025-2029.  Current 

performance has been key in our considerations and challenges to the company as we look ahead to this time 

horizon and beyond.  

Customer Service 

For two years the Water Forum challenged NWL to improve its contact centre’s provision of customer service. We 

are  therefore  very  pleased  to  note  that  the  company  finished  top  in  the  industry  overall  in  Ofwat’s  Customer 

Experience Measure and also rated as giving best overall customer service in the Consumer Council for Water’s 

latest research (the 2022 Water Matters Report). These results show what NWL can achieve when it applies a lot 

of management focus on an issue, and we challenge the team to sustain the improved position and to adopt the 

same ethos for reducing the response time to written customer complaints as well as the other areas we highlight 

below. 

Water Poverty 

There  is  some  good  news  in  NWL’s  performance  results  –  we  see  the  number  of  customers  being  reached 

regarding Priority Services has substantially increased although there is more to do in this area, and the company 

exceeded its targets for the satisfaction of those customers who receive additional financial support.  

However, demand for support has soared and is likely to continue to do so in the coming year – having achieved 

an improving trend in the percentage of households living in water poverty in previous years, unfortunately we see 

a reversal in last years’ results.  

Given that we believe this is due in no small measure to the national cost-of-living crisis, we are very surprised to 

see  that  the  results  for  awareness  of  additional  financial  and  non-financial  support  available  measures  have 

remained stubbornly low and below target. In our view, this indicates that NWL needs to use substantially different 

tactics for making customers aware of what is available to them. We therefore challenge the company to focus on 

and think innovatively about what form a radically different approach could take. 

Environment and climate change resilience  

Water  Forum  members  are  pleased  to  note  NWL’s  commitment  to  and  performance  in  its  water  environment 

improvements measure – the initiative has been an excellent way of enabling customers to connect with the natural 

environment.  

14 July 2023 
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We are encouraged by the direction that the company is taking in its Vision for Coasts and Rivers, although there 

is much to do to achieve the ambitions it contains. Getting more customers and communities involved in their local 

environment, through initiatives such as Water Rangers will be important for success in this area. 

We  welcome  NWL’s  strong  performance  overall  in  relation  to  the  environment.  That  noted,  it  is  going  to  be 

increasingly  challenging  to  maintain  this  level  of  performance  and  environmental  reputation.  Not  only  have  the 

compliance criteria been tightened, but the company has already addressed the more straightforward issues, which 

leaves the trickier, more complex ones to tackle. We note this latter point also applies to the future reductions in 

greenhouse gas emissions measure, for which NWL substantially and positively exceeded its target this year.  

We note that NWL narrowly missed its performance target for mains repairs and attributes this to record summer 

temperatures and winter freeze-thaw events. In our view, such weather events should now be considered as the 

norm due to climate change. This measure is therefore likely to remain challenging, so the preventative modelling 

and other actions described in this report will be essential tools in endeavouring to meet targets next year.  

Our comments on the interruptions to supply measure are of the same nature, in particular the need to increase 

the water network’s operational resilience in the event of a power outage – most notably in the Northumbrian Water 

region where most of the power supply is above ground. We do, however, welcome the work the Company is doing 

to address such issues. 

Pollution incidents, including those caused by Storm Overflows, are high on the public interest agenda. We are 

therefore encouraged to note that pollution incidents were better than target and compared to the previous year, 

albeit that they remain higher than in 2020/21 and need additional focus in the years ahead. 

Sewer Flooding 

We are pleased to see that NWL delivered a good performance on its internal sewer flooding and repeat sewer 

flooding  measures,  with  a  substantial  reduction  in  the  number  of  customers  who  were  faced  with  this  very 

undesirable situation in their homes. We note the company’s acknowledgement that in parallel with sustaining this 

positive progress (and they note that the drier weather has had a more positive impact on their performance), it 

needs  to  put  an  increased  focus  on  preventing  external  sewer  flooding  incidents  too,  for  which  the  target  was 

missed. 

As noted in our report last year, customer behaviour plays a key role in achieving improvements in sewer flooding 

measures.  We  are  therefore delighted  that  through  Defra’s  Plan  for  Water  the  industry  has  adopted a  national 

campaign  based  on  NWL’s  data-led  ‘Bin  the  Wipe’  initiative  and  look  forward  to  seeing  industry  data  on  its 

effectiveness.   

Water resources 

In last year’s report, we commented that for its Water Resource Management Plan (WRMP) to succeed, there is a 

real need for NWL to engage holistically and comprehensively with the public on the nature of the water resource 

challenge and the part that both the water company and its customers can play – including on leakage (which had 

a mixed result this year across the two operating areas) and consumption. 

Our challenge holds true this year and arguably is even more relevant given the levels of investment that will be 

needed to ensure sufficient water is available for current and future generations. We note that the Company is 

engaging well on strategic water planning and water resource groups. We suggest that the industry also engages 

14 July 2023 
PAGE 12 OF 211 

 
 
 
 
well with customers to make the link between levels of water consumption, investment required and the size of 

water bills, and how reducing the former will have a corresponding effect on others.  

Drinking Water Quality 

As we noted last year, NWL is undertaking a large transformation programme with the Drinking Water Inspectorate 

to improve its Compliance Risk Index (CRI) score. The benefits of this work are yet to flow through into the results, 

as is clear in this report, underlining its long-term nature. Our members will continue to stay close to this area, 

which is of fundamental importance to customers.  

Trust and reputation 

We see that customers’ perceptions of trust have declined this year, although we are advised that broader data 

provides a richer picture. Trust very much remains a crucial issue for a range of reasons, not in the least if the 

company is to meet its targets for reducing the amount of water each person uses (per capita consumption).  

We believe that good performance against targets is a very important factor in rebuilding levels of trust, so look to 

the NWL team to explore what else it can do to meet and exceed its targets for 2023 and beyond. In particular, 

delivering against its enhancement programme will be key to building confidence in the company’s ability to deliver 

the huge investment programme that the industry has been mandated to deliver in 2025-2029 and beyond. 

In conclusion, last year’s performance in a number of areas is certainly not where customers would expect it to be 

and we call on NWL to ensure it applies the necessary focus and resources to deliver its recovery plans quickly 

and to deliver its targets for 2023-24. Further, with more people than ever before in water poverty executive pay 

and shareholder dividends need to demonstrably reflect performance from customers’ perspectives and be openly 

and honestly explained. This should contribute to building the levels of trust that will be so important in enabling 

NWL  and  the  wider  water  industry  to  rise  to  the  substantial  challenges  that  lay  ahead  for  it,  including  capital 

investment programmes. We call on the industry to be creative in how it does this in a way that minimises the 

burden on customers and the growing number of those in vulnerable circumstances, for whom affordability of water 

is such a pressing issue. 

Melanie Laws, Water Forum Chair  

14 July 2023 
PAGE 13 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
WHO WE ARE 

Northumbrian Water Limited provides: 

•  Water  and  wastewater  services  to  2.7  million  people  in  North  East  England,  trading  as  Northumbrian 

Water, and 

•  Water services to 1.8 million people in Essex and 0.3 million people in Suffolk, trading as Essex & Suffolk 

Water. 

14 July 2023 
PAGE 14 OF 211 

 
 
 
 
 
 
 
OUR PURPOSE 

Our Purpose is caring for the essential needs of our communities and environment, now and for generations to 

come. 

We do this by providing reliable and affordable water and wastewater services for our customers. 

We  make  a  positive  difference  by  operating  efficiently  and  investing  prudently,  to  maintain  a  sustainable  and 

resilient business. 

OUR VISION 

Our Vision is to be the national leader in the provision of sustainable water and wastewater services.  

OUR VALUES 

As important as what we do is how we do it. Our Values define how we work to deliver our Outcomes and achieve 

our Vision. 

CUSTOMER FOCUSED 

We aim to exceed the expectations of our external and internal customers.  

RESULTS-DRIVEN 

We take personal responsibility for achieving excellent business results. 

ETHICAL 

We are open and honest in meeting our commitments, with a responsible approach to the environment and our 

communities. 

INNOVATIVE 

We continuously strive for innovation and better ways to deliver our business. 

ONE TEAM 

We work together consistently, promoting co-operation, to achieve our corporate objectives. 

14 July 2023 
PAGE 15 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
OUR OUTCOMES FOR 2020-25 

UNRIVALLED CUSTOMER EXPERIENCE:  

•  Our customers tell us we provide excellent customer service and resolve issues quickly. 

•  Our customers say they feel informed about the services we provide and the importance of water. 

•  Our customers say we are a company they trust. 

•  Our finances are sound, stable and achieve a fair balance between customers and investors. 

AFFORDABLE AND INCLUSIVE SERVICES:  

•  Our  customers  say  our  services  are  good  value  for  money  and  we  work  hard  to  keep  water  and 

wastewater services affordable for all. 

RELIABLE AND RESILIENT SERVICES:  

•  We are resilient and provide clean drinking water and effective sewerage services; now, and for future 

generations. 

•  We always provide a reliable supply of water. 

•  Our drinking water is clean, clear and tastes good.  

•  Our sewerage service deals with sewage and heavy rainfall effectively. 

LEADING IN INNOVATION:  

•  We are an innovative and efficient company. 

IMPROVING THE ENVIRONMENT:  

•  We help to improve the quality of rivers and coastal waters for the benefit of people, the environment and 

wildlife. 

•  We take care to protect and improve the environment in everything we do, leading by example. 

BUILDING SUCCESSFUL ECONOMIES IN OUR REGIONS:  

•  We are proud to support our communities by giving time and resources to their important causes  

•  We work in partnership with companies and organisations to achieve the goals that are most important to 

our customers 

14 July 2023 
PAGE 16 OF 211 

 
 
 
 
 
 
 
 
 
 
 
OUR STAKEHOLDERS 

We provide an essential service that is relied on by our customers and communities. Understanding their 

experiences, needs and expectations is therefore vital to our business success in the short and long-term. To 

achieve this, it’s critical for us to engage with the representatives and organisations who share and help to 

advance their interests, including in relation to the environment in our regions. 

We engage proactively with a wide range of stakeholders to understand their views, insight and expertise, and 

work with them to provide an unrivalled customer experience and deliver our business Outcomes. 

STAKEHOLDERS / WHY WE ENGAGE 
WITH THEM 

Customers 
Understanding customer priorities and 
preferences, as well as their 
experiences, is vital to delivering world 
class services today and preparing for 
the future. 

Colleagues 
Our colleagues deliver daily the activities 
and services that enable us to achieve 
our ambitious goals. Our success is 
dependent upon their engagement, 
collaboration and innovation. Therefore, 
it’s essential to understand their needs 
and invest in them. 

Ofwat 
As our economic regulator, Ofwat plays 
a key role in setting the conditions for us 
to fulfil our statutory duties and meet 
customers’ expectations. 

Environment Agency 
We are committed to delivering excellent 
environmental outcomes and work 
closely with the Environment Agency to 
ensure we consistently achieve high 
standards. 

HOW WE ENGAGE 

KEY ISSUES COVERED 

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Focus groups / deliberative workshop 
groups, including via digital platforms  
Co-creation workshops  
Email surveys  
SMS surveys  
Social media  
Community Portal  
People’s Panels 
Customer Zone at Innovation 
Festival  
Telephone and door-to-door 
interviews 
 ‘Heidi Live’ question and answer 
session via broadcast with CEO 
TeamTalk business update events 
with Leadership Group and cascaded 
to all colleagues 
Company-wide Roadshows 
Internal communication channels – 
The Source intranet, weekly 
interactive newsletter, email 
newsflashes, digital screens, 
Yammer  
Leadership Conferences  
Company-wide employee surveys  
Internal networks and forums  
Responding to consultations  
Peer to peer contact and meetings  
Site visits 
Annual Performance Report (APR)  

Responding to consultations  
Annual and monthly performance 
reviews  

  Management reviews  
 

National strategy and practitioner 
networks  
Industry task and finish groups  
Joint working group on pollution 
incidents and monthly pollution 
review group meetings  
Site visits 
Regional and local partnerships and 
groups, including Regional Flood and 
Coastal Committee, Northumbria 
Integrated Drainage Partnership 
(NIDP) and Catchment Partnerships  
Provision of training to local EA 
officers on request 

 
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PR24 business planning 
Long-term strategies 
Drainage and Wastewater 
Management Plan  

  Water Resource Management Plans 
  Water environment improvements  
 
 
  Metering 
 

Social tariffs 
Non-household priorities 

Billing 

 

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Company performance and 
scorecard updates 
Reinforcing our Company purpose, 
vision and values  
Health, safety and wellbeing 
campaigns  
Diversity and inclusion strategy and 
campaigns 
Innovation projects and ideas  
Survey feedback and resulting focus 
areas  

 
PR24 business planning process 
 
DWMP and WRMP 
  Ongoing performance and 

 
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 
 

compliance discussions 
Affordability support 
Engagement with Ofwat’s innovation 
competition  
Response to incidents 
Compliance and performance, 
including pollution and bio-resources  
Event duration monitoring  
PR24 business planning 

 
 
  WINEP development and delivery  
 

Drainage and Wastewater 
Management Plan  

  Water Resources Management Plans  
 

Infrastructure investment and nature-
based solutions 
Net zero target and regional climate 
initiatives 
Nutrient neutrality 
Strom Overflows Discharge 
Reduction Plan 
Data transparency 

 

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14 July 2023 
PAGE 17 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
Drinking Water Inspectorate 
Our commitment to providing clean, 
clear, great tasting water requires us to 
understand and meet the DWI’s 
expectations for best practice. 

Water Forum  
Our Water Forum plays a critical role in 
challenging us on how we improve 
outcomes and delivery for customers, 
including through our approach to 
customer research and engagement. 

CCW 
CCW helps us understand how we can 
continue to develop world class 
customer service and deliver against 
increasing customer expectations. 

Supply chain partners 
Our supply chain is vital in enabling us 
to deliver our services. It is also a 
significant part of the economic impact 
we deliver in our regions, through our 
goal of spending 60p in every £1 with 
suppliers in our operating areas. 

Government and policy makers 
Politicians, civil servants, and policy 
makers have a significant influence on 
the conditions within which we operate. 
They also have an interest in 
understanding how we serve our 
customers and communities. 

Local authorities 
Local authorities are important partners 
in delivering services within their areas. 
They also have a deep understanding of 
the communities we operate in.  

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Responding to consultations  

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  Quarterly operational and 

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transformational liaison meetings  
Senior leadership strategy meetings  
Chief Inspector’s report launch 
meetings  
Consultation and negotiation via 
Water UK groups at board, strategic 
and policy levels  
 
DWI laboratory liaison groups 
  Water safety planning forums 
 
Reviews of regulatory commitments  
 
Industry task and finish groups  
  On site collaborative investigations 

 

and audits  
Formal meetings, sub-groups and 
task groups 
Deep dive reviews 

 
  Meetings with senior managers, 
Executive Leadership Team, and 
Board members  
Consultation processes  

 

 
Responding to consultations  
 
Sharing material for review  
  Quarterly liaison meetings  
 

Attendance at regional public 
meetings  
Bespoke engagement sessions  
Industry working groups and best 
practice forums  
Customer Service Network PAGs  

Joint Framework Governance 
Groups  
Safety, Health and Environment 
Forum  
Integrated programme delivery 
teams  
Joint conferences and workshops  
Joint recruitment and development of 
employees  
Leading and participating in industry 
bodies  
Partner participation in our Innovation 
Festivals  
Briefings  
Site visits  
Face to face meetings  
Attendance at key forums  
Speeches and events  
Responding to consultations  

Regular meetings with senior officials 
and lead councillors  
Technical input and support on 
planning matters  
Participation in consultations and 
steering groups relating to 
environment or economic 
development issues  

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Company compliance assessments  
Dissemination of company incidents 
and agreed learning points  
Technical audit feedback  
Progress with agreed programmes of 
work  
Internal water quality communication 
strategy  
Collaboration opportunities  
National legislation changes  
Research outputs  

PR24 development 
Company performance  
Customer engagement activity and 
performance  
Financial support for customers 
DWMP and WRMP 
Drinking water quality improvements  

Complaints management and best 
practice  

  Water Matters tracking research  
 
Tariffs, including social tariffs and 
tariff innovation 
Customer engagement  
Social purpose 
PR24 business planning 
Future service provision   
Affordability and inclusivity 
Sewer flooding 
Visible leaks 
Demand management 
Dealing with adverse weather events 

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Innovation and best practice 
solutions  
Sustainable operations including 
environmental challenges  
Stakeholder engagement and 
customer service improvement  
Capex programme delivery  
Regional economic development 
Community investment initiatives 
Responsible procurement 
approaches  

Environmental performance and net 
zero commitment  

  Water demand 
 

Storm Overflows and river water 
quality   
Incident response and resilience 
Eradicating water poverty  
Innovation activity  

Asset investment schemes  
Local campaigns and customer 
engagement initiatives 
Environmental performance  
Local economic benefit 
Regional plans, including economic 
development and environmental 
initiatives 
Eradicating water poverty   

 
  WRMP and DWMP 
 

Community investment initiatives 

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14 July 2023 
PAGE 18 OF 211 

 
 
 
 
 
 
 
 
 
 
NGOs and charities 
We’re committed to positive outcomes in 
our communities and environment. 
Working with organisations that share 
this passion and have deep knowledge 
and expertise enables us to deliver more 
effectively. 

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Sponsorship and donations  
Just an Hour volunteering 
programme  
Innovation and development support  

 
  Governance support  
  Meetings and forums  
 

Partnership schemes and 
collaboration  

Media and opinion formers 
Media and other influential voices in our 
regions and industry help us to 
communicate important messages about 
our services and understand the impact 
they have on our audiences. 

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News releases  
Briefings  
Events  

Investors 
Our investors ensure we have access to 
the funding we need to deliver services 
and invest for the future. They also 
provide important feedback and insight 
to inform our business practices. 

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Periodic reporting   
Investor update on new issuance  
Credit investors portal  
Credit agency meetings and 
publications  
Engagement with banks  

 
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PR24 business planning 
Environmental activities and 
investments  

  Water for health campaigns  
 
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Eradicating water poverty  
Education initiatives  
Regional policy support  

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Critical incidents  
Investment schemes 
Key campaigns, including Bin The 
Wipe  
 
Environmental initiatives  
  Water saving / usage advice   
  Water safety advice   
 
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Customer service support   
Community initiatives 
Financial results   
Regulatory and operational 
performance  
Funding, hedging and liquidity  
Regulatory environment  
Capital programme update  
Euro Medium Term Note Programme 

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14 July 2023 
PAGE 19 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ASSURANCE SUMMARY 

Within this Annual Performance Report, we publish a range of information about our services and performance, 

including how we’re performing against the commitments we made in our 2020-25 Business Plan. This helps to 

provide our customers and stakeholders with assurance that we’re delivering what they’ve told us they need and 

want from us. 

It’s important that we have robust assurance arrangements to make sure this information is accurate, clear, and 

transparent.  

We focus a significant proportion of assurance activity on making sure that the information we publish in our 

Annual Performance Report is of appropriate quality. We’ve published a Data Assurance Statement alongside 

this Annual Performance Report. This details how we decide what level of assurance should be applied to our 

data (i.e. who should provide the assurance), and whether this has been completed during the year. It also 

details key findings and, in conclusion, confirms that there were no significant issues to report. 

14 July 2023 
PAGE 20 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTRODUCTION 

This report summarises our performance against our Outcomes during the regulatory year ending 31 March 

2023. This is the third year of us delivering our 2020-25 Business Plan.  

Our drive to be the best is supported by six strategic themes: Unrivalled customer experience; affordable and 

inclusive services; leading in innovation; reliable and resilient services; improving the environment and building 

successful economies in our regions. Our Outcomes are aligned to these themes and set out what we aim to 

achieve. They represent what our customers have told us they value in the long-term. They are our 

commitments, or promises, to our customers.  

Our 14 Outcomes were developed with our customers and stakeholders. Everything we do is driven by an 

Outcome for our customers.  

To track performance against our Outcomes we have clear metrics with associated targets – our Performance 

Commitments (PCs). For delivering better performance in certain measures, we could earn a financial reward. 

Conversely, poor performance in certain measures could incur a financial penalty. These rewards and penalties 

are called Outcome Delivery Incentives (ODIs). Some of our performance measures are simply reputational, 

which means that they do not incur financial penalties or rewards.  

This performance report sets out the work that we are doing to deliver our 2020-25 PCs along with our progress 

towards the longer-term goals which we’ve set.  

The report provides extended commentary for tables 3A to 3I, which is a summary of our performance against 

our PCs that we must provide for our regulator (Ofwat) every year.  

We measure our performance and calculate any penalties or rewards using the methodology in our PR19 Final 

Determination, along with any subsequent amends set out in the CMA’s recent redetermination.  

This reporting process is subject to robust assurance, as set out in the Data Assurance Statement. Further 

information about our performance is available on our website www.nwg.co.uk.  For information about how we 
are performing in comparison to other water and sewerage companies, visit www.discoverwater.co.uk.  

14 July 2023 
PAGE 21 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
OUR ANNUAL PERFORMANCE AT A GLANCE 

We show figures in green where we’ve met our performance against our promise this year, and red where we have 

not met our performance. Similarly, any applicable rewards are shown in green and penalties in red. 

For further details about reasons for performance and our plans for improving, please see the detailed section for 

each PC later in this document. 

MEASURE OF SUCCESS   COMMON / 
BESPOKE  

OUR 
PROMISE 
FOR 2022/23  

OUR PERFORMANCE  

2020/21 
ACHIEVED  

2021/22  
ACHIEVED  

2022/23  
ACHIEVED  

REWARD  
/ PENALTY (£)  

Ofwat’s Customer Measure 
of Experience (C-MeX)  

C  

Response time to written 
complaints  

Ofwat’s Developer Services 
Measure of Experience (D-
MeX)  

B  

C  

Customers’ perception of 
trust (independent survey)  

B  

NWL independent value for 
money survey  

B  

Percentage of households in 
water poverty  

B  

Awareness of additional 
financial support  

Satisfaction of customers 
who receive additional 
financial support  

Awareness of additional 
non-financial support  

Satisfaction of customers 
who receive additional non-
financial support  

Priority services for 
customers in vulnerable 
circumstances – Reach/ 
Actual contact/ Attempted 
contact  

B  

B  

B  

B  

C  

British Standards Institute 
Award for Inclusive Services  

B  

Voids  

B  

Gap sites  

B  
a drought (% of customers)   C  

Risk of severe restrictions in 

Per Capita Consumption 
(PCC) (litres/person/day 3 
year average)  

C  

Unplanned outages at Water 
Treatment Works  

C  

 -   

85.76 (3rd)  

84.46 (2nd)  

83.74 (1st)  

Circa £3.4m  

2 days   

7.1 days  

9.97 days  

7.93 days    Reputational only  

-   

8.8  

8.3  

86.94 (7th)  

88.56 (5th)   

89.85(6th)  

Circa £0.580m  

8.8  

8.3  

8.7  

8.2  

8.5  

8.2  

Reputational only  

Reputational only  

9.42%  

10.38%  

9.61%  

15.27%  

Reputational only  

65%  

41%  

38%  

41.5%  

Reputational only  

8.7  

9.3  

9.2  

9.2  

Reputational only  

52%  

50%  

45.0%  

45.3%  

Reputational only  

8.7  

8.7  

8.7  

8.8% /   
35% /   
90%  

2.3% / 57.3% 
/   
40%  

3.5% / 40.2% 
/ 93.4%  

8.5  

8.8% /   
44% /   
90.3%  

Reputational only  

Reputational only  

Maintain  

Maintained   Maintained   Maintained   Reputational only  

4.30%  

89.7%  

0%  

2.9%  

3.74%  

67.5%  

0%  

3.53%  

64.3%  

0%  

3.39%  
59.1%  

0%  

£1.33m   

Reputational only  

Reputational only  

3.8% increase 
to 156.3 litres  

4.7% increase 
to 157.7 litres  

5.6% increase 
to 159.1 litres  

Ofwat to review in 
2024/25  

4.36%  

5.69%  

4.57%  

3.51%  

Penalty only 
measure/no reward 
available  

14 July 2023 
PAGE 22 OF 211 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Interruptions to supply 
between one and three 
hours (mm:ss)  

Water supply interruptions 
greater than three hours 
(mm:ss)  

Interruptions to supply 
greater than 12 hours 
(properties)  

Leakage (ESW)* (MLD 3-
year average)  

Leakage (NW)* (MLD  3-
year average)  

Visible Leak repair time 
(average days)  

Mains repairs   
(per 1,000km main)  

Abstraction Incentive 
Mechanism (AIM)  

Water quality   
compliance (CRI)**  

Event Risk Index (ERI)**  

B  

C  

B  

C  

C  

B  

C  

B  

C  

B  

Discoloured water contacts 
(per 10,000 population)**  

B  

Taste and smell contacts 
(per 10,000 population)**  

Internal sewer flooding   
(per 10,000 connections)  

Repeat sewer flooding  

External sewer flooding  

Risk of sewer flooding in a 
storm  

Sewer blockages  

Sewer collapses   
(per 1,000km of sewers)  

Treatment works   
discharge compliance**  

B  

C  

B  

B  

C  

B  

C  

C  

Bathing water compliance 
(no. Of sites achieving good 
or excellent)**  

B  

95.0%  

n/a  

87.9%  

124.2%  

-£2.7m  

5 mins 45 
secs   

4 mins 4 sec   5 mins 51 

sec  

8 minutes 17 
seconds   

-£2.611m  

450  

143  

917  

448  

£0.007m  

7.2% reduction 
to 60.5M:D  

0.5% 
reduction to 
64.9MLD  

3.2% 
reduction to 
63.1 MLD   

6% reduction 
to 126.7MLD   

1% increase 
to 136.2 MLD  

0.1% 
reduction to 
134.7 MLD  

7.5% 
reduction to 
60.3 MLD  

3.7% 
reduction to 
129.8 MLD  

£0.031m [we are not 
claiming this]   

£-0.543m  

6.0  

9.7  

6.7  

7.1  

-£0.471m  

132.4  

127.0  

110.9  

154.9  

-£1.863m  

n/a  

0  

n/a  

n/a  

n/a  

n/a  

7.11  

6.36  

7.62  

-£8.531m  

152.940  

197.592  

289.699  

166.907  

-£0.28m  

8.98  

2.05  

1.58  

42  

8.22  

1.75  

1.89  

25  

8.42  

1.89  

1.84  

23  

7.85  

1.75  

1.21  

20  

£0.992m  

£0.263m  

£0.934m  

£1.211m  

3,009  

3,862  

3,454  

3,018  

-£0.56m  

27.30%  

16.11%  

16.11%  

16.11%  

Reputational only  

11,164  

12,023  

11,991  

10,949  

£0.168m   

9.43  

9.82  

8.71  

9.29   

Penalty only 
measure/no reward 
available  

100%  

99.51%  

98.03%  

98.52%  

-£0.287m  

97.06%  

n/a  

97.06% (33 of 
34 sites 
including 1 
exemption)  

97.06% (33 of 
34 sites 
including 1 
exemption)  

-  

Pollution incidents (per 
10,000km of sewers) **  

C  

23.00  

14.61  

22.98 per 
10,000km 
(69)  

19.98 per 
10,000km   
(60)  

£0.9m  

14 July 2023 
PAGE 23 OF 211 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Water Industry National 
Environment Programme 
(WINEP)  

Delivery of WINEP 
requirements  

Water environment 
improvements  

Greenhouse gas emissions 
(tCO2e reduction from 
2019/20 baseline)  

Bioresources  

B  

B  

B  

B  

B  

460  

0  

347  

447*  

Reputational only until 
end period  

Met  

Met  

Met  

Met   

Reputational only  

10km   

30.2 km  

34.6km  

33.1km  

£0.177m  

6,771  

15,235  

46,492  

23,445  

£7.183m  

100%  

100%  

100%  

100%  

Reputational only  

* The change of number of deliverables has been signed off with the Environment Agency so we consider this as on 
track   

We’re pleased to have achieved or beaten 25 out of our 43 PCs in 2022/23.  

Although our overall performance was strong and we are number one in the industry on customer service, we were 

disappointed to fall short on water quality and interruptions to supply. We have clear action plans underway to raise 

these areas of overall operational performance to the same level as our customer service performance. 

The table above shows we earned rewards for eleven of these achievements, excluding the final confirmation of 

C-MEX and D-MEX rewards. However, we are not claiming the reward for leakage in ESW. Of the remaining 11 

commitments we achieved, nine were reputational only and two were penalty only.  

We accrued penalties for not meeting nine of our PCs this year and did not achieve eight of our reputational only 

PCs While there have been some setbacks this year regarding progress towards our longer-term ambitious goals, 

we acknowledge areas where we fell short of our intended goals and have clear performance improvement plans 

in place.  

Headlines include: 

•  We  are  absolutely  delighted  to  have  achieved  our  ambition  of  being  the  top  company  for  C-MeX  in 

2022/23,  the  industry-wide  measure  that  provides  a  holistic  comparison  of  companies’  customer 

satisfaction  and  experience  performance.  The  reflects  our  long-standing  commitment  to  delivering 

unrivalled customer experience.   

•  Our action plan to improve performance for customers in vulnerable circumstances has been a success 

thanks to an innovative approach to partner working and data sharing. In 2022 we increased the number 

of customers on our PSR (Priority Services) register by over 73k households, putting us on track to deliver 

against the most ambitious and toughest target for this measure in the industry. 

•  Our internal sewer flooding performance has improved by over 30% compared with the performance we 

reported last year, with our success resulting from the continuing maturity of our sewer flooding tactical 

plan we started in 2019. We are delighted to have achieved our target. 

•  We have achieved our leakage target in ESW, but acknowledge we have more to do in NW.  

• 

In keeping with our commitment to our communities we have maintained our ambitious local spending 

goal of spending 60p in every £1 locally.  

• 

The cost-of-living crisis has pushed more people into water poverty and as a result, we haven’t hit our 

ambitious target in this area. We are disappointed with this result as although we are helping more people 

14 July 2023 
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and have further enhanced our focus on increasing awareness of the support available, we are still short 

of  our  aim  here.  We  will  continue  to  innovate  in  this  area  to  make  sure  we  positively  face  into  new 

challenges that the wider socio-economic landscape poses and will also continue to work with partners 

and stakeholders to share key messages across all available channels to make sure maximum exposure 

and reach. 

•  We’re disappointed to not hit our high standards in water quality (despite scoring highly in our customer 

facing  measures  around  taste  and  odour  and  discoloration).  We  are  committed  to  achieving  industry-

leading levels of CRI and are delivering our long-term plans to reach this, as well as working closely with 

the DWI and will continue to prioritise our efforts around water treatment where CRI risk is highest.   

•  Our overall performance on interruptions to supply has been impacted by extreme temperatures coupled 

with  freeze  thaws,  doubling  the  number  of  repair  jobs  doubled  from  what  we  forecasted.  Careful 

management of our network made sure we were able to meet demand across our operating areas but 

good performance in the longer term will be dependent on investment to make our assets more resilient 

to these events. 

•  We remain committed to our ambition to have the best rivers and beaches in the country and have updated 

our Vision for Coasts and Rivers. We continue to beat our PC for Pollution Incidents and achieve our PC 

for Bathing Water Quality. We are disappointed to miss our target again for Treatment Works Discharge 

Compliance.  To  get  back  on  track  in  2023/24,  a  tactical  plan  to  improve  performance  is  currently  in 

development and will aim to see us reach over 99% compliance. 

•  We’re  also  pleased  to  have  again  beaten  our  target  (by  a  factor  of  almost  four)  for  delivering  Water 

Environment Improvements. 

•  Our performance overall has created a net penalty of -£3.918m excluding C-MeX and D-MeX performance 

rewards.  Taking  C-MeX  (+£3.361m)  and  D-MeX  (+£0.580)  into  account,  the  estimated  final  reward  is 

+£0.023. 

In  addition  to  the  commitments  outlined  in  the  table  above,  we  have  PCs  to  make  sure  we  deliver  additional 

investments for customers by 2025 including: Smart metering, Lead Pipe Replacement, Delivery of our water and 

wastewater resilience programmes, Howdon Sewage Treatment Works Expansion, Cyber Resilience and Drainage 

& Wastewater Management Plans (DWMPs). 

We encountered some setbacks during the Covid-19 pandemic, with some of the investment schemes starting later 

than originally planned. In addition, global supply chain issues, manufacturing problems and component shortages 

have  also  delayed  our  smart  metering  programme  and  limited  access  to  customer’s  homes  during  Covid  also 

hampered the lead project. Despite these challenges we remain fully committed to delivering these schemes for 

our customers on time and are working hard to achieve this.  

We estimate that completion of our smart metering programme may fall slightly short of target by March 2025 but 

as a minimum we’ll make sure the programme is delivered in full in Suffolk, a water stressed area. We are on track 

with  delivery  against  our  wastewater  resilience  programme,  our  resilience  investment  at  Howdon  and  Cyber 

Resilience and published our DWMP on 31 May 2023.  

14 July 2023 
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OUR 2022/23 PERFORMANCE IN DETAIL 

Some of the measures are ‘common’ across the water industry and some are ‘bespoke’ to us. This is flagged next 

to each measure. 

THEME ONE: UNRIVALLED CUSTOMER EXPERIENCE 

OUTCOME 1: our customers tell us we provide excellent customer service and resolve 
issues quickly 

AMBITIOUS GOAL: Deliver world class customer service 

•  Ofwat’s Customer Measure of Experience (C-MeX) – common 

•  Response time to written complaints – bespoke  

•  Ofwat’s Developer Services Measure of Experience (D-MeX) – common 

Customer Measure of Experience (C-MeX) position - PR19NES_COM01 

We are absolutely delighted to have achieved first place – beating our ambition of being in the top two companies 

for  C-MeX,  the  industry-wide  measure  that  provides  a  holistic  comparison  of  companies’  customer  satisfaction 

(CSS) and customer experience (CES) performance. 

This is an industry comparative measure, defined by Ofwat. As such, the ranking position is more relevant to report 

on as opposed to the absolute score. 

The table below shows our industry ranking for CSS, CES and overall C-MeX across the year. 

Table 1 

CSS 

3rd   
Q1 
3rd  
Q2 
2nd  
Q3 
2nd  
Q4 
OVERALL  3rd  

CES 

7th  
2nd  
4th  
2nd  
3rd  

OVERALL C-MEX 

7th  
1st  
3rd  
1st  
1st  

We  are  passionate  about  engaging  with  our  customers  to  understand  how  they  want  us  to  deliver  world  class 

customer service. Our focus remains on getting things right first time, fast time, every time. We know our customers 
really value this and we always work hard to achieve it. 

After  a  difficult start  to  2022/23,  our  3,038 employees  pulled  together  across  the  business  to  turn  performance 

around and deliver a fantastic overall result for the year through relentless hard work and a real obsession with 

customer service – this is reflected in our 2022 Great Place to Work scores. Over 2,500 of our people took part 

and 70% said that NWG is a great place to work. 

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We know that to be unrivalled and to be recognised by our customers as top performers, we need to look at the 

interactions and  engagements  we  have  every day, as  well  as  the  cumulative  impact of  these  and  the  way  our 

customers see us overall, or through time. 

To improve CSS scores, our focus has been on improving customers’ experiences when they do get in touch. We 

have focused on communication at all stages of our customers’ journeys as we know keeping them informed and 

being open and transparent is critical to satisfaction and positive experiences. We’ve improved how and when we 

communicate, as well as the channels we choose to share messages. 

Being proactive, choosing the  right  time  to  get  in  touch and  the  right  messages  to  share means  we  can  share 

positive updates and information in a timely way that helps customers understand and feel in control. We’ve had 

positive feedback about our enhanced approach here. 

In the small number of cases where complaints are received, we take a ‘phone first’ approach and talk with our 

customers before following up in writing if we need to. This makes sure we fully understand their concerns and that 

they are satisfied with our proposed resolution. We have put in place robust cross-functional processes to make 

sure complaints are  resolved to  customers’ satisfaction  as swiftly  and consistently  as  possible.  This includes a 

series of regular review meetings with our customer, water, wastewater, and billing teams.  

In relation to CES, we continue to promote the great work we do through our Just Add Water integrated marketing 

campaign and have ramped up visibility of this in our local communities, promoting the ways in which we can offer 

help with bills to our customers who are struggling to pay. We’ve offered at least five contact channels throughout 

the year, and at least three of them were digital. 

We’ve also looked at overall journeys and experiences, where our brand is positioned and how we can be the best 

version of ourselves in local communities, for example where our brand is very visible. This is from briefing our 

teams on considerate parking, driving and on-street working, to how we help our customers, engage with them and 

consistently act as positive role models in the areas where we work and live. 

Examples of our channels include voice, automated interactive voice response (IVR), email, webform, website, 

app, social media, and messaging. 

We can earn a reward for high performance if we meet each of the following three criteria: 

• 

• 

We are one of the top three performers by C-MeX. 

We  are  at,  or  above,  a  cross-sector  threshold  of  customer  satisfaction  performance  based  on  the  all-

sector upper quartile (ASUQ) of the UK Customer Satisfaction Index (UKCSI). 

• 

We have lower than the industry average number of household complaints (per 10,000 connections). 

We await Ofwat’s confirmation on the level of our C-MeX reward factoring in the three criteria above but expect 

this to be approximately £3.4m.  

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Response time to written complaints (days) - PR19NES_BES03 

We have not achieved our target but have made an improvement on the previous year’s performance.  

Our  customers  told  us  that  the  speed  with  which  we  respond  to  complaints  was  more  important  to  them  than 

minimising incidents. This is a bespoke PC.  

This measure uses CCW’s definition of a written complaint, which covers complaints via post, email, web, or fax 

that are responded to within the reporting year. We’re committed to responding to a minimum of 90% of written 

complaints  within  one  working  day.  To  reflect  that  commitment,  while  also  maintaining  appropriate  focus  on 

complex complaints which cannot be responded to within one day, we set our PC to two working days for 2020-

25. This has proven to be an extremely stretching target.  

We failed to achieve our target, in part because only substantive and full responses are included in the figure. Most 

complaints we receive are complex and require in-depth investigations and/or further work to resolve the issue. If 

we were to include holding responses the current response time is around 4.77 days.  

Our  response  time to  wastewater complaints is  poorer  than  that  of  water  and  billing complaints  because  these 

issues are  largely more complex  and  take longer  to  fully  investigate  and  resolve.  This applies mainly to  sewer 

flooding investigations. 

While  we  are  disappointed  to  not  achieve  our  target,  we  are  confident  that  we  are  ultimately  working  with  our 

customers to resolve issues to their satisfaction. Customers give good feedback in terms of how we resolve their 

issues, and they are complimentary when they do speak to us. They also tell us that if we keep them informed, 

they are happy for resolution to take that little bit longer to achieve the best outcome.  

Just  3.33%  of  complaints  were  escalated  to  the  second  stage  of  our  complaint  process,  with  more  than  96% 

resolved without the need for an independent review. 

We are working hard to not only reduce the number of complaints that we receive but also to put in place robust 

processes which will allow us to improve response times. 

14 July 2023 
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Examples of feedback from our customers: 

“They were very, very prompt in responding and the engineer that came was considerate and understood. They 

checked with me first. They knocked on the door they came very, very quickly, they explained everything to me, 

they came to check with me again when they were finished. It felt like they cared.” 

“The gentleman I spoke to was very clear in what was needed and before I was asking the questions, he was giving 

additional information, so I didn't need to ask any other questions. He was very proactive. The gentleman was very 

professional, very caring and understood the situation as I described it.” 

“Not only for speed of response, but actually the people that came along were very helpful. They were meticulous 

and  communicated  very  well.  They  just  do  it  (get  on  with  it).  They  explained  it  and  offered  advice.  I  was  very 

impressed. Overall, very helpful people to be dealing with.” 

“They're always very helpful and the website is really easy to use, and they send me a reminder when my payment 

is due every month, which is great for me as I'm a disabled pensioner. “ 

“I was so upset as my dad had recently passed away. The woman on the phone was so kind she said take a minute 

and I will speak to you as I sobbing on the phone [sic] - she was amazing not like Eon who after one hour I couldn't 

get through.  I rang you and got told I was in a queue of one to two mins and that was correct - I cannot express 

my appreciation how I was treated by your staff - she was so helpful and kind and really seemed to care about my 

feelings.”  

Developer Experience (D-MeX) position - PR19NES_COM02 

This is a financial common PC for developer customers looking at a range of Water UK metrics, as well as feedback 

from customers. 

We finished in 6th place and have improved our score from the previous year with an overall score of 89.85, which 

is above average. We scored a qualitative score of 81.32 and a quantitative score of 98.38. We expect to receive 

a reward of approximately £0.58M from a potential reward of £1.3M once Ofwat has finalised figures. 

To make sure we check our performance against the selected Water UK metrics is an accurate reflection of our 

underlying performance in the reporting year, first stage validation is carried out by data providers and then assured 

by our Customer Experience Manager (D-MeX). Validation also includes referring selected performance data to 

our Developer Services Regulation & Compliance Manager. In addition, there is periodic audit of performance from 

our Internal Audit team. 

Our customer satisfaction performance remains strong where we have remained in the top quartile throughout the 

year.  However, our ability to deliver new service connections consistently on time has been hampered by a number 

of  weather events  as  resource  has  been  diverted  elsewhere,  resulting  in  performance  against some  Water  UK 

metrics decreasing. 

14 July 2023 
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Our customer satisfaction performance remains strong as we finished fourth. However, our ability to deliver new 

service connections consistently on time  has been hampered by a number of weather events as resource  was 

diverted elsewhere, resulting in performance against some Water UK metrics  decreasing. This activity has now 

transferred to a different team where resource is ringfenced and for the last two months we have achieved 100% 

performance. 

Some customers will have been left disappointed when we have needed to cancel their new service connection 

however this is a relatively small portion of our customer base.  Our customer satisfaction scores remain high at 

81.32%. We are confident the changes mentioned above will have a further positive impact on customer satisfaction 

next year. 

Overall, our performance for 2022/23 has improved compared to the previous year, however our industry position 

has dropped one place as others have improved. There was a marginal difference of 0.05 between us and fifth 

place,  and  just  0.14  difference  between  us  and  fourth  place.  We  are  focusing  our  efforts  on  making  sure  we 

continue  to  improve  the  customer  experience  through  enhancing  our  online  offering,  introducing  site  visits  and 

Account Managers while revieing processes to reduce timescales.  

Case study: Leading in customer service 

We strive to be at the heart of our communities, and that means understanding our customers and what they need 

us to deliver. Our work on customer experience and satisfaction has meant we have been recognised, not just in 

our  industry  through  the  C-MeX  measure,  but  also  alongside  the  UK’s  biggest  brands  in  the  KPMG  Customer 

Experience Excellence report for 2022. 

The report, by the KPMG Nunwood Excellence Centre, puts us in the top 100 companies in the country for customer 

experience. 

We were delighted that we not only ranked highly but were one of just two utility providers on the list and included 

as an exemplar case study in the report. 

The analysis is carried out based on six key pillars of customer service - Integrity, Personalisation, Empathy, Time 

and Effort, Expectations and Resolution. 

These six pillars support our customer function and are widely understood across the business - even our internal 

processes use them as a guide, ensuring that crucial values like integrity and empathy are at the heart of everything 

we do. 

OUTCOME 2: Our customers say they feel informed about the services we provide and the 
importance of water 

AMBITIOUS GOAL: Give every single customer the opportunity to have a strong voice 

and engage with us, with at least 2m customers participating by 2025 

Whenever we have big decisions to make about changes to the services we provide and how we provide with 

them, we seek our customers’ views to make sure we provide services in the way that they want us to. 

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We also ask them about the channels we use and how they want to engage with us – both operationally and on a 

wider level more generally. As we’ve been developing our updated Unrivalled Customer Experience strategy we’ve 

enshrined this philosophy in our Six Customer Priorities – which have been directly informed by customer research 

and feedback and reflect the things our customers tell us matter most to them. Our Six Customer Priorities, along 

with our Six Pillars of Customer Experience Excellence form the backbone of our Unrivalled Customer Experience 

Strategy, and inform priorities, behaviours and thinking right across our business. 

Getting the right balance between investing in our services, environmental improvements and the affordability of 

customer bills is not easy, and it’s important to us that the views of our customers inform those decisions.  

Since 2020 we have been engaging with customers on our developing PR24 Business Plan and we reflect what 

our customers have asked for, and told us is important to them, in our plans for 2025-30.  

Drinking water quality is consistently rated  amongst our customers’ highest priorities. Through Water Resource 

Management Plans and Drainage and Wastewater Management Plan, we’ve spoken to them about water scarcity 

and drought in Essex and Suffolk, and the need for long-term improvements to river and bathing water quality in 

the North East. 

Customers also tell us that they expect us to work with others in our regions to solve difficult problems – our strong 

track record in this area demonstrates this is something we do well. In creating our Business Plan, we have done 

this more than ever before, working closely with organisations, like the Rivers Trust, to understand the best ways 

to tackle environmental challenges.  

We see growing support for these environmental improvements, but customers don’t always want to pay for these 

through  their  bills  -  especially  when  times  are  already  tough.  Some  customers  support  the  idea  of  phasing 

investments over a longer time so that they’re more affordable.  

With some of the poorest communities in the country on our doorstep, it’s not surprising that our customers tell us 

is that it’s important to keep our services as affordable as possible and build in plans to make sure financial support 

is available for those customers who need it. We take that responsibility very seriously. 

Correctly understanding customers’ needs and diverse circumstances is critical to providing an unrivalled customer 

service and our 4.5 million customers sometimes need a bit of extra help in other ways too.   

We are pleased that our customers value our services and have rated us as the top water company at providing 

customer service in Ofwat’s independent CMEX survey and as the most trusted water company in CCW’s Water 

Matters report. We listen to our customers daily through operational contact that we have with them, including how 

we  use  Rant  &  Rave  to  understand  how  we  can  continually  improve  the  services  that  we  provide  based  on 

customers’ feedback.  

We’ll continue to work hard to make sure that we are delivering customer expectations and are investing in a new 

system with many enhanced features to enable this in even more ways in the future. 

Case Study: Save water, save energy 

Waters worth saving - the summer campaign including no customers off supply during months of drought. 

The cost-of-living crisis has changed how we approach communicating with our customers about issues around 

affordability.  We’ve  reached  out  more  broadly  to  make  sure  more  a  wider  audience  knows  about  the  financial 

support that’s available and have the information they need. 

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Our messages fell into three categories - general affordability messaging covering everything we can do to help; 

individual messaging about specific tariffs and support options; and messaging about saving water and energy. 

That mix of messaging was important, linking a broader audience to information about financial support alongside 

the opportunity to share help and advice on saving water and saving energy, to save money on bills. 

With simple tips focusing on the use of household appliances like kettles,  dishwashers and washing machines, 

alongside messages on water usage through baths and showers, we were able to explain how simple changes 

can help save money on bills. 

Some of the numbers involved are stark - 27% of the water used in the home is in the shower; 5,500 litres of water 

can be wasted in a year by a single dripping tap; 200 litres of water is wasted every day by a leaky loo. 

We’ve seen clear results, with a 192% increase in web traffic to our financial support pages, and 5,000 views of 

our new Save Water, Save Energy page. 

An  additional  19,000  people  are  receiving  financial  support  from  us,  taking  the  total  to  107,000,  and  general 

awareness of those financial support programmes increased from 37% to 46% in our latest customer survey. 

OUTCOME 3: our customers say we are a company they trust 

•  Customers’ perception of trust (independent survey) – bespoke 

Customers’ perception of trust (independent survey) - PR19NES_BES05 

We have not achieved our target.  

This measure is the mean customer satisfaction score out of ten from our independent customer tracking survey. 

The survey engages 500 household customers each quarter. There are no financial incentives associated with this 

bespoke measure which is reputational only. 

Our trust score has dropped to 8.5, which is below our PC.  

It is critical to us that our customers trust us and are confident in the services we provide. We strive to  always 

communicate  openly  and  transparently  with  customers.  We  want  our  customers  to  know  us  as  a  valued  and 

14 July 2023 
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respected partner in the communities we serve and demonstrate this by informing them of the services we provide, 

increasing brand awareness, sharing our good news stories with the media and on social media. 

Examples of how we communicate with our customers include: 

Bin the Wipe - our campaign that helps customers understand why flushing wipes can cause pollution and flooding 

has been adopted nationally by the whole water industry (through Water UK) and was launched in Parliament in 

October 2022. 

Water  usage  communications  -  we  know  our customers responded  well  to  last  year’s communications  about 

using water wisely, weather-related challenges (including the drought), and water demand situation. This, along 

with  the  dedication  of  teams  throughout  the  business,  helped  us  to  avoid  a  temporary  usage  ban  in  our  ESW 

operating area. 

We carried out a brand impact study in September last year following the campaign and found that: 

• 

• 

• 

• 

61% of respondents have changed behaviour to reduce water use (benchmark 49.8%). 

More than half were happy that we were offering tips for water efficiency. 

Appeal for restraint emails had an excellent open rate of over 70%.  

Research  carried  out  in  September  2022  told  us  that  nine  out  of  ten  respondents  consciously  adopt 

behaviours at home to save water. 

• 

There was a significant increase of water stress awareness (10% to 32%). 

In CCW’s Water Matters report 2022/23, our trust score in our ESW operating area (7.27) remains lower than our 

NW score but is still above the average (7.21) across all water companies in England. The percentage of customers 

who agree the company cares about service given to customers stands at 65%, above the WoC average of 59%. 

In our NW region, our trust score increased to 7.81, joint top and significantly higher than average for all water and 

sewerage companies. As with our ESW area the percentage of customers who agree the company cares about 

service given to customers is at an all-time low (68%), just above the WaSC average of 66%. 

While we are disappointed to have dipped slightly compared to our usually high performance, we continue to focus 

on how we engage with our customers to develop our relationship with them. We recently brought our Commercial 

colleagues (including appointed leisure and fisheries business and meter field services) into the Customer team; 

this helps us to begin to better influence experiences to reflect brand. We can also make sure all our customers, 

no matter which service they are using, be it water supply or visiting one of our leisure sites, will consistently receive 

the unrivalled customer service they expect and which has seen us top of C-MeX for 2022/23. 

Case study: Working with trusted partners to support customers  

We  take  our  place  in  the  community  seriously.  That  means  behaving  ethically,  sustainably  and  with  social 

responsibility.  

We focus our financial contributions and our volunteering on key areas including ending water poverty, water for 

health and protecting the water environment. 

14 July 2023 
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During 2022/23, this saw us support a range of initiatives across our operating areas, including Christmas appeals 

- Mission Christmas in Tyneside, Kids Inspire in Essex and Winter Wonderland in Suffolk - and our Powered by 

Water schools programme, which delivers messages on the importance of hydration to children. 

We have also continued our Water Ranger citizen science programme, working with community groups including 

Marske Litter Action, Seascapes beach volunteers, Tees Valley Wildlife Trust, Saltburn Countryside Volunteers 

and the Friends of the Lower Path. 

Overall, we reinvest at least 1% of our profits every year into community activities - a longstanding commitment we 

are proud to have met again in 2022/23. 

OUTCOME 4: Our finances are sound, stable and achieve a fair balance between 
customers and investors. 

There are no PCs under this Outcome. However, we stated in our Business Plan that we will deliver the following 
for  

customers under this Outcome: 

• We are financially resilient 

• We have a financially stable Business Plan 

• We plan our finances for the long-term 

• We raise debt finance efficiently 

• We share any efficiencies we make with customers 

• We pay our taxes 

• We procure responsibly 

We have longer term plans to allow us to operate our business sustainably and we manage our finances in the 

same way to make sure they remain sound and stable. It is important that we maintain a fair balance between our 

customers and investors to keep our customers’ bills as low as possible while continuing to attract capital to finance 

the investment necessary to maintain and enhance our assets. Striking this balance shows our customers they can 

have trust and confidence in us. 

Financial structure and resilience 

Like most companies, we are financed through a combination of money from shareholders, profits, and borrowings. 

NWL  is  a  wholly  owned subsidiary  of  Northumbrian  Water Group  Limited  (NWGL),  which  is  majority owned  by 

companies in the CK Hutchison Holdings Limited (CKHH) group, based in Hong Kong, who are responsible and 

committed investors in our business.  In December 2022, KKR & Co Inc indirectly acquired a 25% shareholding in 

NWGL on a pro-rata basis from NWGL’s three other shareholders. 

14 July 2023 
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The  chart  below  shows  the  summarised  corporate  structure  of  the  Group.  The  chart  shows  the  principal 

intermediate holding companies, which are wholly owned unless otherwise shown. On 21 May 2021, CK Asset 

Holdings Limited acquired the Li Ka Shing Foundation’s indirect interest in NWGL. 

CKHH,  CK  Infrastructure  Holdings  Limited  (CKI),  Business  Thrive  Limited,  KKR  &  Co.  Inc,  KKR  Associates 

Diversified Core Infrastructure SCS, Nimbus UK Bidco and NWGL have provided Ultimate Controller undertakings 

to the Company in accordance with the provisions of the Company’s Instrument of Appointment (Licence). 

Like  any  investors,  our  shareholders  expect  a  return  on  the  money  they  invested  but  these  dividends  are  not 

guaranteed.  We  make  sure  the  dividends  are  set  at  a  level  which  is  sustainable,  remains  consistent  with  our 

investment grade credit ratings and allows us to continuously put money back into the business. 

The Board places a strong focus on maintaining long term financial resilience. We maintain a detailed five-year 

plan that is updated regularly and formally reviewed by the Board annually. This is underpinned by a commitment 

to maintaining an investment grade credit rating, as assessed by independent credit rating agencies Moody’s and 

Standard & Poor’s.  

The Board has assessed our long-term financial resilience over a seven-year period, to the end of the next price 

review cycle. This included stress testing our plan against our most significant risks and uncertainties. The Board’s 

assessment is set out in our long-term viability statement on page 130 of this report. 

14 July 2023 
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Customer bills 

The revenue that we can charge to customers is set every five years through the regulatory price review process. 

We aim to keep our bills as low as possible while still allowing us to invest in sustainable and resilient services and 

allowing a reasonable return to our investors.  

We  operate  and  finance  our  business  as  efficiently  as  we  can  on  behalf  of  our  customers,  and  we  share  any 

efficiencies we make with them. We aim to be at the frontier of cost efficiency which benefits all water and sewerage 

customers in England because it drives the efficiency frontier, against which all companies are benchmarked, to 

new levels. 

Customers benefit from sharing the cost efficiencies we make in each price review period. Any outperformance of 

the totex regulatory allowance for 2020-25 will be shared with customers, resulting in lower future bills. They also 

benefit from efficiencies in financing costs so that customers do not pay any more than is necessary. 

Long term borrowings 

We invest over £1M each business day in maintaining and enhancing our asset base to improve services for our 

customers, and this level of investment is expected to increase sharply over the next few years. The scale of this 

capital  expenditure  means  that  we  need  to  supplement  the  money  we  receive  each  year  from  our  customers 

through their bills by borrowing additional money from banks and debt markets. Our investment grade credit ratings 

and strong capital  structure  help us  to  obtain  financing  at  competitive interest  rates,  making  sure our  financing 

costs stay as efficient as possible for customers. 

We borrow in a controlled and sustainable manner to make sure we can deliver substantial investment in our asset 

base without this leading to a significant increase in customer bills. We spread the financing cost of our investment 

and manage the borrowings over long periods of time, sometimes more than forty years. This means both current 

and  future  customers  help  to  pay  for  the  investment.  As  a  result,  bills  are  more  stable  and  sustainable  for 

customers, with a fair balance of contributions between generations. 

Our borrowings range from short-term working capital financing to long term bonds, typically listed on the UK Stock 

Exchange. Our borrowings reflect a mix of fixed rate, providing stable interest costs, and inflation-linked, to match 

our inflation linked revenues. By maintaining a well-balanced debt portfolio, we can better manage risks of adverse 

movements in inflation and interest rates and minimise volatility on customer bills. 

Our total borrowings at 31 March 2023 amounted to £3.48bn, as reported in Table 1E of this report. 

Shareholder returns 

Our shareholders have provided the necessary capital and financial backing required to run the business and in 

return they receive a dividend return on the capital they have invested. During the year, the Board approved an 

updated  dividend  policy  which  recognises  the  company’s  commitments  to  various  stakeholders  including 

customers,  employees,  specifically  pension  scheme  obligations,  and  investors,  and  with  due  attention  to 

maintaining appropriate levels of financial resilience within the company.  

The updated policy aligns dividends more closely to performance for customers and the environment, as well as 

taking into account longer term financial resilience and the underlying risk profile of the business. This means that 

the returns our shareholders receive are not guaranteed from one year to the next and we paid no dividends in the 

year 2020/21 as a result of the impact of the PR19 Final Determination and the uncertainty surrounding the CMA 

14 July 2023 
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redetermination process and the impact of Covid-19. There are many significant risks associated with the business 

and it is the shareholders rather than our customers who carry the weight of these risks. 

We make sure the dividends are set at a level which is sustainable, remains consistent with our investment grade 

credit ratings and allows us to continuously put money back in the business. Our dividend policy is described on 

page 177 along with an explanation of how the directors have applied the policy in the year. 

Taxes 

Both NWL and our parent company, NWGL, are based in the UK and pay corporation tax to the UK Government. 

We are transparent about our tax arrangements and present our Tax Strategy on page 156 of this report, as well 

our website. This sets out our responsible approach to tax matters, under the oversight of the Board and its Audit 

Committees, and our constructive relationship with HMRC. 

Our customer bills include an allowance to cover the corporation tax we expect to pay, like other operating costs. 

This  allowance  reflects  the  benefit  of  tax  reliefs  that  are  available  to  us,  such  as  capital  allowances  on  our 

investment in our assets, which helps keep customer bills down. 

Responsible procurement 

Our responsible approach to procurement is described on page 1210-124 of this report.  

Case study: Tipping Point – asset life extension tool 

A new tool, initially developed at our Innovation Festival 2021, allows us to be more efficient and estimate when 

replacement is a better option than repair. 

Our entire asset base is worth £28bn, and much of it has an expected life span of decades - or even a century. To 

achieve  that,  assets  need  to  be  properly  assessed  and  maintained,  with  repairs  carried  out  promptly  on  those 

assets which are aging or damaged. 

Above Ground Civils Structures - assets often made from reinforced concrete - make up about 15% of our asset 

base. 

As those assets age, it's important to keep track of how rapidly they are deteriorating, and while tools exist to do 

that, none of them can predict the point at which replacement becomes more cost effective than repair. 

We set that challenge to the innovators at our Innovation Festival and working with Wood Group PLC (now part of 

WSP), we developed our Tipping Point Tool. 

The tool allows us to predict when assets will need to be replaced, building resilience and meaning we can focus 

our investment programme where it’s needed most. 

Before developing the tool, we needed specialists to visit and make on-site inspections before then extrapolating 

what was found across our whole asset base. 

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With  the  Tipping  Point  Tool,  those  predictions  are  far  more  accurate  and  reduce  the  risk  of  large-scale  asset 

replacements  being  required  over  a  short  period  of  time  -  something  that  would  be  expensive,  and  potentially 

undeliverable. 

Instead, we can plan and focus investment effectively. 

THEME TWO: AFFORDABLE AND INCLUSIVE SERVICES 

OUTCOME 5: Our customers say our services are good value for money and we work hard 
to keep water and wastewater services affordable for all 

AMBITIOUS GOAL: Eradicate water poverty in our operating areas by 2030 

• NWL independent value for money survey – bespoke  

• Percentage of households in water poverty – bespoke  

• Awareness of additional financial support – bespoke  

• Satisfaction of customers who receive additional financial support – bespoke  

• Awareness of additional non-financial support – bespoke  

• Satisfaction of customers who receive additional non-financial support – bespoke  

• Priority services for customers in vulnerable circumstances – common  

• Reach of Priority Services Register – common  

• Review of Priority Services Register – common  

• British Standards Institute Award for Inclusive Services – bespoke  

• Percentage of void household properties – bespoke  

• Gap sites – bespoke 

NWL independent value for money survey - PR19NES_BES30 

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We have not achieved our target.  

This customer survey is a bespoke measure which is reputational only.  

This year the average satisfaction of customers answering whether they think the services we provide represent 

good value for money remained at 8.2 out of 10 meaning we were just short of our PC. Our 2020 score of 8.3 out 

of 10 was the highest we’ve received in the last seven years. 

We are pleased to still achieve a high result and continue to promote the value of water through campaigns such 

as Water’s Worth Saving, where we actively promote the installation of a meter and how saving water could save 

money on household energy bills as well as reduce water usage.  

Given  the  affordability  challenges  our  customers  are  facing,  we’re  always  working  hard  to  keep  bills  low  and 

affordable, and despite the recent bill increase, our bills (in NW region) are still the lowest water and sewerage bills 

in England. 

We look for ways to support people when they struggle and actively promote early engagement with us. We can 

offer significant discounts where people qualify and can offer payment breaks and reduced bills. It’s also important 

that we look at new tariffs and new social tariffs to make sure we can support as many people as possible who 

need our support. This work is ongoing.  

In CCW’s Water Matters report 2022/23, we were pleased to score 86% (above industry average of 75%) in our 

NW region for satisfaction with value for money of water services. This is 5% up on last year’s score and our highest 

ever score for this measure. Overall satisfaction with sewerage services has shown a downward trend for the past 

four years and we have our lowest percentage of satisfied customers here at 82% (just above the industry average). 

However, the percentage of customers satisfied with value for money of sewerage services is at 83%, which is just 

below the WaSC top score of 84%. Further, 76% of participants agree charges are fair, a 5% increase on last year 

and significantly higher than average, which is 64%.  

In our ESW region, 79% of customers are satisfied with value for money of water services, a 6% increase on last 

year and our highest ever score (WoC average is 75%). Also, 73% of participants were satisfied with the value for 

money of their water charges which was well above the average score of 64%.  

Percentage of households in water poverty - PR19NES_BES06 

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We  have  not  achieved  this  PC.  At  the  end  of  2022,  we  peaked  with  over  190,000  customers  being  positively 

impacted through bill reductions 2020/21 and support tariffs. We now expect the bill reduction benefit to have all 

been eroded completely by 2025. 

This is a non-financial bespoke measure. We were the first water company to set the ambitious goal to eradicate 

water poverty in our regions by 2030. Customers in water poverty are paying more than 3% of their net household 

income (after housing costs) on their water bill.  

When  we  first  set  our  water  poverty  target,  we  had  an  estimated  22%  of  our  customer  base  in  water  poverty, 

equating to 380,000 households. We set out to reduce this number to 140,000 households by 2025, a reduction of 

240,000.   

One of the major strands of our original plan was a significant bill reduction at the beginning of the current price 

review which we expected to take around 100,000 customers out of water poverty. We saw a bigger benefit initially 

form this price reduction and up until this year the net bill reduction alongside our financial support schemes meant 

we  were  ahead  of  our  water  poverty  targets.  The  past  three  years  have  seen  a  period  of  significant economic 

upheaval, with Brexit, the Covid-19 pandemic and the current period of high inflation creating a cost-of-living crisis 

period, this coupled with increasing water bills, driven by higher inflation and lower real term wage increases have 

meant that the initial bill reduction has all but eroded away.    

As a result of these external factors, we have worked with TransUnion to update our baseline analysis of water 

poverty in our regions to understand the impact of the cost-of-living crisis and increasing bills on our customers. 

This has shown that there has been a net baseline reduction from 22% to 20.6% of our customers are currently in 

water poverty. This baseline reduction reflects the movement of incomes vs changes to bills over  the period and 

demonstrates that most of our bill reduction benefit has now been eroded. If we then overlay our customers on 

either a capped or reduced bill, we have 15.30% customers in water poverty, which while being behind the original 

target has meant that so far, the inflationary impacts have been mitigated for our underlying customer base. 

We are seeing an increase in customers reaching out for financial support. The cost-of-living crisis is impacting of 

customers who were previously just about managing. During 2022/23, the number of customers benefitting from 

either a reduced or capped bill tariff increased by 54% to 104,701.  

Within these numbers our company-funded tariff increased by 14% during year, with customers’ bills being reduced 

by a total of £1.35m (to be updated when final figures received).  

This is a bespoke measure, however when comparing customers on our affordability schemes, we have identified 

that we are at the lower end of performance. Funding of support is a challenge, as our customer subsidy is £3 and 

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£3.75 in North – one of the lowest in the industry. Some other companies are now nearer £20 cross subsidy so 

have the capacity to expand the offerings to different segments of customers. At our current funding level, we are 

already over capacity and unable to expand the support that we offer. 

Data sharing with DWP (Department for Work and Pensions) has continued to provide the largest opportunity to 

provide reduced bills for customers. During this year, we have increased the number of customers on WaterSure 

by 68% and Low-Income Pensioner Discount by 123%, with a large proportion of these customers being identified 

with no customer effort.  

We have successfully set up data sharing agreements with two councils to share customer data using the digital 

economy act. This allows for councils to extract customer information they have and share with us where they can 

see that customers may be eligible for a discount. To date this has identified nearly 2,000 customers where we 

have been able to apply a discount of us to 50%.   

To  reduce  customer  effort,  we  have  introduced  an  eligibility  checker  on  our  website  which  with  a  few  simple 

questions can direct them to the best financial support for them. This could be an affordable payment arrangement, 

tariff application or applying for payments to be taken directly from their benefits.  

In  January  2023,  we  expanded  our  use  of  Policy  In  Practice,  who  provide  social  policy  software  that  helps 

customers  check  if  they  are  receiving  all  of  the  government  benefits  they  are  entitled  to.  This  tool  has  been 

enhanced so that it can identify if customers are eligible for a discounted or capped bill or if they would be better 

off on a water meter. Alongside assessments for our tariffs, the tool also identifies if customers are eligible for both 

Thames Waters low-income discount and Anglian Water Lite tariffs, again reducing customer effort with customers 

only needing to apply once to cover both water and sewerage charges. We have seen over 2,500 applications 

since it was launched.  

Providing proof of eligibility for our low-income schemes has previously created a barrier for customer applications 

as they have needed to send us copies of benefit statements and bank statements. We wanted to assist vulnerable 

customers by being able to offer them 50% reduced bills for their water usage but to do this, we needed a new 

method of processing and verifying customer applications. Our data-driven solution which has been developed with 

TransUnion enables us to check eligibility at the click of a button, streamlining the customer journey and reducing 

the risks of fraud. This is due to go live in Autumn 2023 and is leading in the water industry. 

We are working with industry on how we can deliver a more aligned social tariff approach for customers in the 

future to help increase awareness of industry help and give customers confidence that those in similar situations 

across the country can get the help they need. 

Despite falling short of our target this year, we are ahead of our original targets for customers on our affordability 

schemes. Increasing the cross subsidy from customers is key for us to be able to help more customers in the future.  

Case study: Sharing data to make accessing support easier 

Data  sharing  is  an  important  tool  for  us  to  make  sure  customers  get  the  support  they  are  eligible  for.  With 

agreements in place with DWP, local authorities, housing associations and neighbouring water companies, we’re 

seeing big increases in customers able to access discounted bills and our social tariff. 

We know that understanding what support  they’re eligible for - and even knowing that support exists in the first 

place - isn’t always easy for our customers. 

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Alongside efforts to improve our communications and make application processes easier, we’ve also entered into 

a  series of  data  sharing  agreements  with  key  partners  to help  us  proactively identify  those  in greatest need  of 

support and cut out big parts of our eligibility checking process. 

Through a data sharing agreement with the Department of Work and Pensions, we’ve been able to proactive assess 

customers for eligibility for WaterSure and our pension credit tariffs. 

That work with DWP has helped us increase the number of customers benefiting from WaterSure by  60% and 

increased fourfold the number of pensioner households receiving a discounted bill. 

We’re working with local authorities, including with Norfolk County Council helping customers in arrears through 

the  government’s  Household  Support  Scheme,  and  with  our  fellow  water  company  Anglian  Water,  sharing 

information on WaterSure eligibility in our shared operating area. 

We’re also working with Believe and Gentoo - two housing providers - to help customers we do not bill directly. 

In total we have around a dozen partners who help us assess eligibility for our social tariff as part of their own 

financial wellbeing work. 

This all works to make accessing support as easy as possible for the customers who need it - and in some cases, 

they now receive it automatically. 

Awareness of additional financial support - PR19NES_BES02a 

We have not achieved our target.  

This bespoke PC measures customers’ awareness of the additional financial support we offer. This includes both 

discounted  bills  and  writing  off  customer  arrears  for  eligible  customers.  We  measure  awareness  in  quarterly 

surveys with customers.  

14 July 2023 
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Awareness  of  additional  financial  support  has  increased  slightly  since  last  year,  however,  is  lower  than  our 

stretching target of 65%. We are very disappointed and surprised with this result, especially due to the focus that 

we have taken to increase awareness of the support available.  

Lower awareness impacts our customers as they are not applying for the support that they are entitled which may 

mean they miss out on discounts available. We have already put several measures in place this year to mitigate 

this and expect to see increased awareness moving forward.  

At a time when more of our customers find themselves in circumstances where they require financial support, we 

have clear plans in place to increase awareness of the support we can offer.  

We  will  integrate  our  financial  and  non-financial  support  services  and  customer  records  to  make  sure  we  can 

provide a clear and combined service package to customers. Combining these two data sets will enable us to better 

target  and  personalise  our  messages  to  ensure  they  are  more  relevant  and  have  the  greatest  impact.  Hyper-

personalisation of our messages will enable us to proactively communicate and offer timely support when it can 

bring customers the greatest value. 

We  have  also  begun  rebranding  our  inclusivity  messaging  following  customer  research.  This  will  see  our 

communications  evolve  from  personas  we  used  in  developing  out  Water  Without  the  Worry  campaign  to  more 

relevant and accessible profiles.  

Our  smart  metering  model  office  has  developed  an  integrated  approach  where  meter  installers  are  specifically 

trained to give a rounded customer experience at an individual level based on their specific needs. Smart meter 

installers can talk to people about personal circumstances, including if they are struggling to pay their bills, at the 

time of installing the meter. This successful approach will now be rolled out across all meter services. 

We will continue to work with partners and stakeholders to share key messages across all available channels to 

make sure maximum exposure and reach. 

We  will  work  to support  customer  adoption  and  education of  digital  tools  and  we  will offer  alternative  routes  of 

communication where social media and digital tools are unavailable. This may include having a greater presence 

in local communities where there are higher levels of digital deprivation. 

Case Study – Believe Housing Partnership 

Following an idea from our 2022 Innovation Festival, we completed an initial six-week trial working with Believe 

Housing in the North East. Believe is a social housing provider in County Durham with more than 18,000 homes. 

During the trial, we co-located employees in Believe’s offices, also working with the local authority and The Money 

and  Pensions  Service  (MaPS)  to  offer  a  one-stop  support  service  covering  water,  housing,  council  tax  and 

money/debt advice. This initiative delivered fantastic customer outcomes in providing rounded support to those in 

need. 

This successful trial led to interest from two more housing associations that operate in our area wanting to carry 

out similar activities. 

Satisfaction of customers who receive additional financial support - PR19NES_BES01a 

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We have achieved this PC.  

This bespoke, reputational only PC is designed to make sure we provide high quality financial support to household 

customers  that  are  signed  up  to  one  of  our  SupportPLUS  tariffs or  WaterSure.  The  score  is  determined as  an 

annual mean from telephone surveys, during which a total of 1,000 customers who are receiving financial support 

for either water arrears or ongoing charges are asked to rate their overall satisfaction with the services we provide. 

We continued to beat our target of 8.7 with a high score of 9.2.  

With the impact of the cost-of-living crisis we are seeing customers reaching out to receive financial support who 

have never struggled to pay before. To support customers through this we have continually reviewed our approach 

to raising awareness of financial support available and reducing effort for customer application.  

During 2022 we have taken a new approach to applications for our affordability schemes, both with the introduction 

of a telephone application process for our customers who have found themselves in short term financial hardship, 

and also the expansion of our partnership with Policy In Practice. They offer an online tool that has been tailored 

to  assess  the  best  tariff  for  our  customer,  with  the  additional  benefit  of  identifying  any  additional  government 

benefits they may be eligible for.  

The scores we receive (via a satisfaction score out of 10), indicate that we are delivering a quality approach to 

supporting these customers. 

Awareness of additional non-financial support - PR19NES_BES02 

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We have not achieved our target.  

This bespoke PC measures customers’ awareness of the non-financial services we offer as part of our Priority 

Services Register. We’ve achieved 45.3% awareness, which is similar to last year and we recognise we need to 

do more.  

We need to understand customers circumstances to allow us to tailor our service for customers. We have already 

put several measures in place this year to mitigate this and expect to see increased awareness moving forward. 

Using our PSR digital twin dashboard, which details internal and external information about demographics, sign-

ups to tariffs and PSR information to help us understand our customers better, we have been able to prioritise 

which segments to target who may need additional non-financial support. For example, segmenting pensioners, 

homes  with  young  children  and  people  with  health  problems.  We’ve  created  a  messaging  matrix  from  this 

information by identifying their needs rather than using generic messaging.   

We’ve created a suite of digital adverts using these messages promoted online on websites and social media and 

using keywords targeted on Google. We also continue our outdoor advertising for "Just add Water which supports 

these messages for customers who are not online.  

Going forward we will integrate our annual marketing communication campaigns to better highlight the financial 

and  non-financial  services  we  offer,  personalised  and  tailored  to  customers  unique  circumstances.  Following 

customer research, we are rebranding our inclusivity messaging. This will see our communications evolve from 

personas we used in developing out Water Without the Worry campaign to more relevant and accessible profiles. 

We will integrate our financial and non-financial support services and customer records to ensure we can provide 

a clear and combined service package to customers. Combining these two data sets will enable us to better target 

and personalise our messages to make them more relevant and have the greatest impact. Hyper-personalisation 

of our messages will enable us to proactively communicate and offer timely support when it can bring customers 

the greatest value. 

Building  on  existing  data-sharing  arrangements  with  UKPN,  we  are  working  with  SGN,  UK  Power  Networks, 

Northern Powergrid, Northern Gas Networks and the Cross Utilities Forum, as well as with other water companies, 

to identify the best way to share information about those who need extra support. After successfully bidding for 

funding to Ofwat’s Innovation Fund, the “Support for All” project seeks to design and build a hub to host this data, 

sharing Priority Service Registers between companies. Once this is working regionally, we would like to develop 

this into a national platform to benefit society.  

Our  smart  metering  model  office  has  developed  an  integrated  approach  where  meter  installers  are  specifically 

trained to give a rounded customer experience at an individual level based on their specific needs.  Smart meter 

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installers  can  talk  to  people  about  personal  circumstances  at  the  time  of  installing  the  meter.  This  successful 

approach will now be rolled out across all meter services. 

We  will  work  with  partners  and  stakeholders  to  share  key  messages  across  all  available  channels  to  ensure 

maximum exposure and reach. Going forward in our 2025-30 Business Plan we want to invest more in partnerships 

and community engagement teams who can integrate into the local communities. 

We  will  work  to support  customer  adoption  and  education of  digital  tools  and  we  will offer  alternative  routes  of 

communication where social media and digital tools are unavailable. This may include having a greater presence 

in local communities where there are higher levels of digital deprivation. 

Satisfaction  of  customers  who 
PR19NES_BES01 

receive  additional  non-financial  support 

- 

We have not achieved this PC. 

This is a bespoke PC, which is reputational only. An independent market research provider has interviews 1,000 

customers to understand their satisfaction with the service they have received. 

Over this year, we have seen a slight reduction in the customer satisfaction from customers compared to previous 

years. We have just missed our PC this year with a score of 8.5 out of 10. 

This decrease was most noticeable in the last quarter, where we saw the lowest result of this year with 8.3. 

In  Q4  of  2022  we  asked  250  customers  who  are  on  either  our  Priority  Services  Register  (PSR)  to  rate  their 

satisfaction and to also tell us why they gave their score. The top reasons were: 

•  No problems/never had a problem (20%)  

•  Good/great scheme/idea – beneficial (10%) 

•  Alert customers regarding issues, works, supply problems, updates (9%) 

•  Satisfied/happy with them/been good to me (8%) 

14 July 2023 
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•  Helpful/supportive (7%) 

•  Reassuring to have/offers what we need (7%) 

• 

The fact they have/will supply bottled water, so never without (6%) 

•  Good/proactive communication/return calls/frequent etc (4%) 

•  No supply problems (4%) 

•  Good service/customer service (4%) 

•  Poor/no communication (3%) 

• 

It’s excellent/brilliant etc (3%) 

We saw that 9% of customers are referencing supply issues as the focus on their scoring. This year we have seen 

a significant increase in the number of customers registered on our PSR and this has impacted the level of service 

we have been able to provide for supply interruptions with delivery of bottled water so anticipate this has impacted 

on customer satisfaction. 

Delivering unrivalled customer experience means making sure all our customers receive leading service, especially 

when  they  are  in  vulnerable  circumstances,  so  we  were  very  disappointed  with  this  result.  They  rely  on  the 

reassurance of a constant supply of water. We have completed a benchmarking exercise to understand the level 

of service offered by other water companies and how we compare. We will carry out a full review of our approach 

to  interruptions  to  supply  and  delivery  of  bottled  water  to  help  us  to  manage  customer  expectations.  In  the 

meantime, the sharp increase in demand due to the higher number of customers who are on our PSR means we 

will focus on prioritising bottled water delivery to those customers with medical dependency. This approach is in 

line with other companies. 

We are also reviewing our approach to notifications of the services that we offer and the messaging to communicate 

when  work  is  being  completed  in  the  area  that  might  impact  customers.  For  example,  potential  access/noise 

disturbance  or  if  work  needs  to  be  carried  out  to  maintain  a  constant  supply.  A  benchmarking  piece  using 

information from company websites and direct contact with colleagues at other water companies to compare how 

bottled water requests are managed during an incident has been carried out. Some companies outsource bottled 

water delivery and have a longer timescale than we currently do (three hours). This is currently industry leading 

and the increase in our PSR numbers means will be unable to sustain this level of service with current resource, 

so we need to look at our alternatives. 

Priority services for customers in vulnerable circumstances - PR19NES_COM16 

This  is  a  common,  reputational  PC.  Its  purpose is  to ensure  a  minimum  standard across  all  companies  for  the 

number of households registered on the Priority Service Register (PSR) and for PSR data checking.  

The PC has the following criteria: 

• 

The  PSR  reach:  percentage  of  households  that  the  company  supplies  with  water  and/or 

wastewater services that are registered on the company’s PSR. 

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•  Actual contact: percentage of distinct households on the PSR that the company has contacted 

over a two-year period.  

•  Attempted  contact:  percentage  of  distinct  households  on  the  PSR  that  the  company  has 

attempted to contact over a two-year period. 

To achieve compliance with this PC, all the reach, attempted contact and actual contact targets must be achieved. 

Reach of Priority Services Register (PSR)  

We have achieved this PC.  

More than 8.8% (174,573) of our households are now registered. PSR membership figures include: communication 

(15,350),  support  with  mobility  and  access  restrictions  (123,690),  support  with  supply  interruption  (162,035), 

support with security (22,369) and support with other needs (49,195). 

During 2022 we have increased the number of customers on our PSR register by over 73k households. This has 

been achieved through several initiatives:  

* Expansion of data sharing with UK Power Networks, the company that owns and maintains the electricity cables 

and lines in our Essex and Suffolk operating areas. Due to the success of this partnership this approach is now 

being  extended  to  Northern  Power  Grid  and  Electricity  Northwest,  who  maintain  services  in  our  North  East 

operating region.  

* Using internal data to understand customers who are not registered on our PSR, however have circumstances 

that identify they would require tailored support. This could be age or where they have shared that they are claiming 

mobility benefits.  

*  Partnership  approach  with  councils  and  housing  associations  to  register  households  where  they  know  the 

occupiers are vulnerable. For these households, the housing associations are being registered so that they have 

advance notification of interruption to supply and can provide additional support.  

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We  have  used  data  analysis  of  inbound  calls  to  highlight  any  missed  opportunities  of  PSR  registration.  Since 

moving to our latest telephony platform, our telephone calls are also transcribed now, as well as recorded, and 

through data mining we have been able to extract where key words or phrases have been used. Further analysis 

is to be completed to understand if this can be expanded.   

After successfully bidding for funding to Ofwat’s Innovation Fund, the “Support for All” project seeks to design and 

build a hub to host this data, sharing Priority Service Registers between companies. Once this is working regionally, 

we would like to develop this into a national platform to benefit society. This will be a leading approach and is being 

built collaboratively with other water companies. 

Review of Priority Services Register 

Actual contact 

Attempted contact 

We have achieved this PC.  

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This common PC verifies customers’ needs where they have been on the PSR for more than two years and we 

have beaten both our actual and attempted contact targets again this year.  

We are validating our PSR register in four main ways: 

• 

• 

• 

When a customer who is already on our PSR contacts us the Customer Advisor receives an alert to 

verify their needs. 

As part of our proactive contact with customers, when we are completing planned work, we review 

their PSR information.  

We are making outbound contacts to customers who were due to have their information validated who 

hadn’t  contacted  us  directly. This has  involved  sending  letters  in  with  customers’  bills  and  sending 

texts and emails where we have received our highest response rate. 

• 

We are working with large housing associations to update social housing properties for tenants living 

in accommodation reserved for anyone needing support. 

With the number of customers registered on our PSR increasing year on year, this year we had over 45k properties 

where we had customers on the PSR register for over two years.  

Following the success of last years’ text and email campaigns, we used these as our primary contact approach. 

We need to keep our PSR up to date to make sure customers receive the tailored service they require. The letters 

that we send also give a summary of all the services that are available so that customers are more aware of the 

offerings and can sign up for additional services. 

British Standards Institute Award for Inclusive Services - PR19NES_BES23 

We have achieved this PC.  This is a bespoke PC and is reputational only. Our target is to maintain this award 

consistently.  

This PC is designed to make sure we provide a fair, flexible service which can be used by all customers equally, 

regardless of their health, age, or personal circumstances. 

14 July 2023 
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We’re proud to have maintained BS 19477: Inclusive Service Verification (BSI) this year. The standard assesses 

whether  inclusive  services  are  fully  accessible  to  all  customers  and  that  companies  have  the  right  business 

processes in place. 

This is the third year that we have completed the audit which reviews our approach to vulnerability and makes sure 

our services are inclusive for all - whatever a customer’s circumstances. During the assessments BSI reviewed our 

documented policies and procedures, then held sessions with our teams to see how we operate the policies and 

procedures  on  a  day-to-day  basis.  The  sessions  include  contact  with  all  areas  of  the  business,  including  call 

listening,  a  complaints  review,  our  communications  planning,  how  we  manage  events,  debt  recovery  and 

affordability. 

With BSI alongside core expectations on delivery of service, they continually focus on seeing how we are continuing 

to develop our offering and learning from customer feedback. We’ve put an action plan in place to cover the non-

conformity and opportunities highlighted, which will be completed this year to further enhance our website offering 

and how we improve the identification of triggers and risk factors that highlight our customers may be in vulnerable 

circumstances.  

We’re always reviewing the services we offer, and this expert assessment provides regular external scrutiny of our 

processes.  This  was  our  best  result  of  the  three  audits  that  have  been  completed,  where  there  were  no 

nonconformities identified.  

Following the audit last year, we have successfully delivered action plans to improve the accessibility of our website 

and also a detailed plan on training on identifying customers in vulnerable circumstances and how we can have 

open conversations to identify how best we can offer support.  

BSI  recognises  our  performance  in  delivering  tailored  services  for  all  our  customers.  This  standard  is  widely 

achieved in the water industry, and the standard is transitioning to a Kitemark which is an enhanced audit. This 

has  been  completed  by  a  pilot  group  of  water  and energy companies  and  we  will  shortly  be  completing  a  gap 

analysis for our transition in 2023. 

Percentage of void household properties - PR19NES_BES08 

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We have achieved this PC.  

This is a bespoke measure, with financial incentives for both under and outperformance. We’ve beaten our PC 

again and earned a financial reward of £1.33m. 

Billing  all  customers  in  a  timely  and  accurate  way  has  always  been  our  focus.  Reducing  the  number  of  void 

properties,  which  are  occupied  but  not  billed,  leads  to  fairer  charges  between  customers  and  lower  bills  for 

customers already being billed. 

We continue to work closely with TransUnion to improve the way that we proactively use credit reference data to 

identify properties that are occupied yet not billed. We have continued to refine the selection criteria to improve the 

quality of accounts raised via our established auto billing process. This alongside automation to deal with returned 

post and steps in the trace process, has enabled an efficient empty property routine to be embedded. 

Our work continues with local authorities and housing associations to share information on their tenants who may 

not yet have registered for billing, these arrangements help tenants by reducing back billing and creating debt and 

offer us an opportunity to actively offer information on our support tariffs. 

In future years we expect to see improvements by using data from our smart metering programme to help identify 

when  customers  have  moved  out  without  telling  us,  or  where  they  have  started  to  use  a  supply  that  we  have 

registered as empty. We are working to establish an efficient process for those properties where consumption is 

identified by our new smart meter data management system, and we don’t have a registered bill payer.  

Gap sites - PR19NES_BES07 

We have not achieved this PC.  

The aim of our bespoke gap site PC is to reduce the risk of sites or properties receiving water and/or wastewater 

services that are unknown to us and are not being billed. Reducing the number of these gap sites, which are also 

potentially occupied, leads to fairer charges between customers and lower bills for customers already paying.  

This PC is reputational only so no penalty or reward is payable.  

14 July 2023 
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The number of gap sites cannot be measured directly as they are unknown to us. The only way to assess gap site 

risk is by comparing our property data with third party information to look for differences.  

Over the last 12 months our focus has been on data quality and eligibility of premises within the market following 

an updated eligibility guidance produced by Ofwat in August 2022. In 2021/22 we completed 1,179 deregistrations; 

this increased to 1,632 in 2022/23 which demonstrates that we concentrated on removing ineligible premises. The 

number of gap sites we completed in 2021/22 was 409 and this remained roughly the same with 424 gap sites 

completed in 2022/23.  

MOSL  (the  market  operator  for  the  non-household  water  retail  market  in  England)  monitors  and  compares 

wholesalers across a range of measures including the number of  Government’s Valuation Office Agency (VOA) 

references and unique property reference number (UPRN) each wholesaler updates in the central market register. 

This  metric  is  purely  looking at  fields  populated  and  does not measure the level of  accuracy.  We are currently 

placed third for completeness of VOA score and eleventh for completeness of UPRN score.    

The  NHH  market  2023-26  Business  Plan  focuses  on  the  need  to  remove  friction  in  the  market  and one  of  the 

strategic goals is to make sure wholesalers create and maintain accurate and reliable address data in the central 

market register.  A data quality trial (Project TIDE) was completed by MOSL in April 2022 which showed that 16% 

of records in the market could not be matched to address referenced sources and a focus group to look at the 

findings has been created. No agreed methodology of what good data quality should be measured against has 

been released and, following the Data Cleanse Consultation document published in November 2022, we decided 

to pause any work we were doing to match against  VOA business listings or update UPRN references through 

Address Based Premium until an agreed guidance has been released.  

To improve our performance, we are working together with a third party who will match our data against address 

reference sources to produce a list of gap sites that we can work through and add to our source systems and the 

non-household (NHH) market. We have recruited additional resource to manage this project.    

THEME THREE: RELIABLE AND RESILIENT SERVICES 

OUTCOME  6:  We  are  resilient  and  provide  clean  drinking  water  and  effective  sewerage 
services; now, and for future generations. 

•  Risk of severe restrictions in a drought – common 

•  Delivery of our smart water metering enhancement programme – bespoke 

•  Delivery of our water resilience enhanced programme – bespoke  

•  Delivery of our lead enhancement programme – bespoke 

•  Delivery of our wastewater resilience enhanced programme – bespoke 

•  Delivery of our Howdon Sewage Treatment Works enhancement – bespoke 

•  Delivery of our cyber resilience enhancement programme – bespoke 

•   Delivery of our Drainage and Wastewater Management Plan – bespoke 

14 July 2023 
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Risk of severe restrictions in a drought - PR19NES_COM10 

We have achieved this PC.  

The overall metric is the percentage of our population at risk of experiencing severe restrictions in a 1-in-200-year 

drought,  on  average,  over  25  years.  The  metric  tracks  water  company  implementation  of  Our  PR19  Water 

Resources Management Plan (WRMP19) supply and demand schemes, to reduce the percentage of customers at 

risk of severe drought restrictions.  

We  report  a  result  of  0%  of  population  at  risk  for  this  metric,  meeting  our  PC,  reflecting  progress  to  date  with 

implementing our WRMP19 schemes. Our WRMP19 demonstrated that we have 100% security of supply in all our 

Water Resource Zones (WRZs), across the full 40-year planning horizon. We also demonstrated resilience to a 

drought with a return period of 1 in 200 years in all our WRZs, with 0% of our customers at risk from severe supply 

restrictions. We therefore did not need to promote any supply schemes in our WRMP19 but did include demand 

management schemes.  

Delivery of our smart water metering enhancement programme - PR19NES_BES26  

14 July 2023 
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We have not achieved our target.  

This is a bespoke, penalty-only PC to incentivise delivery and return funding to customers if we fail to deliver the 

programme in full by March 2025. The PC specifically measures the percentage delivered of our smart metering 

programme. This is limited to installing new smart meters and replacing existing basic meters with smart meters. 

Only household meters can be counted for this PC, and only once for each household in the five-year period. New 

developer installs are also discounted from the PC despite advanced metering infrastructure (AMI) meters being 

installed at these properties. 

We’re committed to rolling out smart water meters for our customers with the overall goal that all our meters will be 

fully smart by 2035. While we made significant progress with the smart programme in the last year, we did not 

achieve our PC for 2022/23. 

In the last year we expanded our Arqiva Flexnet smart communications coverage with the addition of two further 

communication  towers  on  the  Thames  border.  This  provides  smart  coverage  to  a  total  of  78,000  properties  in 

Essex. To date we have connected 26,000 meters to this network capable of providing hourly read data. This rich 

source of data allows us to better understand water usage in our supply area and identify leakage and wastage, 

enabling us to work with customers to help reduce demand and leakage. 

By the end of March 2023, the install volumes for 2022/23 were 29,050 new installs, 17,360 replacements and 

13,351 at new builds or bulk meter to individual replacements, which do not count towards the PC. While this is an 

increase of 49% on 2021/22 installs performance, 2022/23 performance fell short of target.   

We continue to offer our customers free water meter installations, on request. Our current strategy is to install only 

smart meters in our Whole Area Metering (WAM), selective and replacement programmes. These meters can be 

read  in  automated  meter  reading  (AMR)  or  advanced  metering  infrastructure  (AMI)  modes  where  a  Smart 

Communications Network (SCN) is installed. All meters installed are therefore classified as ‘smart’ based on the 

definition outlined by Ofwat. However, until a meter is covered by an SCN it remains in AMR mode and is read 

manually. There will be instances when a customer may request a ‘basic’ meter, either through the non-household 

retail market (meter to be logged) or for our domestic customers for religious grounds. 

We are still recovering from the slow start that we made to our metering programmes in 2020/21 which was largely 

driven by the effects of Covid-19. We continued to see supply chain constraints driven by Covid-19 and the war in 

Ukraine  which  has  capped  our  install  opportunity  in  the  last  year  and  led  to  a  four-month  slowdown  in  install 

volumes to mitigate wider meter stock shortages. This is an industry wide issue that also affected smart installation 

activity at other water companies. The delays to our smart metering programme also impacted our water efficiency 

drive and PCC (per capita consumption) targets.  

We delayed procurement of additional meter variants and the enduring smart communications network until we 

had signals from the market that the supply chain was improving. A further factor constraining deployment was the 

ongoing issues recruiting additional resource in a challenging labour market, particularly in our Essex and Suffolk 

operating regions.  

In response to these challenges and supply chain constraints, we are prioritising efforts on installation of NEW 

smart  meters  (I.e.  installations  where  no  meter  previously  existed)  as  opposed  to  upgrading  existing  analogue 

meters to smart, as it is the new installations where we see the greater benefit in terms of managing consumption 

and leakage. 

14 July 2023 
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Customer demand for meters (optants) started to recover to pre-pandemic levels and by the end of the year we 

were seeing a 67% increase in demand versus February 2020. To drive further demand for meter installation we 

ran a series of targeted marketing campaigns aimed at customers in Essex and Suffolk who would benefit the most 

from moving to a metered bill. However, we did not meet our total optant demand target for the year (23,000) as 

we achieved a total install volume of 16,580. Total customer demand (optant applications) was 25,141. 

We  have  now  installed  26,500  WAM  meters  at  previously  un-measured  properties.  We  engage  with  these 

customers on a six-monthly basis to share their measured water consumption and  to give them data that allows 

them to compare it to their un-measured charges. Overall, we are seeing that 26% of customers could benefit from 

switching to a metered bill with an average saving of £192 per year. A further 36% of customers could make a 

financial saving by adopting small behaviour changes.  

Through hourly smart data we were able to identify 2,077 properties with customer side leakage. Many of these 

were  at  previously  un-measured  properties  where  it  would  have  otherwise  been  unlikely  that  we  would  have 

identified a leak. 39% of these leaks have been resolved but persuading customers to take action for low volume 

leaks still proves challenging.  

We remain focused on maximising programme delivery by March 2025 however there remains the risk of a shortfall. 

As a minimum we expect to deliver our PR19 expectations in full in our Suffolk operating area. Within Suffolk, in 

the  water  stressed  Hartismere  supply  zone,  we  are  aiming  to  achieve  close  to  100%  meter  penetation,  for 

household and non-household customers, by March 2025 – exceeding the commitments we set out at PR19. 

Following on from 2022/23, we are forecasting a further increase in installations of 32% for 2023/24 and 38% for 

2024/25, a trajectory which continues to ramp up our delivery capability in advance of targeting a larger metering 

programme in 2025-30.  

Case study: Empowering employees as ‘Smart Cookies’ 

To  continue  to  deliver  unrivalled  customer  experience  and  foster  a  deeper  understanding  of  smart  meter 

technology, we are introducing a unique initiative called "Smart Cookies" later this year. The initiative will empower 

non-senior  managers  across  the  organisation  to  become  knowledgeable  ambassadors  capable  of  addressing 

customer inquiries related to smart meters. 

Smart  Cookies  will  carry out comprehensive training  to  enable  them  to  provide valuable  insights  into  customer 

energy  consumption  patterns.  This  data-driven  approach  ensures  that  they  can  offer  personalised  advice  and 

recommendations tailored to individual needs, at the same time as carrying out their original roles.  

By providing employees with real-time data and personalised information, we aim to enhance customer service 

and facilitate meaningful conversations that address individual and household energy needs. 

Knowledge sharing across the business will promote the exchange of ideas, best practices, and lessons learned, 

further enhancing their expertise in the smart meter domain.  

Delivery of our water resilience enhancement programme - PR19NES_BES24 

14 July 2023 
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In  our  2020-2025  Business  Plan  we  committed  to  making  some  improvements  to  strengthen  the  resilience, 

effectiveness, and efficiency of our water services through several major investment schemes.  

These schemes in the North East include a new underground reservoir at Springwell (Gateshead) and upgrades 

to our Tees pipeline along with a new Abberton to Hanningfield pipeline in the Essex area  – all of which aim to 

improve the resilience of our water supply network.  

These schemes are due for completion by or before March 2025 and we encountered some setbacks during the 

Covid-19  pandemic,  with  some  schemes  starting  later  than  originally  planned.  In  addition,  global  supply  chain 

issues, manufacturing problems and component shortages have also meant some of the schemes were delayed 

in  starting.  Funding  for  one  scheme  was  granted  a  year  later  than  normal  when  we  appealed  Ofwat’s  funding 

settlement for 2020-25 to the Competition and Markets Authority (CMA). 

Despite these challenges we remain fully committed to delivering these schemes for our customers on time and 

are working hard to achieve this. 

In some instances, there may be a small amount of follow-on activity (and expenditure) remaining to be 

done after this date, for example landscaping work at the site. Also, in some instances the enhancement 

scheme  may  be  incorporated  within  broader  investment  being  made  on  an  asset,  and  part  of  that 

broader investment may continue after the deadline for the enhancement element.  

A summary of these schemes, target and forecast completion dates, and a description of the criteria for 

successful completion, is described in the table below. 

SCHEME  

TARGET 

FORECAST 

SUMMARY OF ACTIVITY  

DESCRIPTION OF 

DATE 

COMPLETIO

N DATE 

SUBSTANTIAL 

COMPLETION 

Mosswood: We’re 

Dec  22  (for 

Dec 23  

The Drinking Water Inspectorate 

 As Agreed with the 

installing new treatment 

DWI 

(DWI) elements of the scheme 

Drinking Water 

capability at this 

elements) 

were delivered on time by 

Inspectorate  

treatment works in 

County Durham to 

manage cryptospridium 

risk from raw water 

sources (such as 

rainwater and ground 

water).   

December 2022. The remaining 

elements, including a power 

supply upgrade, are scheduled 

to complete by end 2023. 

Layer: We’re installing 

Mar 25 

Jan 25  

We’re in the final stages of 

As Agreed with the 

new treatment processes 

negotiating costs and estimate 

Drinking Water 

to address raw water 

quality changes in 

Abberton Reservoir. 

we will award the contract for 

Inspectorate. Read 

this work by September 2023. 

more here.  

14 July 2023 
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Springwell service 

Mar 25 

Jun 25 

In Jan 23 we awarded the 

Protect 52,147 from a 

reservoir: We’re 

constructing a new 

storage reservoir in 

Gateshead together with 

1.5km of pipe to connect 

the reservoir to our 

network.  

contract for the work, and we 

loss of supply event by 

forecast completion 3 months 

providing additional 

late in June 2025 with 5% 

storage sufficient to last 

(£2.4m) of investment forecast 

24 hours in the event of 

to be after the deadline. This is 

a supply failure. Read 

due to a reservoir size review 

more here.  

extending procurement and 

planning timelines. The 

contractor is on site and 

construction is about to begin. 

There has been a series of 

successful customer events.   

Tees pipeline: We’re 

Mar 25 

Mar 25 

The contract was awarded in 

70,404 to benefit from a 

upgrading the network in 

the North East.  

August 2022. Construction work 

second source of supply 

has started on the shafts for the 

should an issue arise 

Tees Crossing and we forecast 

with their primary 

completion date for some 

source. Read more 

elements of the work (those 

here.  

linked to our enhancement 

commitment) by March 25. 

Planning permission is granted. 

The schedule remains tight, and 

some elements cannot be 

accelerated by increasing 

workforce (for example, river 

crossings). 

Abberton pipeline: We’re 

Mar 25 

Mar 25 

We’re in the final stages of 

370,000 customers to 

upgrading the network in 

Essex (also known as 

Layer to Langford 

pipeline) 

negotiating costs and estimate 

benefit from increased 

we will award contracts for the 

resilience of raw water 

pipe procurement in September 

supplies. Read more 

2023.  

here. 

Barsham: We’re installing 

Mar 25 

Mar 25  

The contract was awarded in  

36,614 customers to 

a borehole water 

treatment plant and a 

new treated water service 

reservoir.  

2022. Construction is underway 

benefit from increased 

excavating for the main 

resilience equivalent to 

structures. We forecast 

24 hours of storage. 

completion by March 2025.  

Note we remain in discussions with Ofwat to clarify the terms of the ODI attached to this programme. 

14 July 2023 
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Delivery of our lead enhancement programme - PR19NES_BES25 

We have not achieved this PC.  

This programme is supported by a bespoke, penalty-only PC to incentivise delivery and return funding to customers 

if we fail to deliver the programme in full by March 2025, alongside a reputational target in each year of the period 

against  which  we  can  track  progress.  While  we  are  currently  behind  our  original  output  profile,  we  are  gaining 

momentum and remain confident that we will deliver 100% of the programme by March 2025.  

As a priority, we want to protect those most vulnerable to the effects of lead in drinking water by focusing on lead 

pipe replacement in buildings frequented by children (our Vulnerable Groups scheme, which covers educational 

and community establishments).  

In addition to protecting our most vulnerable communities, our lead pipe replacement programme prioritises areas 

at  the  highest  risk  to  lead  exposure  (our  Hot  Spots  scheme).  These  schemes  are  spread  across  our  three 

geographic supply areas so all our customers will benefit. 

To  mitigate  the  risk  of  lead  in  drinking  water  at  the  tap,  the  programme  goes  beyond  replacing  our  lead 

communication  pipe  by  replacing  the  customer’s  lead  supply  pipe  to  inside  their  homes.  The  success  of 

replacement therefore requires individual property owner’s consent.  

Our lead replacement programme was impacted throughout 2020/21 by Covid-19. There were two main aspects 

of  this.  Firstly,  the  impact  that  the  government  restrictions  had  on  our  supply  chain  and  their  people  being 

furloughed as a result, and secondly, our customers were reluctant to engage in a programme that involved work 

inside their homes.  

In 2020, we focused on developing the delivery strategy, including setting up the commercial framework,  and on 

implementing the model for delivering and reporting on our lead enhancement commitments. Although, some lead 

replacement was able to start in 2021, concerns for the pandemic were still high and it wasn’t until January 2022 

that we were able to move forward with more assurance within the circumstances.  

Throughout 2022/23 we have refined our customer engagement strategy and exceeded our annual target outputs 

for  hot  spots.  In  addition,  we  have  secured  business  authorisation  for  our  delivery  approach  which  will  see  us 

deliver  a  greater  proportion  of  hot  spot  and  rural  candidates  whilst  extending  the  project  covering  vulnerable 

customers to also include registered nurseries, child minders and foster carers, as well as schools. 

14 July 2023 
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We are still confident we can deliver 100% of our programme by 2025, by flexing the ratio of scheme types (hotspots 

v  rural  supplies  v  vulnerable  customers)  to  reflect  levels  of  customer  take-up/stakeholder  appetite.  We  are 

increasing resources to accelerate delivery in years four and five to support this.  

Delivery of our wastewater resilience enhancement programme - PR19NES_BES27 

We have achieved this PC.  

This bespoke,  penalty-only  PC  tracks  the  delivery of  our  wastewater  resilience  enhancement programme.  This 

programme  is  focused  on  delivering  investment  at  141  sewage  treatment  works  (STW)  and  sewage  pumping 

stations (SPS) to increase the resilience of our wastewater network and mitigate disruption to customers.  

We achieved 101 outputs by the end of 2022/23 (ahead of the target), which included a variety of measures to 

mitigate flood risk or improve recovery in the event of power failure thereby increasing the resilience of our network. 

All site visits have been completed and a project to deliver the remaining 40 outputs is now underway. 

Delivery  of  our  Howdon  sewage 
PR19NES_BES29 

treatment  works 

(STW)  enhancement 

- 

We have achieved this PC so far but are flagging it as at risk.   

14 July 2023 
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Howdon is one of our largest STWs. This scheme seeks to improve the sites resilience. Two key assets have been 

identified  as  requiring  a  major  upgrade:  the  primary  effluent  pumping  station  (PEPS),  the  Southbank  pumping 

station (SBPS) and both associated rising mains. These assets are required to deliver flows up to 6,200l/s. 

This programme is supported by a bespoke, penalty-only PC to incentivise delivery and return funding to customers 

if we fail to deliver the scheme by March 2025. As planned, we are now in the final stage of contractual negotiations 

with our lead delivery partner, Mott MacDonald Bentley. There are some complex programme challenges which 

are currently being worked through so that we can successfully deliver the resilience elements within this agreed 

timescale. However, due to some complex construction constraints required to ensure that STW performance is 

maintained, there is a risk that delivery may be delayed by up to twelve months. 

To mitigate some of this risk, as much of the works as possible are being accelerated. Demolition of derelict assets 

on the recently purchased land adjacent to the existing Howdon site is ongoing so that the working area is fully 

prepared for Mott MacDonald Bentley, so that they commence the upgrade as quickly as possible. 

The project has two further objectives to increase the permitted dry weather flow, due to population growth in the 

next 25-30 years (estimated to be 150,000 population equivalent) and additional measures to better manage storm 

flows. We know our customers want us to greatly reduce spillages and we are setting new aspirational targets for 

our approach to rives and coasts in our long-term vision for 2050.   

The  delivery of  this  additional  scope  is  aligned  to the programme  for  the  expected  population growth,  which  is 

continually under review so that business risk is fully managed. Delivery of this growth scope is phased to complete 

by early 2027. 

Delivery of our cyber resilience enhancement programme - PR19NES_BES28 

We are on target to achieve this PC at the end of March 2025.  

This  programme  aims  to  deliver  multiple  benefits  by  enhancing  our  cyber  security  function  and  supporting 

compliance with the Network and Information Systems (NIS) Directive. We have already delivered most of this PC 

and are on target to deliver by the end of the 2020-25 Business Plan.  

We continue to monitor the increasing cyber threat landscape to make sure our investment is focused on the areas 

that  have  the  greatest impact  on  protecting  our  business. Keeping  up  with  advancements  in  technological  and 

human cyber capability, particularly from well-funded foreign state threat actors is both challenging and expensive 

so we make sure our investments are allocated to the most appropriate areas. We continue to develop our policies 

14 July 2023 
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and are making sure all our people are equipped with the relevant knowledge and continue to develop through 

Exercises, Training and Phishing simulation tests. 

Several cyber security procurements and enhancement have been made during 2022/23 and others are currently 

in flight. Our Cyber Security team is increasing in size to support new enhancements and we continue to develop 

our security posture in line with our continuous improvement strategy to make sure technical and human advances 

by malicious threat actors are mitigated appropriately and keep our people and our customers safe.  

Delivery of our Drainage and Wastewater Management Plan (DWMP) - PR19NES_BES32 

We have achieved this PC.  

In 2023 for the first time, we are due to publish a Drainage & Wastewater Management Plan (DWMP) to identify 

how we will extend, improve, and maintain a robust and resilient drainage and wastewater system considering the 

pressures of climate change, population growth and growing customer expectations. 

Publication  of  our  DWMP  is  supported  by  a  bespoke,  reputational-only  PC,  performance  against  which  will  be 

assessed in 2023.  

As planned our draft DWMP was published in June 2022 and included an adaption to our plan to meet the new 

requirements of the Storm Overflow Discharge Reduction Programme set out by Defra. Following publishing we 

have carried out further work on:  

• 

The  development  our  plan  following  publication  of  the  Defra  Storm  Overflow  Discharge  Reduction 

Programme (SODRP), including prioritisation of Storm Overflow (SO) interventions. 

• 

Further development and submission of our Water Industry national Environment Programme (WINEP) 

programme to the Environment Agency (EA). 

•  Our DWMP structure and narrative following feedback from Defra, Ofwat, EA, and CCW. 

We published our DWMP on 31 May and this will include all aspects of our wastewater plan that will be included in 

our 2025-30 Business Plan in October 2023.  

Our DWMP will be based on the information available from regulators on 6 April 2023. Any further changes after 

this date may require us to republish at a later date. We are planning for this scenario as many aspects of our plan 

are yet to be agreed, for example, WINEP, and we are still awaiting guidance for some aspects (nutrient neutrality). 

Smart networks are an evolving concept which presents an opportunity to further strengthen our DWMP - we have 

commissioned  a  study  with  Hydro  Digital  to  understand  the  possibilities  available.  This  work  will  be  used  in 

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particular  to inform our planned interventions for our storm overflow programme, identifying any opportunities to 

outperform our plan. Any updates will be provided in our re-published plan in October 2023.  

Case study: Durham WINEP - Building a network for the future 

Each  decision  we  make  when  investing  in  our  network  has  one  eye  on  needs  now  and  the  other  on  future 

requirements. In County Durham we've invested £8m to be ready for the future. 

When we invest in our network, we always think about flexibility and resilience for the future. In County Durham, 

we've invested £8 million in 6km of new pipeline and two new pumping stations at Plawsworth and Pity Me. 

The new pipeline has been designed with the accommodation of the transfer of future flows in mind, allowing for 

expected population growth in the area. 

These  projects,  which  are  just  the  first  part  of  a  larger  upgrade  plan  which  will  run  until  2030,  will  streamline 

sewerage treatment processes, add an extra layer of protection to Blackdene Burn, and futureproof the network 

around these sites. 

OUTCOME 7: We always provide a reliable supply of water 

AMBITIOUS GOAL: Have the lowest levels of leakage in the country in our water-stressed 
Essex & Suffolk Water (ESW) operating area 

AMBITIOUS  GOAL:  Have  a  per  capita  consumption  (PCC)  for  water  use  of  118  litres  per 
person per day by 2040 

• Per Capita Consumption (PCC) – common  

• Unplanned outages – common 

• Interruptions to supply between one and three hours – bespoke  

• Interruptions to supply greater than three hours – common  

• Interruptions to supply greater than 12 hours – bespoke  

• Leakage (ESW) – common  

• Leakage (NW) – common  

• Visible leak repair time – bespoke  

• Mains repairs (was bursts) – common  

• Abstraction Incentive Mechanism (AIM) – bespoke 

Per Capita Consumption (PCC) - PR19NES_COM07 

14 July 2023 
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We have not achieved this PC.  

This is a common PC. Our PC requires us to deliver a reduction of 5.6% by 2025 against a baseline of 150.6 l/hd/d 

in 2019/20, on a three-year rolling average basis. The PCC for 2022/23 is 153.8 l/hd/d. This represents a 2.5% 

reduction from 2021/22 and a 7.2% reduction since 2020/21. However, PCC is still 2.1% higher than the target 

base year. The 3-year average PCC, which is 159.1 l/hd/d in 2022/23, is inflated by the two heavily Covid-impacted 

years.  

Reported 

Base Year 

2020/21 

2021/22 

2022/23 

Annual average PCC NWG 

3-year average PCC NWG 

150.6 

165.7 

156.3 

157.8 

157.7 

153.8 

159.1 

There are four core components that impact Per Capita Consumption (PCC); water efficiency interventions, water 

metering  (including  smart  metering),  Government-led  supportive  policy  change  and  external  impacts  such  as 

Covid-19 and extreme weather. There is a clear link between the performance of our metering programme and the 

impact on PCC.  The metering delivery outcome can be found on page 54. 

Impact of Covid-19 on PCC 

In September 2021, we wrote to Ofwat setting out a comprehensive evidence base of the sustained and material 

impact on PCC (7.3% increase in 2020/21). The estimated impact for 2022/23 is 1.6% increase potentially due to 

Covid; hybrid working and sustained behavioural changes account for this increase. These impacts are not unique 

to Northumbrian Water and have been realised nationally.  

Our  comprehensive  annual  report  on  the  Impact  of  Covid-19  on  Demand  summarises  the  outputs  from  data 

analysis, customer research and collaborative industry-wide analysis. The report is available on request by emailing 

demand.planning@eswater.co.uk. We have also worked with the Met Office to produce annual modelling of water 

demand  across  our  regions  which  disaggregates  the  impact  of  Covid-19  on  demand  from  other  variables  that 

influence PCC. Our modelling work with the Met Office is showing that: 

14 July 2023 
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•  PCC for our operating areas overall increased by 5% between April and August 2020. 63% of this was due to 

an increase in base demand from normal, and 37% was due to an increase in weather dependent demand 

from normal. 

•  Between April and September 2021, demand in all three of our operating regions stayed higher than 2019 

(pre-Covid). The weather dependent demand seen from people being at home using water in the garden has 

significantly reduced in this period compared to 2020/21. From this it can be concluded that Covid-19 alone 

impacted total demand and PCC over and above the effects of the weather. The first half of 2021/22 saw the 

continuation of lockdowns and meant we continued to review, adapt, and develop innovative approaches and 

a new water efficiency strategy for the remainder of the 2020-25 period. As we moved into the second half of 

the year (2022) and out of Covid-related restrictions, we were able to initiate various new approaches alongside 

returning to our tried and tested interventions. 

•  Between April and September 2022, both the relationship between weather and demand and the non-weather 

dependent  (base)  demand  in  all  three  of  our  operating  regions  returned  to  pre-Covid  levels.  Weather 

dependent demand contributed significantly to the total usage over the periods of warmer and drier weather, 

with conditions not previously captured in demand data, either before or during the Covid period. 

We have also completed several phases of customer research to understand changes in work location, staycations, 

water use now and in the future. Customers told us working from home has increased and that they were using 

more or much more water. Frequent surveys have allowed us to understand the trends and changes over time. 

The below graph shows the average PCC for 2022/23 is in-line with the last reported pre-Covid dry year PCC of 

2018/19, indicating the impact of Covid has been lower on PCC this year but the dry weather experienced in 2022 

is causing an increase.  

 Figure 1: Average PCC for recent reporting years. Red columns denote 'dry' weather years. 

2022 was the warmest year on record for the UK. Extreme heatwaves in the summer months included temperatures 

more than 40 °C being recorded in the UK for the first time and all four seasons were in the top-ten warmest for 

the  UK  overall.  It  was  also  the  driest  January-August  period  since  1976  and  drought  conditions  were  declared 

14 July 2023 
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across parts of England and Wales. Dry weather is proven to impact household consumption with increased water 

use particularly outdoors. 

Conversely  to  the  impact  of  the  summer  drought,  the  large  rises  in  energy  costs  have  also  impacted  water 

consumption  with  measured  households  reporting  they  reduce  or  are  more  efficient  with  their  showering, 

dishwashing and washing machine habits. We will  continue to carry out research and data analysis annually to 

2025 to make sure we have a robust and clear picture of how the pandemic continues to impact PCC. 

An increase in internal plumbing loss (IPL) also impacts PCC. By increasing this estimate of IPL this increases the 

IPL estimate assigned to properties within our unmeasured small area monitor in NW. The change in IPL adds an 

additional 14.6 l/p/d onto unmeasured household consumption in NW. This has a direct impact on average PCC 

when  considering  57%  of  households  in  NW  are  unmeasured.  In  summary,  the  changes  in  IPL  assumptions 

increased our PCC by 2.6 l/hd/d in 2021/22 and 2.78 l/hd/d in 2022/23.”  

The PCC reporting methodology is broken down into reporting components and then into elements. We can confirm 

that  that  the  reporting  methodology  used  to  provide  these  figures  is  consistent  with  a  ‘green’  (I.e.  compliant) 

assessment against each component. 

Water Efficiency Programme 

In 2022/23, we achieved a saving of 1.29 Ml/d (470.85 Ml/year) because of our water efficiency activity. As set out 

in WRMP19 we aimed to deliver a 1.1% reduction as well as addressing the shortfall accumulated in the last two 

years. We have not achieved our target for 2022/23.  We anticipate we will reach between 30% and 39% of the 

planned activities over the 2020-25 period and that we would have achieved between 44% and 66% without the 

restrictions from Covid. We substantially pivoted our water efficiency strategy  to ensure continued engagement 

with customers and to mitigate the impact of the lockdowns on household consumption. Our action plan is below:  

 2022/23 Plan 

Performance 

4,000  home  water  and  energy  saving 

This programme targets visits at highest users with enhanced focus 

retrofits  each  saving  c.20  litres  per 

on  personalised  behaviour  change  and  longer  term  follow  up.  The 

property per day. 

Water’s  Worth  Saving  programme  is  our  most  complex,  dynamic, 

Exceeded action plan commitment by 

multifaceted  and  ambitious  retrofit  scheme  yet.  This  new  strategy 

25%  on  visits  and  35%  on  water 

allows us to maximise the water savings achieved per visit. We have 

saving.  5,007  delivered  saving  27 

worked  with  academia  through  the  design,  implementation,  and 

litres per property per day.   

delivery of the programme to make sure it was both built and delivered 

using  behaviour  change  and  social  practice  theory  to  ensure 

sustainable behaviour change. 

3,000 leaking toilet repairs each saving 

This significant scaling up (more than double previous years activity) 

a minimum of 215 litres per property per 

of the leaky loo programme was a result of targeted advertising with 

day. 

new  developments,  TV  advertisements  and  enabling  customers  to 

Exceeded action plan commitment by 

video their toilet so we can check if it is leaking in partnership with 

25%  on  total  water  saved.  3,749 

Vyntelligence.  

leaking toilet repairs saving 215 litres 

per property per day.   

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Continue 

to  engage  schools  and 

In-school  delivery  had  to  stop  as  schools  closed  in  2020,  so  we 

stakeholders  to  increase  the  use  of 

quickly  pivoted  our  educational  offering  to  an  online  platform 

online  resources  for  primary  schools 

accessible to teachers, parents and carers of Key Stage 2 children. 

teachers on The Ripple Effect. 

The Ripple Effect is an innovative, interactive website  that explains 

We  engaged  2,285  pupils  in  the  NW 

the  principals  of  the  water  cycle  and  water  use  in  age-appropriate 

region  and  1,868  pupils  in  the  ESW 

language and delivery. We worked in partnership with Waterwise and 

region  through  half-day  workshops. 

Water  UK  to  develop  and  deliver  a  new  national  campaign  called 

Supported  by  working  with  DfE’s 

Water’s Worth Saving producing over 51 million impressions, nearly 

Schools  Water  Strategy 

team 

700,000  link-clicks  and  over  12,000  engagements  (likes,  shares, 

(inviting  schools  to  sign  up  for  a 

comments  and  saves)  exceeding  its  aims.  We  initiated  this 

Ripple Effect workshop).   

programme and led the developmental sprint to form the concept. 

c.15,000  bespoke  water  saving  kits  to 

Bespoke water saving kits were provided to 6,847 homes in the ESW 

homes 

region and 8,241 in the NW region. The total of 15,088 exceeded our 

commitment by 16%. 

c.20,000  online  digital  water  efficiency 

Core  to  this  was  the  implementation  of  an  innovative  online 

engagements 

survey/calculator that customers can use to understand more about 

We 

engaged 

4,191 

customers 

their  water  consumption,  how  it  links  to  energy  consumption  and 

through our website, water calculator 

offers a personalised report detailing key actions they could take and 

and  pledges. 

  Digital 

journey 

the associated benefits. Future development of the Water and Energy 

improvements  identified  in  2022/23, 

Saving Calculator will deliver tailored Water Efficiency digital journeys 

implementation in 2023/24 in order to 

while enhancing our ability to use customer data to benefit a range of 

increase use.  

strategic and performance objectives. 

Pilots  of  innovative  new  water  saving 

NRV2 – whole home flow restrictor continued to be fitted.  

products 

Shower 

timer 

trials  as  part  of  our  highest  user  visits 

(AQOS/Aguardio/Amphiro) 

Two water efficiency related programme 

c.£1m Catalyst bid on Water Literacy – Successful. 

submissions  into  Round  3  of  Ofwat’s 

c.£6m  Transform  bid  on  changing  Showering  behaviour 

Water 

Breakthrough 

Competition 

(PitterPattern) 

Challenge 

Funding  Partners  in  two  other  catalyst  bids:  United  Utilities  Whole 

home flow restrictor upscaling & United Utilities Non-household Large 

Industry Pilots – Unsuccessful 

A  water  efficiency  related  sprint  at  the 

In  the  2022  Innovation  Festival,  water  efficiency  was  integral  to 

2023 Innovation Festival 

sprints  focused  on  digital  gamification,  bill  design  and  customer 

experience. In 2023, we are working with Southern Water on internal 

leakage and with Wave on exploring solutions to business use. 

A 

wide-reaching 

hot 

weather 

The key objective of changing behaviour was achieved, with nearly 

communications  Water’s  Worth  Saving 

one in three enforcing the advice and tips to save water in their home. 

campaign across our regions. 

63%  identified  as  the  top  message  by  the  audience  was  ‘Simple 

changes in your daily routine can help water efficiency’, and 51% took 

WWS away as a strong message. 61% exposed to the campaign took 

(or  will  take)  some  sort  of  action.  Launched  a  targeted  paid  for 

advertising campaign delivering approx. 9m impressions. 

We have also: 

14 July 2023 
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• 

Taken an active and leading involvement in two national water efficiency behaviour change campaigns: 

Water’s  Worth  Saving  and  Pledge23.  We  were  the  key  partner  in  developing  a  new  social  media  led 

campaign called Pledge 2021 with Waterwise. We also sponsored the 2022 Waterwise Conference. The 

conference  is  the  key  event  in  the  water  efficiency  calendar  and  plays  a  crucial  role  in  amplifying  the 

importance of water efficiency as a key demand management measure.  

• 

Integrated water efficiency as a core customer journey in our smart metering programme. Our Smart meter 

installation programme is allowing us to trial various water saving interventions, across different customer 

groups, at different times of the customer journey. Smart meter data will allow us to better understand the 

impact of these interventions and create customer profiles, which will allow us to create tailored offerings 

to get the maximum customer uptake in future. 

• 

Led and Chaired the ‘task and finish’ group focused on building the evidence and case for the co-delivery 

of water and energy efficiency (now aligned to Strategic Objective 7 of the new national Water Efficiency 

Strategy 2030). 

We continue  to  recommend  that  2020-25  PCC  targets  be adjusted  by holding  companies  to  account  for  the  % 

reductions in PCC committed to at PR19 but measured against a baseline adjusted for Covid-19 impacts.  

Unplanned outage - PR19NES_COM13 

We have achieved this PC.  

This is common, penalty-only measure, which is used to assess the health of our assets for our water abstraction 

and  water  treatment  activities.  It  is  designed  to  minimise  the  extent  that  available  water  treatment  capacity  is 

reduced due to unplanned issues or outages, and in turn make sure water companies appropriately maintain and 

improve the asset health of their non-infrastructure or above-ground water assets for the benefit of current and 

future generations and demonstrate their commitment to asset stewardship responsibilities.  

Ofwat set us the very ambitious target of having only 2.34% of unplanned outages by the end of 2025, with a glide 

path to demonstrate us getting there year on year.  

14 July 2023 
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Every day our workers discuss how best to look after the treatment of water and the control of its distribution around 

our network, they look to minimise the time of any unplanned, or planned treatment issue and over the last year 

we’ve been tested by the weather. 

We have once again improved performance reporting 3.51 % across the company beating our 2022/23 target of 

4.36%. 

We  continue  to  inform  Ofwat  of  any  unplanned  or  planned  situations  when  we’re  unable  to  meet  Peak  Week 

Production Capacity (PWPC) because of any asset failures or the inability to treat water to required standards. In 

addition,  we  continue  to  improve  our  processes  and  simplify  the  data  entry  process  for  operations.  Internal 

engagement through regular meetings and outage reviews means our people have a clear awareness of the need 

to accurately record outages. Our internal and external audit teams ensure the number we provide is as rigorous 

as it can be. 

Our  improvement  plans  remain  centred  on  proactive  maintenance  regimes,  continued  operator  asset  care  and 

delivery of future investment to our water treatment assets. 

The unplanned outage reporting methodology is broken down into reporting components and then into elements. 

We can confirm that that the reporting methodology used to provide these figures is consistent with a ‘green’ (I.e. 

compliant) assessment against each component. 

Interruptions to supply between one and three hours - PR19NES_BES14 

We have not achieved this PC.  

This is one of our two bespoke supply interruption measures for 2021-25. We used three years of data from 2018/19 

through to 2020/21 to establish a ‘baseline’ level of performance from which we can measure our performance as 

a percentage change. 

For this measure, all interruptions between one hour and two hours 59 minutes are added up to give the total time 

that  customer  supplies  were  lost  across  our  supply  area.  We  then  divide  this  total  time  by  the  total  number  of 

connected properties we serve. This gives an average time in minutes and seconds that we have interrupted each 

customer  for  between  one  and  three  hours.  The  Baseline  average  of  the  last  three  years  is  08:17mm:ss.  This 

performance will result in a penalty of £-2.7m. 

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An interruption to the water supply can either occur on a planned basis when we carry out network maintenance, 

or  unexpectedly  when  a  burst,  third  party  damage  or  other  failures  occur  in  the  network.  We  recognise  that 

interruptions to the water supply can cause our customers real inconvenience - especially when they’re unexpected 

and we cannot warn customers in advance.  

Our overall performance has been impacted by the uplift in repair activity caused by the dry soil conditions during 

the summer heatwave, where temperatures hit 40 degrees in our Essex region. As well as the freeze-thaw event, 

which occurred in both of our operating areas during December 2022. During this time temperatures dropped to a 

low of -7 degrees Celsius recorded on 13 and 16 December to a high of 13 degrees on 19 December. The number 

of repair jobs that were created doubled from what we forecasted. 

This required careful management of our network to make sure we were able to meet demand across our operating 

areas and made rezoning our network to provide an alternative supply more difficult.  

We have recently completed a company-wide project to holistically review how we provide water to our customers. 

These zonal studies have helped us identify how we can become more resilient, and where we need to become 

more operationally focused until investments in our assets are delivered on the ground. 

Water supply interruptions greater than or equal to three hours - PR19NES_COM04 

We have not achieved this PC.  

This  is  a  common  measure  designed  to  incentivise  companies  to  minimise  the  number  and  duration  of  supply 

interruptions.  

An  interruption  to  the  water  supply  can  occur  on  a  planned  basis  when  we  carry  out  network  maintenance  or 

unexpectedly  when a  burst  or  other  failure  occurs  in  the  network.  We  recognise  that interruptions  to  the  water 

supply can cause our customers real inconvenience - especially when they are unexpected, and we cannot warn 

customers in advance.  

14 July 2023 
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For this measure, all interruptions of three hours or longer are added up to give a total time that customer supplies 

were lost across our supply area. We then divide this total time by the number of properties we serve. This gives 

an average number of minutes and seconds we have interrupted each customer for three hours or longer. 

We put our customers at the centre of our response to a supply interruption and have been one of the industry 

leaders  over  several  years.  Our  focus  is  to  restore  our  customers  supplies  before  undertaking  any  permanent 

repair, while always taking a balanced approach to other considerations such as environmental protection and the 

health and safety of our team and the public. 

We restore supplies by rezoning our network or deploying temporary equipment, and we are pleased to report that 

we have fully rolled out the mobile storage units (MOWBIs) in Essex. These units can provide a temporary supply 

to an individual property, and we are very proud that our teams have been taken this innovation from the conceptual 

stage through to the point of delivery. Looking ahead we are planning on deploying MOWBIs across our whole 

business and scaling the concept to be able to supply multiple properties. 

Supply  interruptions  remain  a  key  area  of  focus  for  us,  and  underlying  performance  has  been  stable  when 

compared to 2021/22. Our performance of 8 minutes 16 seconds is due to the uplift in repair activity caused by the 

dry soil conditions during the summer heatwave, where temperatures hit 40 degrees in our Essex region. Moreover, 

supply  interruptions  were  also  caused  by  the  freeze-thaw  event  which  occurred  in  both  of  our  operating  areas 

during  December  2022  when  temperatures  dropped  to  a  low  of  -7  degrees  Celsius  recorded  on  13  and  16 

December to a high of 13 degrees on 19 December. Our response was to recruit additional resources to help find 

and fix leaks. 

We are disappointed that one of our largest events was caused by a third party who damaged three of our mains 

while  working  in  Middlesborough.  It  is  incidents  such  as  these  which  drive  our  passion  to  see  the  National 

Underground Asset Register (NUAR) deployed across the UK. Developed at our 2017 Innovation Festival, it sees 

existing  data  on  underground  pipes  and  cables  brought  together  in  one  single,  digital  map  to  display  where 

electricity and phone cables, and water and gas pipes are buried.  

NUAR has been live in our North East operational area since April 2023. Once fully operational across England, 

Wales  and  Northern  Ireland,  NUAR  will  help  improve  efficiencies  in  construction  and  development,  reduce 

disruption to the public and businesses (from extended road closures and congestion), improve workers’ safety 

and is envisaged to deliver at least £350 million economic growth per year. 

Our plans to improve performance are below.  

ACTION  

DESCRIPTION  

Improve pressure 

We are working hard to find new ways to manage water pressure and 

management  

investing in new schemes to help with pressure management. We have 

deployed  temporary  pressure  loggers  at  specific  locations  to  collect 

extra  data  at  critical  sites.  We  have  identified  some  opportunities  to 

adjust our pressure reducing valves and are investigating these further 

before taking action. 

TARGET 

END 

DATE  

End 

March 

2024  

14 July 2023 
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Reviews after 

We will continue to carry out reviews and learn from the events we 

In use 

incidents  

have had to see where a change in processes could prevent similar 

occurrences. 

Network support units   We  have  invested  in  new  equipment  to  help  maintain  water  supply 

In use 

during unexpected events. 

Internal 

Our focused approach to training means that all teams involved know 

In use 

communications – 

how to keep water supply interruptions as short as possible. 

every minute counts  

Innovation  

This year we have developed a MOWBI, a mobile storage until that can 

In use  

be transported to single properties experiencing a loss of water which 

temporarily restores water to the property (at a sufficient pressure), until 

a more permanent resolution can be put in place. These are particularly 

useful in events where we find a more complicated repair or there is a 

health  and  safety  reason.  We  predict  this  will mean  some customers 

experience  a  shorter  interruption  in  the  future,  even  while  the 

permanent solution is still ongoing. 

Longer  term  our  performance  against  this  metric  remains  susceptible  to  external  factors  in  particular  weather 

events such as storms or flooding which are expected to increase in frequency due to climate change and which 

can disrupt the operation of our assets, particularly if they affect power supplies. Our PR24 Business Plan will set 

out  robust  proposals  to  address  this,  however  delivery  of  these  proposals  will  be  dependent  on  provision  of 

associated funding.  

Interruptions to supply greater than 12 hours - PR19NES_BES09 

We have achieved this PC.  

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This is our second bespoke supply interruptions measure for 2020-25 where we report the number of properties 

which are affected by a water supply interruption for 12 hours or longer. This is a very stretching target to meet 

over the next few years as it could only take one large event that could result in losing the ability to achieve our 

performance commitment for this measure.  

We are delighted to report that we have been able to keep supply interruptions greater than 12 hours to an absolute 

minimum while operating in very challenging conditions during the summer and winter. We have had 23 weeks of 

the reporting year where we had zero properties interrupted for more than 12 hours. We investigate where any 

property is interrupted for more than 12 hours and remain well placed to address the root cause of the interruption. 

We have fully rolled out the mobile storage units (MOWBIs) in Essex. These units can provide a temporary supply 

to an individual property, and we are very proud that our teams have been taken this innovation from the conceptual 

stage through to the point of delivery. We view these to eliminating supply interruptions for 12 hours or more as we 

deploy these more across our business. This is because most supply interruptions > 12 hours occur occurred on 

single properties. 

We did have some events where there was a high risk of properties experiencing a long interruption. During the 

freeze-thaw event where temperatures rapidly changed from a low of -7 degrees to a high of 13 degrees, we had 

18,723 properties experience an interruption of at least one hour. However, our focused response meant that only 

two customers went on to experience an interruption greater than 12 hours. 

Looking ahead we are planning on deploying MOWBIs across our whole business and scaling them to be able to 

supply multiple properties. 

Leakage Northumbrian Water (NW) - PR19NES_COM05 

We have not achieved this PC for 2022/23 but have delivered a year-on-year reduction in annual leakage. 

14 July 2023 
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This  is  a  common  measure  based  on  a  revised  industry-wide  reporting  methodology  for  2020-25  that  helps 

companies  calculate  leakage  more  consistently.  Leakage  from  the  water  network  is  measured  in  Megalitres 

(millions of litres) lost per day. Leakage levels fluctuate throughout the year as the weather changes, and we report 

the average daily level at the end of the year. Our PC is based on a percentage reduction of three-year average 

leakage against a 2019/20 baseline.  

We have reduced leakage from 130.5Ml/d in 2021/22 to 118.8Ml/d in 2022/23 (an 8% year on year improvement) 

which  gives  a  3-year  average  of  129.8Ml/d  against  a  PC  equivalent  of  126.7Ml/d  which  in  turn  equates  to  a 

reduction of 3.7% against a PC of 6%.    

During the year we achieved some of the lowest levels of leakage ever recorded in the North East and headed into 

the summer months in a strong position. The first four months of the reporting year saw leakage remain under the 

performance commitment target profile. The hot and dry summer with record breaking hot temperatures in mid-

July started to create significant numbers of burst mains and other asset failures which created a very challenging 

operational environment. Just before Christmas we entered a period of freeze and thaw. This freeze-thaw event 

saw leakage increase rapidly. In comparison to our expected daily leakage in December, we saw a 72% rise in our 

North East operating area.   

During these peak times, we have responded quickly to the sources of leakage by bringing in additional operational 

resources to fix leaks. We have also increased the number of people that were looking for leaks to enhance our 

detected leaks to support recovery of our position.  

Increasing  our  operational  resources  is  just  one  of  the  ways  we  are  tackling  leakage.  During  the  year  we 

implemented  several  new  and  exciting  technologies  and  techniques  to  help  us  achieve  our  leakage  goals.  We 

collaborated with industry experts to develop Digital Twins for four of our District Metered Areas, which gave us a 

new digital tool to identify leaks on our network. We have implemented new AI sensor technology that makes our 

leakage detection surveys more efficient. We use our annual Innovation Festival to explore new concepts, such as 

"no-dig" repair techniques, and emerging sources of data that can enrich the insights we have now. Finally, we are 

leading on industry collaboration, as we develop the new National Leakage Research and Test Centre. This will 

be  a  5km  buried  water  pipe  network  purpose  built  for  developing  and  testing  leakage  interventions  without 

disrupting customers’ supplies or affecting water quality. We continue to evaluate and optimise how we use Smart 

Meter data, as we build on the penetration of meters already deployed.  

Despite all the above improvement, we recognise that we remain off track against our performance commitment 

and are implementing solutions to deliver a step change in performance. We are continuing to fund innovations 

and trials of emerging technologies, alongside identifying what we need to take forward in terms of the level of 

resources we deploy across the year.  

Our final leakage position for the year is confirmed by an annual review of our water balance, this reconciles the 

total volume of water input into our supply network at our treatment works with the water that is consumed by our 

metered and non-metered customers, along with the water used for various other purposes, and the volume lost 

due to leakage. We are continually improving the quality off all datasets to ensure we present the most accurate 

picture of use and leakage across our network and these elements all change annually.  

14 July 2023 
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As part of our ongoing commitment to improvement, we have conducted recent work with a third party, Invenio, to 

support our endeavours and it has provided independent review of each of these datasets, contributing valuable 

insights to our assessment.  

Notably, we focused on enhancing the accuracy of household plumbing loss data through the integration of data 

obtained from our smart metering program and supplementary surveys, and we anticipate further advancements 

as we continue to install more smart meters. Our findings potentially align with some initial emerging evidence that 

may point to increasing trends in plumbing losses, potentially influenced by the components used in modern dual 

flush toilets. This would be consistent with the noticeable increase in demand for our free service, which aids in the 

repair of leaky loos. 

This  improvement  in  measurement  and  understanding  of  this  component  has  contributed  6.9Ml/d  of  the 

improvement in annual leakage for 2022/23. 

The  way  datasets  are  combined  to  calculate  final  leakage  numbers  is  described  in  the  reporting  methodology, 

which ensures that performance across the industry, as well as baseline and in-year performance, are calculated 

consistently. 

We aim to achieve full compliance with this methodology, which is made up of several components of the leakage 

calculations. We continue to have a ‘green’ status against  Ofwat’s reporting requirements for most components 

including the ‘Household Night Use Component’ which includes the plumbing losses data. 

We have one red area for 2022/23 which relates to the size of the water balance gap of 3.9%. The improvements 

to plumbing losses does not have a material impact on the water balance gap contributing 0.06%.   

We do not consider that this has a material impact on the accuracy of our reported leakage because: 

1. 

The water balance gap has been allocated to the various water balance components – including leakage 

- using the best practice MLE methodology, which allocates the unaccounted for water across the water balance 

components according to their relative accuracy, that is components considered to be less accurate (with a worse 

‘confidence grade’) are given a higher allocation.  

2. 

Sensitivity analysis shows that reported leakage is not especially sensitive to the confidence grade used 

for the leakage component, that is if the confidence grade for the leakage component is artificially worsened it does 

not have a material impact on reported leakage. 

Our  external  technical  auditors,  PwC,  performed  independent  assurance  procedures  in  relation  to  leakage 

performance  information.  PwC’s  independent  assurance  report,  including  the  scope  of  their  work  and  the 

assurance opinion, can be found here. 

The key actions we are taking to further improve performance are set out below: 

14 July 2023 
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ACTION  

DESCRIPTION  

TARGET 

DATE  

Minimise leak repair 

We have recruited extra ‘find and fix’ technicians to help minimise leak 

Ongoing  

times  

repair times in the future.  

Improve pressure 

We’re  also  working  to  identify  new  ways  to  manage  water  pressure 

End March 

management  

using special valves. 

2024 

Allocation of leak 

We’re improving the way we allocate resources to larger rural areas. 

End March 

detection resources  

2024 

Better understand link 

We’re  now  carrying  out  studies  to  better  understand  customer 

End March 

between consumption 

consumption. A big part of calculating leakage is understanding how 

2024 

and leakage  

much  water  our  customers  use  at  night.  The  more  accurate  our 

estimates are then the more confidence we have in what is leakage on 

our  network,  which  we  need  to  find  and  repair,  and  what  is  actually 

being used by customers. 

Improve logging of 

A project is underway to add extra data loggers to business customers’ 

End March 

non-household 

meters  to  help  us  improve  accuracy  when  tracking  and  measuring 

2024 

customers  

consumption and leaks for businesses.  

Improve monitoring of 

Trunk mains are our large water pipes that deliver high volumes of 

2025-30 

trunk mains  

water, and we are investing money to improve the way we monitor 

these for leakage. 

Innovation to improve 

We already use innovative and clever ways to track leakage, such as 

Ongoing 

efficiency  

surveying  8,000km  of  pipes  by  satellite.  We’ve  been  trailing  small 

listening devices, more sensitive than the human ear, at points around 

the water network, where we can monitor the noise levels on the pipes 

to help find tiny leaks that we wouldn’t be able to spot otherwise. We’re 

even creating ‘digital twins’ – virtual models of our water pipe network 

that  allow  us  to  run  simulations,  study  problems  and  generate  new 

solutions.  

No dig technology  

We’re trialling a gel and mineral-based solution that allows leaking 

Ongoing 

pipes to ‘self-heal’ without the need for excavation (digging).  

CASE STUDY: Dealing with a freeze-thaw event 

In mid-December 2022, temperatures varied massively across the course of just a few days. Lows of  -7℃ were 

recorded in Newcastle on 16th December and Southend on 17th December, thawing rapidly to a high of 13℃ in 

Newcastle and 14℃ in Southend on 19th December. 

As a result, we saw a 70% rise in our expected daily leakage in the North East and a 133% increase in our Essex 

and Suffolk operating area. 

14 July 2023 
PAGE 76 OF 211 

 
 
 
 
 
The number of repair jobs doubled from what we’d expect to see in a normal December, and unfortunately, this 

meant interruption of supply to 18,723 homes. 

Knowing this freeze-thaw event was coming  - and learning lessons from previous events  - we had our incident 

team established early. 

This allowed us to take clear decisions as the situation unfolded, including checking vacant commercial properties 

for leaks, tankering water around our operating areas, and moving pallets of bottled water into strategic locations. 

This included 152 pallets into Northumberland, where the area surrounding Ashington was severely impacted by 

an asset failure at one of our treatment works. 

We  set  up  a  bottled  water  station  at  Ashington  Leisure  Centre  for  three  days  while  customers  experienced 

interruptions to supply, and deliveries of bottled water to more than 400 customers on our Priority Services Register. 

Throughout the incident, we kept customers informed  - sending more than 800,000 emails, nearly 150,000 text 

messages, and posting information and responding directly to queries on social media. 

We also worked closely with stakeholders in our operating areas - including MPs, local authorities and business 

representatives,  housing  providers  and  voluntary  sector  groups  to  make  sure  they  had  all  the  information  and 

advice to share with their contacts. 

Our rapid response meant we received just eight written complaints relating to the freeze-thaw event. 

Leakage Essex & Suffolk Water (ESW) - PR19NES_COM06 

We have achieved this PC for 2022/23. 

This  is  a  common  measure  based  on  a  revised  industry-wide  reporting  methodology  for  2020-25  that  helps 

companies  calculate  leakage  more  consistently.  Leakage  from  the  water  network  is  measured  in  Megalitres 

14 July 2023 
PAGE 77 OF 211 

 
 
 
 
 
 
 
 
 
  
(millions of litres) lost per day. Leakage levels fluctuate throughout the year as the weather changes, and we report 

the average daily level at the end of the year. Our PC is based on a percentage reduction of three-year average 

leakage against a 2019/20 baseline.  

We have reduced leakage from 59.3Ml/d in 2021/22 to 55.6Ml/d in 2022/23 (a 5% year on year improvement) which 

gives a 3-year average of 60.3Ml/d against a PC of 60.5Ml/d which in turn equates to a reduction of 7.5% against 

a PC of 7.2% - achieving the PC. 

During the year we achieved some of the lowest levels of leakage ever recorded in Essex and Suffolk. By July we 

had driven down the visible leak repair time in Essex and Suffolk to an average of 4.3 days in comparison to 7.9 

days during the corresponding period in 2022, achieved in part through increasing our operational resources.  

Increasing  our  operational  resources  is  just  one  of  the  ways  we  have  tackled  leakage.  During  the  year  we 

implemented  several  new  and  exciting  technologies  and  techniques  to  help  us  achieve  our  leakage  goals.  We 

collaborated with industry experts to develop Digital Twins for four of our District Metered Areas, which gave us a 

new digital tool to identify leaks on our network. We have implemented new AI sensor technology that makes our 

leakage detection surveys more efficient. We use our annual Innovation Festival to explore new concepts, such as 

"no-dig" repair techniques, and emerging sources of data that can enrich the insights we have now. Finally, we are 

leading on industry collaboration, as we develop the new National Leakage  Research and Test Centre. This will 

be  a  5km  buried  water  pipe  network  purpose  built  for  developing  and  testing  leakage  interventions  without 

disrupting customers’ supplies or affecting water quality. We continue to evaluate and optimise how we use Smart 

Meter data, as we build on the penetration of meters already deployed.  

These  improvements  have been  offset  by an  increase  in  water  mains bursts  caused  by  the  dry  soil conditions 

during the 2022 summer heatwave, where temperatures hit more than 400C in our Essex region. We repaired more 

than 1,000 additional visible leaks than we did in the summer of 2021, and overall, the number of repairs that were 

required  during  the  summer  was  double  that  of  an  average  year.  We  saw  leakage  increased  to  133%  of  our 

forecasted daily level during the freeze/thaw event which occurred in December. We were able to recover quickly 

from this winter peak as we had planned and prepared for this event and could quickly deploy additional resources. 

Our final leakage position for the year is confirmed by an annual review of our water balance, this reconciles the 

total volume of water input into our supply network at our treatment works with the water that is consumed by our 

metered and non-metered customers, along with the water used for various other purposes, and the volume lost 

due to leakage. We are continually improving the quality off all datasets to make sure we present the most accurate 

picture of use and leakage across our network. These elements all change annually.  

As part of our ongoing commitment to improvement, we have conducted recent work with a third party, Invenio, to 

support our endeavours and it has provided independent review of each of these datasets, contributing valuable 

insights to our assessment.  

Notably, we focused on enhancing the accuracy of household plumbing loss data through the integration of data 

obtained from our smart metering program and supplementary surveys, and we anticipate further advancements 

as we continue to install more smart meters. Our findings potentially align with some initial emerging evidence that 

may point to increasing trends in plumbing losses, potentially influenced by the components used in modern dual 

14 July 2023 
PAGE 78 OF 211 

 
 
 
 
  
  
  
  
  
  
  
flush toilets. This would be consistent with the noticeable increase in demand for our free service, which aids in the 

repair of leaky loos. 

This  improvement  in  measurement  and  understanding  of  this  component  has  contributed  2.9Ml/d  of  the 

improvement in annual leakage in ESW for 2022/23. 

The  way  datasets  are  combined  to  calculate  final  leakage  numbers  is  described  in  the  reporting  methodology, 

which ensures that performance across the industry, as well as baseline and in-year performance, are calculated 

consistently. 

We aim to achieve full compliance with this methodology, which is made up of several components of the leakage 

calculations. We continue to have a ‘green’ status against Ofwat’s reporting requirements for most components 

including the ‘Household Night Use Component’ which includes the plumbing losses data. 

We  have  one  amber  area  for  2022/23  which  relates  to  the  size  of  the  water  balance  gap  of  2.5%.  We  have 

conducted materiality analysis that we used in 2020/21 to demonstrate that this does not have a material impact 

on the accuracy of our reported leakage.  

While reflecting on our performance, and despite achieving our target, we have decided that we will not claim an 

ODI reward for ESW leakage for 22/23, considering that we have only marginally beaten our target, and that further 

improvements  are  required  over  time  to  the  dataset  relating  to  household  plumbing  losses.  Taking  a  broader 

perspective across both regions, we recognise that there is further room for improvement, and we remain steadfast 

in our commitment to advancing towards our 2025 goals before considering any justifiable claim for rewards.  

In comparative terms, Essex & Suffolk continues to have some of the lowest leakage levels in the country. This 

means that remaining leaks become smaller, harder to find, and more expensive to fix per unit of water saved. 

Improvements in the longer term from an already low base will hence become increasingly dependent on the extent 

to which additional funding can be dedicated to address leakage. 

Case  study:  Water  resilience  innovations  -  a  flexible  approach  to  alternative  water 

supplies 

When supplies are interrupted, we prioritise our customers who are most vulnerable. Through our Priority Services 

Register we know which customers might need extra support or perhaps have health problems which make coping 

with interruptions to their supply particularly difficult. 

Traditionally, we put a temporary supply in place by running hoses and pipes around, often needing to use pumps 

and generators. 

As part of our Innovation Festival, we developed a mobile pumped water storage unit to change that. 

The plan was to design a unit which could be delivered to the location of the interruption of supply and quickly 

connected to provide water for essentials like cooking and flushing the loo. 

14 July 2023 
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We built an initial prototype - a converted wheelie bin - which proved the concept and, working with our partners 

Furst Technologies, we’ve developed the idea into a version that can be used reliably on site. 

Not only can MOWBIs be used individually, but they can be chained together to support greater water needs - for 

example,  when  faced  with  a  burst  pipe  locally,  we  were  able  to  provide  an  emergency  supply  to  a  nursery  in 

Chelmsford using a set of MOWBIs which kept 80 children plus staff on site until the end of the day. 

We’re  now  developing  a  TOWBI,  a  larger  version of  the MOWBI,  to support commercial  properties  like vets  or 

hairdressers where a stable water connection is a necessity. 

Daniel Fletcher, Technical Supervisor, said: “It’s about lots of small wins adding up. If we can ease the disruption 

for individual households or individual businesses, it quite quickly starts to have a big impact across our operating 

areas. We know we’re ahead of the industry with this innovation, and I know our partners at Furst are looking at 

how to support other water companies to follow suit.” 

MOWBI is an innovation which started intending to solve a problem but is already outgrowing that - there’s now a 

team of specialists building around it and the deployment of MOWBIs has become something that is built into our 

business-as-usual process for planned works. 

It’s a practical solution, helping us provide a more reliable supply to the customers across our operating areas. 

Visible leak repair time (days) - PR19NES_BES04 

We have not achieved this PC. 

This is a bespoke PC to incentivise us to reduce the time it takes to repair customer-reported visible leaks. This 

will reduce the amount of water wasted through leaks, something our customers tell us is very important to them. 

We recognise that particularly during times when we are asking customers to be mindful of their own personal 

consumption, they want to know that we are working hard to minimise leaks and it’s not acceptable to fall short of 

our targets. 

14 July 2023 
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From April through to June, we had a similar run rate of visible leaks in comparison to the same time in 2021 - but 

we were repairing them 40% quicker in just over four days.  

We had our best monthly performance in July where we took 3.8 days on average to repair a visible leak across 

all  our  operational  areas.  Despite  operating  in  record  high  temperatures  that  continued  through  to  September. 

During these summer months the number of visible leaks increased significantly as the network responded to the 

dry soil conditions, particularly in the Essex region. We repaired more than 1,000 visible leaks than we did in the 

summer of 2021.  

Collectively, the average number of visible leak repairs completed per month in 2022/23 is close to 900, which is a 

20% uplift in comparison to previous years. 

We acted by recruiting additional resources to help find and fix leaks. This brought the average repair time back 

down, but the freeze/thaw event of early December was challenging and further impacted our average repair time. 

This year has been like no other we have faced as we have measured ourselves against visible leak repair time.  

Our year end average is 7.1 days. Our visible leaks target for the next two years is 4.0 days. We look ahead with 

confidence knowing we have achieved this performance previously, but that our challenge is to do so consistently. 

We  are  looking  at  working  patterns,  forecasting,  and  innovations  such  as  ‘No  Dig’  technology  to  improve  our 

performance. 

Mains repairs (bursts) - PR19NES_COM12 

We have not achieved this PC and are very disappointed with this result as this is usually an area where we perform 

well.  

This is a common PC and is measured per 1,000km of the entire water main network conveying treated water 

around  the  distribution  point  (excluding  communication  and  supply  pipes).  Proactive  (found  because  of  active 

leakage control/detection by the company) and reactive (customer reported) repairs are reported separately. 

We measure the number of mains bursts by counting the repairs we make to water mains each year. This year we 

repaired 154.9 mains bursts per 1,000km, which is below our PC of 132.4 and results in a -£1.863m penalty.  

14 July 2023 
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Our  performance  for  mains  bursts has  been  impacted  by  the  dry  soil conditions  during  the  summer heatwave, 

where temperatures exceed 40 °C for the first time ever in the UK. As well as the freeze-thaw event, which occurred 

in both of our operating areas during December 2022. During this time temperatures dropped to a low of -7 degrees 
Celsius recorded on 13 and 16 December to a high of 13 degrees on 19 December.  While we are not able to fully 

weatherproof our network, we can make sure our response to these events is our top priority. We did have some 

freeze-thaw events where there was a high risk of properties experiencing a long interruption and one such event 

saw 18,723 properties experience an interruption of at least one hour. However, our focused response meant that 

only two customers went on to experience a supply interruption greater than 12 hours. 

It is the significant uplift in mains bursts during the winter and summer months that have markedly impacted our 

overall performance. For example, we had close to double our forecasted mains bursts in August compared to our 

recent performance based on a three-year average. Our underlying burst rate continued to be in line with previous 

years outside of July through to September and December and January this year.  

Looking ahead we continue to refine our modelling capability for identifying areas at a higher risk of bursts. We will 

feed these into our analysis as we prioritise areas for investment. We continue with staff training calm network 

operations, and investing technology, which can help us identify activity on the network that can cause a mains 

burst. 

We continue to focus efforts on ways in which we can mitigate the impact of demanding weather scenarios on our 

performance. Outside of July, August, December and January our run rate for bursts has been in line with previous 

years indicating a strong underlying performance consistent with our performance commitment. 

Finally, as one of four asset health metrics, longer term performance is strongly linked to the delivery of appropriate 

levels of capital maintenance. Our PR24 Business Plan will set out our proposals in more detail, however delivery 

of this plan will in turn be dependent on.the provision of appropriate levels of funding for capital/asset maintenance 

activities. We do not consider that the current regulatory approach to setting funding allowances is sustainable in 

the longer term, a topic we will elaborate on further in our Business Plan.   

Abstraction Incentive Mechanism (AIM) - PR19NES_BES18 

We have achieved this PC.  

The Abstraction Incentive Mechanism (AIM) is is a common, financially incentivised measure designed to protect 

the  ecology  of  raw  water  sources  by  limiting  the  extent  to  which  we  can  abstract  water  from  them  during  dry 

conditions. 

For NWL the AIM only applies to one location at Ormesby Broad, Norfolk. This year’s summer (May to September 

2022 inclusive) rainfall was around the long-term average, however, we managed broad water levels to remain 

well above the level at which AIM would be triggered. 

We report full details to the EA in our WRMP Annual Review which we submit on 30 June.  

14 July 2023 
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OUTCOME 8: Our drinking water is clean, clear and tastes good  

AMBITIOUS GOAL: Promote confidence in our drinking water so that nine out of ten of our 
customers choose tap water over bottled water. 

• Water quality compliance (CRI) – common  

• Event Risk Index (ERI) – bespoke 

• Discoloured water contacts – bespoke  

• Satisfaction with taste and odour of tap water – bespoke 

Water quality Compliance Risk Index (CRI) - PR19NES_COM03 

We have not achieved this PC.  

CRI is a common, penalty-only, calendar year PC using a risk-based monitoring methodology, which assesses 

water quality compliance against our statutory obligations.  

Our  CRI  was  7.62  (to  2  decimal  places)  against  a  PC  level  of  0,  incurring  a  penalty  of  £8.531M.  This  is  a 

deterioration  in  performance  from  our  overall  score  in  2021.  For  2022  most  of  our  CRI  score  is  derived  from 

compliance failures in our North East operational area while in 2021 it was primarily the Essex and Suffolk area.  

When a failure occurs at an asset or in a supply area  that is subject to an agreed programme of work with the 

Drinking Water Inspectorate (DWI), the DWI’s compliance assessment will increase the associated CRI score. In 

2022, this effect increased the CRI total by 2.27 units.  

The biggest impact on CRI for 2022 was a bacteriological failure from a water treatment works in the Teesside 

area, which accounted for 1.431 units. This represents more than 15% of the final figure. No definitive cause could 

be identified however, the condition of the superstructure which houses the filter gallery, contact tanks and flash 

mixer is known to be in very poor condition. Some parts of the asset cannot be accessed to carry out inspection. 

The contact tanks are due to be inspected in April 2023 which should provide some greater understanding of the 

condition of those assets.  

14 July 2023 
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A sampling campaign at the time of the failure demonstrated that the result was confined to the treatment works 

and had no impact on customer supplies or public health.  

72% of the sample failures recorded in 2022 were at customers’ taps at the point of use. Over half of these results 

were because of internal plumbing or the property supply pipe and therefore did not attract any CRI points. In these 

circumstances, we work closely with the customer to understand the issue and determine a root cause. Support 

for  the  customer  can  take  several  forms,  including  the  issue  of  precautionary  advice  and  bottled  water  while 

investigations continue, education and awareness on tap hygiene and cross contamination in the home,  and the 

replacement of lead communication pipes supplying a property where the risk is shown to be elevated. Our aim is 

to make sure customers retain a high level of trust in the tap water we provide. 

There have been fifteen service reservoir (SR) failures in 2022. These were all in the North East region apart from 

one failure in Essex and Suffolk. This is a deterioration in performance compared to 2021. In the last 12 months, 

we have completed the full replacement of a treatment site in Wooler, which will provide more reliable supplies and 

meet future drinking water standards. Following on from this is the new treatment works at Horsley which (alongside 

the  existing  site) supplies  a  large  proportion  of  Tyneside.  This  new  works  is  partially  in  supply,  and  we  expect 

completion in 2024.  

The  replacement  of  three  sites  in  Northumberland  was  completed  in  2022  along  with  the  completion  of  the 

installation of UV treatment at two works supplying the Durham and Wearside areas.  We are continuing with the 

enhanced programme of treated water storage tank inspections to mitigate some of the risks identified at these 

sites, alongside a risk review of treatment processes.  

We’re disappointed to not hit our high standards in this area as we are committed to achieving industry-leading 

levels of CRI and are delivering our long-term plans to reach this, as well as working closely with the DWI. We’ve 

accelerated and increased funding in our base capital programme as part of a transformation plan with the DWI.   

We are continuing to prioritise our efforts around water treatment where CRI risk is highest, and areas of focus 

include filter media refurbishment, carbon regeneration, and water quality minor works activities such as on-line 

monitoring capability to increase resilience and control of the treatment processes.   

The journey of water from treatment through to customer tap is important, and in our networks, we are continuing 

with the enhanced service reservoir maintenance programme, inspecting and (where applicable) repairing a higher 

number of tanks per annum to maintain the integrity of these assets and minimise any water quality risks. We are 

using a combination of physical assessment and technologies such as Remote Operating Vehicles (ROVs).   

We are continuing with smart network innovation to allow real time operational decisions to be made on the quality 

of water being supplied through our networks and so improve the customer experience.  

Finally, as one of four asset health metrics, longer term performance is strongly linked to the delivery of appropriate 

levels of capital maintenance. Our PR24 Business Plan will set out our proposals in more detail, however delivery 

of this plan will in turn be dependent on.the provision of appropriate levels of funding for capital/asset maintenance 

activities. We do not consider that the current regulatory approach to setting funding allowances is sustainable in 

the longer term, a topic we will elaborate on further in our Business Plan.   

14 July 2023 
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ACTION  

DESCRIPTION  

TARGET 

DATE  

Five-year water 

Five treatment sites in Northumberland were replaced in 2022 along 

End March 

quality plan  

with UV treatment being installed at two water treatment works 

2025  

(WTWs) supplying the Durham and Wearside areas. An extensive 

programme of inspections and work at treated water storage tanks is 

preventing some of the risks identified at these sites, alongside a 

thorough risk and hazard review (HazRev) of all treatment processes 

to improve condition, capability and resilience. As we prioritise our 

efforts around water treatment our areas of focus include filtration, 

carbon regeneration, and water quality activities such as on-line 

monitoring to control the treatment processes. We are also trialling an 

innovative smart network in the Tees area of supply, which we believe 

will be the largest implementation of a water quality sensor network in 

Europe.  Monitors are being installed at both service reservoirs and 

District Metered Areas to help create insight in how the network 

influences water quality and the CRI measure, and to signpost positive 

interventions around operational management, asset maintenance and 

cost efficiency, all with the aim of improving the customer experience. 

We will continue to work with customers on tap hygiene and cross 

contamination in the home, and the replacement of lead pipes where 

necessary. 

Improve Layer Water 

We are investing in new treatment equipment at these sites to respond 

March 

Treatment Works 

to changes in the quality of the raw water (from rivers and reservoirs) 

2025  

and Mosswood Water 

Treatment Works  

that these sites have to treat. 

March 

2024  

Case study – Project Pipeline - Future-proofing supply in Co Durham and the Tees 
Valley 

More than 200,000 customers across the south of County Durham and into the Tees Valley are benefiting from a 

£155m investment to upgrade and futureproof our water supply network across the area. The programme - ‘Project 

Pipeline:  County  Durham  and  Tees  Valley’  -  will see  both new  pipeline and the replacement  of sections of  the 

network that have served the area for more than 100 years. 

The beginning of 2023 saw the start of a £155m, multi-year project to upgrade and futureproof the water supply 

network in south County Durham and the Tees Valley. 

14 July 2023 
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The programme, called ‘Project Pipeline: County Durham and Tees Valley’, will see around 200,000 customers 

benefit  from  the  significant  investment  which  will  improve  resilience  and  allow  us  to  continue  to  deliver  for  the 

people of the area for generations to come. 

Phase 1 of the project is underway, which will replace pipeline connecting Lartington Water Treatment Works with 

Gainford - including sections which are more than a century old  - as well as see new pipe linking underground 

reservoirs at Whorley Hill and Shildon, and up into Spennymoor. 

As with any project of this size, delivering the work itself is just part of the process - equally important is keeping 

customers in the area informed. 

We’re working hard to make sure as work progresses into new areas that customers living nearby are kept up to 

date and know about any impact activities may have on them. 

The environment is at the heart of everything we do, and also has a place at the heart of Project Pipeline, and 

we’re  making  sure  it  delivers  for  the  environment  at  the  same  time  as  delivering  great  quality  water  for  our 

customers. 

Event Risk Index (ERI) - PR19NES_BES13 

We have not achieved this PC.  

Our performance of c.166.907 units for the year marks a 42% improvement on 2021 outturn. Despite this, we have 

not achieved this PC as the penalty threshold reduced by 32% to 152.940 units.  

This means we have incurred a penalty of -£0.028M. 

This  is  a  bespoke,  penalty-only,  calendar  year  measure  and  this  PC  incentivises  us  to  promote  a  proactive 

approach to risk mitigation of water quality events, including understanding the impact of events on customers. 

Events are assessed by the Drinking Water Inspectorate (DWI), and the assessment considers the seriousness of 

an event, our response, the population impacted, and the duration. 

14 July 2023 
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During 2022, 42 events were notified to the DWI for assessment, which is comparable to the number of events 

reported in 2021. The outcome in 2022 was influenced by five high scoring events, four of which occurred in our 

North East operating area. A bacteriological failure at Whittle Dene, one of our major water treatment works (WTW) 

in the North East was our highest scoring event accounting for 54.6795 units. It was an isolated event with no 

further  sample  failures  taken  at  the  treatment  works,  or  in  the  network,  supplied  by  Whittle  Dene.  The  lack  of 

additional sample failures or customer complaints confirmed that the issue was confined to the treatment works 

and had no impact on customer supplies or public health. Steps have been taken to protect customers from future 

failures including additional site inspections, root cause analysis, and staff training. 

Our  biggest  failure  in  our  Essex  and  Suffolk  region  occurred  in  August  2022  when  we  received  a  total  of  11 

customer contacts regarding metallic taste and odour of their supply. A cluster of contacts in the Broomfield area 

of  Chelmsford  have  been  linked  to  firefighting,  and  it  is  very  likely  that  the  large  draw  of  water  from  hydrants 

disturbed some mains sediment causing the customers to experience a temporary metallic taste to their water. In 

addition,  some  positive  sample  results  in  a  block  of  flats  highlighted  a  specific  issue  at  that  location.  It  was 

discovered that a valve, assumed open, was closed. It is believed this closed valve has caused some customers 

to notice a slight metallic taste to their water. In response additional flushing and sampling was carried out, with 

customers reporting to us that their supply had returned to normal. 

We’re committed to improving on ERI performance and investing in our assets. 

Discoloured water contacts - PR19NES_BES11 

We have achieved this PC. 

This is a bespoke calendar year measure that reflects the number of times we’ve been contacted by customers 

due to the appearance of their tap water not being clear, per 10,000 population. The appearance measure covers 

seven contact types including discolouration (brown/black/orange and blue/green/pink), aerated water, particles, 

and general conditions. 

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Our PC this year was 8.98, which we’ve beaten with a result of 7.85, earning a reward of £0.992M. We’ve continued 

to  perform  better  than  our  PC  for  the  eighth  year  in  a  row  and  this  has  been  the  best  performing  year  for 

appearance. 

Our  plan  continues  to  focus  on  appearance:  discoloured  water  –  brown,  orange,  or  black,  which  is  our  major 

contributor of contacts to this measure. Very occasionally, and for a short time, customers’ tap water may appear 

discoloured. This is caused by the disturbance of harmless material in our water supply network, possibly caused 

by a burst, leak or third-party activity. We are continuing to progress with our programmes of work agreed with the 

Drinking Water Inspectorate (DWI) to improve the number of trunk mains in which flow can be automatically raised 

with less risk of disturbing mains material and causing discolouration in downstream supply areas. 

Continuing  to  flush  smaller  sized  pipes  closer  to  customers  is  happening  on  a  prioritised  basis  as  well  as 

investigations into how to improve the other contact types such as water coloured white due to aeration. Due to 

resource issues requiring careful management through the summer, we focused our flushing activity in Teesside. 

This focused zonal approach appeared to deliver step change in performance. As a result, we are reflecting on 

how we can replicate this approach in future within other areas. 

We’ll also look for innovations that can cleanse parts of the network which cannot be managed with our current 

techniques. 

We’ve increased the number of text messaging alerts to cover the different contact types to inform customers that 

we are aware of an issue and are investigating the potential cause. We’ve also continued with employee training, 

to make sure we are using the correct operational techniques, which we know helps to manage the number of 

contacts we receive while we work on the network. We’ve supplied training to third party contractors to also help 

manage the number of contacts we receive. 

Taste and smell contacts - PR19NES_BES12 

We have achieved this PC. 

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This bespoke measure reflects the number of times we’ve been contacted by customers to report perceptive issues 

with the taste or smell of their tap water. We want our customers to be satisfied with the taste and smell of our tap 

water. 

We received 789 taste and smell contacts in 2022. This level of performance is better than the upper quartile (top 

25%)  threshold,  and better  than  our  stringent  PC  of 960  contacts.  An  outperformance  reward  of  approximately 

£0.263M is payable for this measure. This is particularly good, given we were able to maintain this performance 

through  challenging  operational  periods.  The  hot/dry  summer  required  carful  management  as  we  protected 

resources, and addressed an elevated numbers of mains bursts and other issues which required a reactive repair. 

Water supplies for most areas routinely come from the same source. However, to carry out asset maintenance, or 

in response to reactive issues like a burst pipe, water to an area can be re-zoned through a different route or come 

from a different source treatment works. We know that customers can be sensitive to changes derived from these 

actions and may choose to contact us to report a perceived change in taste or odour to their supply. 

The drinking water we supply is very high quality, but occasionally some of our customers perceive different tastes 

or odours. This could be due to: 

• The use of chlorine to maintain good hygiene in our water supply network. 

• A change in where a customer’s water comes from, or how it is treated. 

• Issues with a customer’s own plumbing inside their home. 

• A change in a customer’s perception. 

There is an ongoing project with Siemens in the Tees system where there are a higher-than-average number of 

contacts for both discolouration and T&O, and also records a steady number of CRI-related fails each year. Borne 

out  of  the  Innovation  Festival,  we  installed  online  water  quality  monitors  in  the  distribution  network  to  identify 

changes in water quality parameters. This information is then being used to support investigations into water quality 

changes  which  may  influence  taste  and  smell  of  the  water.  The  project  also  incorporates  leakage  data  to 

understand synergies with water quality and includes customer behavioural research to understand how the future 

customer wants to interact with water quality info.  

OUTCOME 9: Our sewerage service deals with sewage and heavy rain effectively 

AMBITIOUS  GOAL:  Eradicate  sewer  flooding  in  the  home  as  a  result  of  our  assets  and 
operations. 

• Internal sewer flooding – common  

• Repeat sewer flooding – bespoke  

• External sewer flooding – bespoke  

• Risk of sewer flooding in a storm – common  

• Sewer blockages – bespoke  

• Sewer collapses – common 

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Internal sewer flooding - PR19NES_COM08 

We have achieved this PC.  

This is a common measure with financial incentives associated with under and out performance. The performance 

commitment records the number of internal sewer flooding incidents per 10,000 connected properties per year.  

Internal sewer flooding is one of the worst performance failures that our customers can experience. Since the end 

of 2019/20 we are delighted to have reduced the number of internal sewer flooding incidents we report by  more 

than 64%.   

Our performance has improved by over 30% compared with the performance we reported last year with our success 

resulting from the continuing maturity of our sewer flooding tactical plan we started in 2019.  

Highlights this year include visiting over 500 high risk properties and investigating, clearing blockages, and fixing 

sewer defects where we find them. We also significantly boosted the engagement we have had with customers 

from our Bin the Wipe campaign by sending an additional 100,000 information letters to customers in hotspot areas. 

This is on top of the 170,000 properties we have engaged with directly on the ground.   

Our tactical plan is reviewed monthly to make sure we are doing everything we possibly can to help reduce the risk 

of sewer flooding to customers, as well as providing the right level of support and standards when this does happen. 

We are also working to implement several additional recommendations recently identified in Ofwat’s and CCW’s 

joint sewer flooding research and hope to have these embedded as business as usual for 2023/24. This will include 

how we can provide an enhanced standard of care for customers who experience internal and repeat internal sewer 

flooding. 

Our performance this year means we are one of the top performing companies in relation to internal sewer flooding, 

with our performance above the industry upper quartile. Further initiatives planned for 2023, including CCTV of all 

first-time blockages will help further reduce the risk of sewer flooding to customers in the North East.   

Repeat sewer flooding - PR19NES_BES17  

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We have significantly outperformed our PC again this year.  

In accordance with our ambition to reduce sewer flooding in the home as a result of our assets and operation, we 

have a bespoke performance commitment for repeat sewer flooding (properties which have flooded internally more 

than once in the last five years). For the third year in a row, we have significantly outperformed our performance 

commitment for this measure.   

Since the end of the previous reporting period, we have reduced repeat sewer flooding by over 75%.  

Our performance for repeat sewer flooding continues to be driven by the rigour we undertake through manager led 

investigations as well as from the interventions we carry out as part of the sewer flooding tactical plan we have had 

in place since 2019.   

Internal sewer flooding, particularly repeat internal sewer flooding is one of the worst service failures our customers 

can experience. We are proud that our performance in this area continues to be strong, especially with respect to 

the number of internal sewer flooding incidents we are now experience  ‘in year’, which is only six incidents this 

year.   

In accordance with our incentive structure for this measure, we’ve earned an outperformance payment of £1.212M. 

External sewer flooding - PR19NES_BES16 

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We have not achieved this PC.  

This is a bespoke measure with a financial incentive applied. The performance commitment records the number of 

external sewer flooding incidents per year.   

Since  the  end  of  the  last  regulatory  reporting  period  (2019/20)  we  have  reduced  the number  of  external sewer 

flooding incidents by 34%. However, despite this improving performance, we underperformed against our PC and 

in accordance with our structure for this measure, an underperformance payment of £0.560m will be paid. 

Although  we  did  not  achieve  our  PC,  our  performance  has  improved  by  a  further  10%  compared  with  the 

performance we reported last year. We have the right initiatives in place within our sewer flooding tactical plan to 

meet our future targets, including several specific initiatives helping  us to reduce external sewer flooding. These 

initiatives  are  now  starting  to  outperform  our  initial  benefit  assessment,  with  a  great  example  of  this  being  the 

investigations  and  technical  rigour  we  are  undertaking  on  first  time  external  flooding  events  occurring  on  the 

Transferred Drains and Sewer Network (TDS), which is delivering a measured reduction in external flood risk of 

10% more than we originally had estimated.   

We  continue  to  support  affected  customers  with  Guaranteed  Standards  Scheme  (GSS)  payments,  as  well  as 

providing  support  and  cleaning  services  post  flood  events.  Our  response  time  for  attending  external  flooding 

incidents (four hrs) is already amongst the best in the industry. We are also investigating how we can now provide 

longer term solutions to those properties with chronic repeat hydraulic flooding, following on from the sewer flooding 

studies we carried out and reported on in our last annual performance report.   

Our performance this year shows that our overall reduction in external sewer flooding incidents since the start of 

the regulatory reporting period on average continues to be among the best of those other companies that are also 

improving. Despite this, we are still one of the worst performing companies at present for external sewer flooding. 

We are confident in our planning and that our performance will improve in the near future, however, we will also be 

using the outputs from our Drainage and Wastewater Management Plan (DWMP) to identify future hotpot areas for 

investment, as well as using this programme to identify how we can best use new technology to proactively manage 

risk through ‘smart networks’.   

Risk of sewer flooding in a storm - PR19NES_COM11 

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We have achieved this PC.  

This is a common measure with no financial incentive.  

The performance measure defines the percentage of population at risk in a 1 in  50-year return period storm as 

defined by hydraulic modelling.   

As we reported last year, the supporting hydraulic modelling work that we carried our as part of our Drainage and 

Wastewater Management Plan (DWMP) has led to us exceeding our 2024/25 performance commitment for this 

measure ahead of programme.   

We are publishing our final DWMP in May 2023 and as the modelling work has been completed, there has been 

no further opportunity to reduce this number. 

We have continued to reduce the risk of sewer flooding for our customers through our tactical plan activities in 

accordance with the other performance commitments we have in place for sewer flooding.     

We  are  behind  in  comparison  to  the  rest  of  the  industry  with  the  percentage  at  risk  number  we  are  reporting. 

However, our final DWMP will help provide long-term resilience for our customers and therefore we are confident 

we have the right long-term strategy for this area, despite this particular measure not being a common performance 

commitment in 2025-30. 

This measure is reputational only and therefore no outperformance reward has been earned.   

Sewer blockages - PR19NES_BES15 

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We have achieved this PC.  

Our sewer blockage performance has improved by 14% compared to last year and as a result we have earned an 

outperformance reward of £0.168m. Our improvement in performance has been driven by the continued success 

of our tactical plan initiatives including our Bin the Wipe campaign, which has now engaged more than 170,000 

households.  We are proud that Bin the Wipe has now been adopted as a national campaign through Water UK.   

We recognise that blockages are a significant contributing factor to the performance of our sewerage system. We 

therefore have a bespoke performance commitment in place which records the number of sewer blockages that 

required clearing. A blockage is defined as an obstruction in a sewer which causes a reportable problem, such as 

sewer flooding or a discharge to the environment. 

We  have  also  continued  to  have  some  great  success  in  reducing  the  amount  of  Fats  Oils  and  Grease  (FOG) 

entering  our  network  from  Food  Service  Establishments.  A  great  example of  this  success  is  the  work  we  have 

completed in partnership with Greggs. We have shared best practice and information on the risks the FOG in our 

network causes and as a result Greggs will be rolling our Grease Recovery Units at over 200 outlets across the 

North East.     

Over 50% of sewer flooding incidents are  because of blockages within the sewerage system, with over 60% of 

blockages caused by wipe wipes. The work we are leading on both locally and nationally in this area is now starting 

to deliver real benefits to our customers. 

Our sewer blockage performance continues to be better than the industry average and we are also better than the 

industry  upper  quartile.  As  part  of  our  tactical  plan,  we  continuously  benchmark  ourselves  with  the  rest  of  the 

industry and  because of this knowledge sharing, we will be starting a new initiative in 2023 to CCTV all sewer 

blockages, fixing any defects that we identify along the way. This will be another intervention that will help further 

reduce our sewer blockage performance over the next year and beyond.   

We also planning to adopt AI defect recognition software to help with the proactive inspection of our sewer network 

and are currently piloting this technology on a couple of existing programmes.   

Case study: Inspiring the nation to ‘Bin the Wipe’ 

Back at the start of 2020, we launched our Bin the Wipe campaign. Since then, we have seen a 52% reduction in 

blockages and a 64% reduction in home flooding incidents. The campaign has been so successful that the nation’s 

industry  body,  Water  UK,  is  coordinating  with  water  companies  across  the  country  to  take  the  Bin  the  Wipe 

message nationwide. 

14 July 2023 
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Our Bin the Wipe campaign has been successfully reducing the number of sewer blockages since 2020, and 2022 

saw our teams operating in 24 hot spot areas, engaging with more than 90,000 households. 

Wipes are a significant challenge for our sewers, as they do not break down in the way toilet roll does, causing 

them to settle in pipes and add to or cause blockages. In fact, wipes were present in 64% of the more than 15,000 

sewer blockages our team cleared in the year before the Bin the Wipe campaign started. 

The campaign combines education on the problems wipes can cause with on-the-ground action from our teams 

which enables them to speak to wipe flushers face-to-face. This combination has been successful, and in the best 

performing areas - Washington and Darlington - we found a 91% reduction in the number of wipes found in the 

sewers. 

This improvement has contributed to a 52% reduction in blockages in the hot spot areas since the campaign started 

in 2020, and a 64% reduction in the number of home flooding incidents. 

Those excellent outcomes have caught national attention. In the past year WaterUK, the industry body representing 

water companies across the country, has unveiled plans for a national Bin the Wipe campaign, inspired by our 

success and with the backing of MPs. 

Bin the Wipe is a simple message, but one with a significant impact - not just in the North East but now across the 

country as well. 

For us, since its’ inception in 2020, the campaign has:  

•    Reduced blockages by 52% 

•    Reduced internal flooding by 57% 

•    Reduced external flooding by 60% 

•    Reached over 170k customers in our hotspot areas 

•    Reduced the wipe count in hotspots by up to 91%. 

Sewer collapses (per 10,000km sewer) - PR19NES_COM14 

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We have achieved this PC. This is a common measure with an associated penalty and therefore we do not earn a 

reward for our outperformance.       

We are continuing to reduce our sewer collapse number and have outperformed our PC once again, for the third 

year in a row.  

The  measure  is  a  count  of  the  number  sewer  collapses  per  thousand  kilometres  of  sewer  that  have  not  been 

identified proactively and cause an impact on service or the environment. 

We have reduced the number of sewer collapses we report by 50% compared to the number we reported at the 

end of 2019/20.  

We  carried out specific  training  within  our operational  teams  to  embed  the  learning  and best practice  we  have 

identified throughout the year. We’re also seeing several sewer collapses avoided through proactive investigations, 

for  example  those  identified  as  part  of  our  find  and  fix  activities  associated  with  our  ‘Flooding  Other  Causes’ 

programme.  

Our sewer collapse performance is ahead of the average number of sewer collapse reported by the industry. We 

recognise that there is more than we can do in this area and will continue to benchmark our performance and learn 

from companies who are doing slightly better than us to help us continue to reduce sewer collapses in the future. 

The work we are trialling using AI for defect recognition from CCTV survey footage is a good example of where we 

plan to improve the efficient and effective proactive inspection of our sewer network. 

Our continuing improving performance in this area has helped reduced the risk of sewer flooding incidents and 

environmental discharges across our region.  

Finally, as one of four asset health metrics, longer term performance is strongly linked to the delivery of appropriate 

levels of capital maintenance. Our PR24 Business Plan will set out our proposals in more detail, however delivery 

of this plan will in turn be dependent on.the provision of appropriate levels of funding for capital/asset maintenance 

activities. We do not consider that the current regulatory approach to setting funding allowances is sustainable in 

the longer term, a topic we will elaborate on further in our Business Plan.   

14 July 2023 
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THEME FOUR: LEADING IN INNOVATION 

OUTCOME 10: We are an innovative and efficient company 

AMBITIOUS GOAL: To be leading in innovation within the water sector and beyond 

We measure innovation in multiple ways across the business, as detailed in the below table.  

Table 2 

METRIC 

DESCRIPTION/HOW 

2019/20  2020/21 

2021/22  TARGET 

2022/23 

Reach 
Culture  

WILL MEASURE  

Social media reach  
No. 
of 
ambassadors  

innovation 

Employee 
participation  

Collaboration 

No.  of  employees  taking 
part 
Innovation 
in 
Festivals  
Innovation 
attendees 

Festival 

External 
collaboration 

No. 
of 
businesses/organisations 
attending 
Innovation 
Festivals   
Added value   Training delivered as part 
Innovation  Festivals 

of 
(hours)  
of 
No. 
activities  

8.6M 
47 

15M 
71 

2.3M 
82 

484 

645 

439 

ACHIEVED  

>5M 
All 
employees 
of NWG 
>20% 

3.8M 
96 

610 

3,311 

734 

2,730* 
(digital 
event)  
941 

4000 

>2,500 

>2050 

800 

>140 

600 

46 

400 

256 

>12 

256 

/ 

Design 
sprints 
hacks  
Ideas 
generated  
Ideas  in  the 
innovation 
pipeline  
Success  rate 
(%) 
Potential 
value (£)  
Innovation 
funding 
secured (£)  

innovation 

23 

40 

44 

>20 

31 

Ideas unfiltered  

615 

2,000 

1,675 

>300 

1800 

Total no. of ideas  

56 

70 

87 

>50 

109 

Projects adopted as BAU 
(business as usual)  
Potential  value  of 
pipeline 
External funding secured  

the 

38% 

41% 

40% 

40% 

40% 

£37M 

£20M 

£66M  per 
annum 
£12.03M  >£500,000  £1.8M 

£15m 

- 

27M* 
estimated  
£475,000  for 
innovation; 
£350,000  for 
research  & 
development  

Leading in innovation  

Innovation is central to how we work across the whole business and ‘innovative’ is one of our core values  that is 

reinforced  and celebrated  across  the  year.  For  the  past  seven  years  we have  been  working  to  create  the  right 

environment for an innovative culture to thrive. We are now benefitting from increased engagement in innovation 

which is enabling everyone to improve how we work no matter the job level or role. This is essential so that we can 

deliver the ambitious goals set out in our 200-25 Business Plan and has resulted in us being widely seen as leading 

in innovation, both within the water sector and beyond.  

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This year we have built on the strong foundations laid and have focused on enabling bigger ideas, faster execution 

post proof of concept and inclusive innovation. This has enabled us to build the number of employees involved 

innovation which currently stands at 20% of the organisation.  

We have continued to build the robustness of the pipeline process, making it more accessible and accurate. In 

addition, we have had significant success securing external funding to grow our innovation capacity both in terms 

of capacity and capability. To date we have won the largest number of bids from the Ofwat Innovation Fund (10 

out of 51 winning bids) and have secured £14M in funding.    

Innovation culture 

Our innovative culture has matured and more of our employees are able to play an active role. The growth of our 

innovation ambassador group is central to the growth and strength of the culture shift which is more curious and 

open for changing how we run our operations and business.  

We  have  firmly  established  ‘hub  leads’  for  each  of  our  operational  directorates,  which  is  an  effective  way  of 

communicating new ideas to the right audience and hearing more of what is needed from the business. The number 

of  employees  engaging  with innovation  has  grown  significantly.  The  innovation ambassador  group  now has  96 

members up from 80 last year - these members come from across the whole business and represent all levels. In 

addition, more than 600 employees attended the Innovation Festival which is a key engagement opportunity.   

This  has also  enabled  us  to  have  a better  relationship  with the supply  chain  as  we  are  faster at  responding  to 

opportunities and can give clear feedback. We were voted number one in the British Water Supply Chain Survey 

for innovation. We also share our innovation news monthly through our Innovation Connect newsletter and invite 

external organisations that excel in innovation to a quarterly Innovation Connect virtual call.   

Training and knowledge sharing is a key aspect of the Innovation Ambassador group which brings in an inspiring 

external speaker each month and invites sharing across business units internally. We have continued to upskill the 

organisation  via  our core  skills  training  programme  and  the  NWG  Innovation  University, which  offers bite-sized 

training  covering  all  the  core  elements  of  innovation.  More than  100  employees  took  advantage  of  the  training 

offered on intellectual property, facilitation, design sprints or core skills which exceeded 500 hours. 

Open data  

We have a long history of living Our Purpose and Our Values. As a result, developing our capabilities regarding 

open data is the natural ethical thing for us to do. We have been opening up our data sets, collaborating widely 

and realising value for more than seven years now mainly in the form of data hacks. This has exposed us to new 

thinking  that  we  have  brought  back  into  our  business.  This  collaboration  and  co-creation  has  also  brought 

economic, societal and environmental benefits to our operating regions  and beyond. The National Underground 

Asset Register is one of our best examples of what can happen when we become more open with data.  

The water industry holds vast data sets, that can play a key role in unlocking value for the UK from open data. The 

industry and our customers are facing challenging times, dealing with complex issues related to climate change 

and the current cost-of-living crisis. We believe that open data has a big role to play in helping us to tackle these 

issues and are delighted to be publishing our Open Data strategy. This strategy clearly sets out our ambition and 

commitment to open data, not only for the benefit of our own customers and regions but for the whole industry and 

other sectors. While developing this strategy, we have researched published best practices as well as inspiration 

from those who have demonstrated the ability to generate real, quantifiable value as a result of opening up data, 

14 July 2023 
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such as governments from around the world. We have consulted widely and challenged ourselves, our assumptions 

and our practices and we are excited to be able to bring this to life for our company and across the water sector. 

We have a growth mindset, and we know that we learn by doing. We will review this strategy periodically and will 

continue to scour the outside world for best practice that improves our performance.  

Open data statement  

We have recently published our Open Data Strategy and were cited in the Ofwat sponsored PwC assessment on 

Open Data progress in the Water Industry (Open Data Assessment Report Live (ofwat.gov.uk) as an example of 

good practice for strategy and strategic oversight. We have clearly and publicly set out our aspirations, ambition, 

and commitment to driving value for our customers, society, and environment through opening up our data. Our 

Open Data Lead is working with stakeholders to bring the strategy to life and deliver year one of our tactical plan. 

We  have  already  begun  to  develop  and  strengthen  our  data  publishing  by  adding  licenses,  certificates,  and 

additional datasets. We prioritise user ease and provide metadata and data user support. 

While we put in place robust processes and practices in line with our strategy, we have made some improvements 

to the way we publish our APR data. These include: 

• 

Adding an open data licence type with a link to further detail on the licence condition  – to help users of 

the data to clearly understand what, if any, the restrictions are. This licence has also been embedded into the file 

itself so that it remains with the data upon download. 

• 

Adding an Open Data Institute certificate – this is in line with our commitment to adopt the ODI certification 

scheme so users can see at a glance how closely the published dataset conforms to best practice. 

• 

Publishing additional datasets alongside the final APR tables – initially we have created a 3-year dataset 

for a subset of Table 3 datapoints. This allows users to see trends without having to download and manipulate 

three separate files. We are also investigating the release of further related datasets, which provide more detailed 

data behind the APR numbers. These will form part of our prioritised data publication pipeline. 

• 

Basic metadata alongside the file, to help users understand the data at a glance while we work on adopting 

our full open data metadata standard. 

• 

The provision of a data user help function, to support users with data related queries.  

Lastly, we are leading the Stream initiative, which helps us publish additional datasets that support the APR tables. 

This is useful for users who want to access data at the sector level instead of just individual company data. The 

Use Case and Market Needs advisory group in Stream will consider APR-related data and supporting datasets to 

prioritise which sector datasets to publish first. 

Innovation Festival  

The Innovation Festival returned for the sixth year, an in-person event again, and was our most successful to date 

in terms of engagement across the water sector and beyond and quality of the output. The Innovation Festival is 

an important element of our innovation programme and is key for idea generation, acceleration of existing projects 

and establishment of consortia for future external funding bids.  

These  events  are  now  very  established  and  highly  anticipated  nationally  and  globally.  The  novel  format  of  the 

festival also enables us to attract a diverse audience which is a critical part of design sprints.  

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Our latest festival hosted 31 activities, 27 sprints and four data hacks. Five of the sprints were online to keep our 

festival as inclusive as possible.  

The festival attracted 53 sponsors from 38 sectors, 600 organisations with participants from over 33 countries. We 

also had four sprints that had global hubs including US, India, Ireland, and Australia. Our novel, electronic delegate 

badges enabled 23,000 connections and saved 77Kg of paper.  

Sydney Water ran its second Innovation Festival in November using a similar blueprint as ours. We continue to 

collaborate closely with Sydney Water and played an active part in the 2022 event including a couple of shared 

sprints.  We also passed on our expertise to help the company run the event, further reinforcing our leadership in 

innovation globally. The equivalent professional services value of this contribution is estimated to be between five 

and six million pounds.  

Since our first Festival we have taken >250 ideas back into the business and put more than £1.5million back into 

the local economy, demonstrating our convening power to bring others into our regions. In 2022 we reached an 

engaged  audience  across  key  social  media  channels  (LinkedIn,  Twitter  and  Facebook),  building  up  a  strong 

innovation community with thought leadership and impactful content that had a social reach of >2.7 million. The 

festival output projects cover many aspects of the business, including the sector changing No Dig pipe fix product 

which we have used in >10 live trials with great promise. Additionally, five Ofwat innovation bids were formulated 

in  the  festival  potentially  worth  >£18M,  these  include  Project  Greenscape,  Asset  Health  Demonstrator  (in 

partnership  with  the  nuclear  sector)  and  a  self-powering  smart  meter.  This  shows  the  strength  of  the  festival’s 

convening power. 

Innovation fund  

During 2022/23 there has been another round of the Ofwat Innovation Fund, Breakthrough 3 and us have been 

active in both the Catalyst and Transform rounds. We submitted five bids into the Catalyst fund, asking for £4.5M. 

There was a total of 32 bids submitted from 10 water companies, 19 of these were invited to pitch stage. We took 

four out of five bids through to pitch stage and successfully won two bids out of 10 awarded, with a game changing 

water powered smart meter (£874,954)  and a root growth prevention technology (£939,377). We are also short 

listed for potential funding with the water literacy tool kit (£864,484) bid with funding remaining from the Transform 

round.  

We have four bids submitted into the two stage Transform competition and got all four through to stage two. These 

bids cover asset health, regenerative agriculture, open data, and water efficiency. Our Stream open data project 

was successful and secured £3,973,205. There were 11 bids in the competition and  five secured funding in this 

round. In addition, they awarded our Water Literacy Toolkit Catalyst project £864,484 funding, netting us three out 

of  five  catalyst  bids.  These  bids  have  brought  our  overall  total  funding  secured  to  £18,904,917  which  is  164% 

versus our contribution to the competition and 18.5% of the total fund so far. 

Previously in the funding programme we have secured eight bids worth over £12.5M, which is already more than 

we put into Ofwat during the 2020-25 Business Pan period (£11.5M).  

This competition is extending our innovation capacity both in terms of available funding and personnel.  It is also 

driving  higher  levels  of  collaboration  across  the  water  sector  and  beyond  as  we  seek  out  new  and  interesting 

partnerships for future rounds.  

The projects have been granted funding are progressing well, including the Organics Green Ammonia project which 

now  has  the  equipment  being  commissioned  at  Howdon.  This  world-first  project  turns  ammonia  into  green 

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hydrogen fuel, collaborating with Organics, Wood Group, and Warwick and Cranfield Universities. The Support for 

All  platform  to  help vulnerable  customers  pilot has  also been  successfully  run and  we  are  now exploring scale 

opportunities. The National Leakage Research and Test Centre (£5.3M), an ambitious, first of its kind leakage test 

centre for the sector to significantly fast forward technology development in this vital space is now in the design 

phase. Stream, the transformational open data platform has completed phase one work and is in the Transform 

competition to secure further funds to bring this to life. 

Value from innovation  

We have continued to drive speed to value from innovation and making our ideas bigger. The innovation pipeline 

has 109 ideas being considered across the business. The estimated value of ideas in the pipeline, if successful is 

worth >£66M per annum if successful.   

We actively encourage employees to come forward with innovative ideas and support their development. A great 

example of this is the Invest Quest competition, which enabled the Micro-Algae treatment process to grow to three 

times its original design.  

We are focusing support on the transformational ideas such as the Tipping Point asset health tool, No Dig pipe fix 

technology  and  the  National  Underground  Asset  Register,  which  are  all  now  ready  for  business-as-usual 

deployment.  

In addition, the Pressure Vessel solution, which was home grown in Essex & Suffolk, is now making a difference 

to reduce interruptions to supply. This team won the Innovative ViVa award in 2022. ViVa (Vision and Values) is 

our employee awards scheme to commend employees for doing a great job or going the extra mile.  

These are a few examples of how innovation is really making a difference to our customers, now and for a more 

resilient future. 

Case study – Innovation fund – Investing in technology to reduce leaks 

We are at the forefront of new technology to help detect and repair leaks faster. Last year we were awarded more 

than £5m to create the National Leakage Research and Test Centre, which will provide a testbed for new solutions 

to the problem of leakages in the water network. 

Across the country, the water network loses 51 litres of water per person per day to leakages. That’s a huge amount 

of water, and leaks can cause significant problems for customers and put unnecessary strain on the environment. 

Lots of progress has been made, and the number of reported leaks has fallen significantly since the mid-1990s - 

but there’s lots more to do, and we were disappointed this year not to hit our target for leakage reduction in the 

North East. 

To help with that effort, we have been awarded more than £5m from Ofwat to create the National Leakage Research 

and Test Centre (NLRTC). The project will create a testbed for trialing innovative new solutions for detecting and 

fixing leaks.   

That testbed - a five kilometer-long buried water network - will have its own control room, with three new dedicated 

staff to run it. 

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The NLRTC will provide a place where innovators can try out new ideas without risking interruption to customers’ 

water supplies or harming water quality - any water leaked by the centre is collected and recycled. 

The project is part of the Water Breakthrough Challenge, which is led by Ofwat along with Challenge Works, and 

awards funding to innovative initiatives which deliver benefits for customers, society and the environment.  

THEME FIVE: IMPROVING THE ENVIRONMENT 

OUTCOME 11: We help to improve the quality of rivers and coastal waters for the benefit of 
people, the environment and wildlife 

AMBITIOUS GOAL: Have the best rivers and beaches in the country 

AMBITIOUS GOAL: Have zero pollutions as a result of our assets and operations 

• Treatment works compliance – common  

• Bathing water compliance – bespoke  

• Pollution incidents – common 

• Water Industry National Environment Programme (WINEP) – bespoke  

• Delivery of WINEP requirements – bespoke 

Our care and respect for our natural environment goes far beyond our regulatory requirements. We work constantly 

to protect and bring about improvements for our coasts, rivers, and watercourses in all areas of our operations.  

Our vision is to be the leader within our sector for environmental performance for our customers and communities 

- and we have achieved several significant successes towards this. In the last two years, we have:   

•  We  have  a  good  track  record  of  being  a  Four  Star  rated  company  in  the  Environment  Agency 

Environmental  Performance  Assessment.  In  its  latest  assessment  we  achieved  Three  Stars  (leading) 

because the threshold for Four Stars has got higher with  compliance (our only area rated amber) now 

being a core metric. We score green in all other areas.  

• 

In the North East, 32 out of the 34 bathing waters are rated Good or Excellent. We have overseen dramatic 

reductions in pollution in the past decade. 

•  We were also the first and remain the only water company to use 100% of our sewage sludge to produce 

clean energy through advanced anaerobic digestion at our green power stations at Howdon on Tyneside 

and Bran Sands on Teesside. That is a significant factor in putting us on track to achieve our ambitious 

goal of making our operations carbon Net Zero by 2027. 

This has all been achieved while offering our customers the lowest wastewater bill in England. 

We are proud of the level of environmental investment we committed to in the current five-year investment period, 

which  reflects  our  customers’  priorities  as  we  understood  them  pre-Covid,  but  we  understand  that  times  and 

expectations have changed.  

Climate  change  increases  the  risk  of  drought,  affecting  the  health  of  our  waterbodies,  and  intense  storms, 

increasing  the  risk of  unplanned  discharges  to the  environment. In  the  last  year, our  CEO,  Heidi  Mottram,  has 

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helped to establish and co-chair a new partnership, Net Zero North East England, bringing together a series of 

organisations in our northern operating area to make a bigger collective difference.  

We have recently updated A Vision for our Coasts and Rivers, to set out the progress we have made against the 

nine pledges we have made to water quality and our programme of work to 2025 that will help us achieve our goals. 

They include reducing spills from our storm overflows to an average of 20 per year by 2025. The number came 

down from 25.3 to 20.3 in 2022. However, we are not complacent – while this was in part down to our actions and 

investment, it was also a year in which we saw fewer intense storms, so we recognise there is more to do to make 

sure we can consistently achieve this level, or better.  

We expect to deliver on our pledge to put real time monitoring in place for all our storm overflows during 2023. We 

have also developed a clear plan to implement water quality monitoring at our highest priority sites. 

We  continue  to  cooperate  fully  with  Ofwat’s  and  the  Environment  Agency’s  investigations  into  Flow  to  Full 

Treatment (FFT) compliance at our sewage treatment works and understand we may now be reaching the end of 

Ofwat’s investigation process. More in depth updates can be found on our website.   

Important work is taking place at the two bathing waters that are not rated Good or Excellent, and we are playing 

a full part in this even though their lower status does not appear to be due to our assets. We have also taken steps 

to protect the standards achieved elsewhere in our region. 

Many of our pledges cannot be achieved without the support of partners. Over the past year the Rivers Trust has 

worked with us to establish the North East Catchments Hub and through this new approach, develop a  series of 

catchment and nature-based solutions we hope to take forward from 2025. This would see us deliver water quality 

improvements for North East rivers, while working more closely with communities, catalysing more investment, and 

providing a range of other benefits including flood resilience, biodiversity net gain and carbon sequestration.  

Treatment works compliance - PR19NES_COM15 

We have not achieved this PC.  

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This  is  a  common  measure.  It  differs  slightly  from  that  reported  by  the  Environment  Agency  (EA)  in  its  annual 

Environmental Performance Assessment (EPA) of water companies in England. This measure is reported as the 

total number of failing sites (rather than the number of failing discharges) where one or more numeric permitted 

discharges have been confirmed as failing in a calendar year. This is expressed as a percentage of the total number 

of discharges on the EA register. For both NW and ESW in 2020-25, this measure now includes both sewerage 

treatment  works  (STW)  and  water  treatment  works  (WTW)  discharges  and  is  subject  to  penalty  for  under-

performance (EPA does not include ESW sites). 

Our result this year has stayed stable at  98.52%. This performance is below the 99.00% deadband  and we will 

incur a penalty of £0.287m.  

This year we have seen failures at three sites out of a total of 205 eligible treatment works – these are not the same 

sites that failed in 2021/22.  This result has been associated with two treatment work sites in our Northumbrian 

operating region (one STW and two WTW) and two WTW in the Essex & Suffolk area.  

The  North  East  failing  discharges  were  at  Honeyhill  WTW  due  to  and  iron  failure  and  Billingham  STW  for  a 

suspended solids failure. In Essex & Suffolk, there was also a chlorine failure at Barsham WTW.   

To make sure we are doing all we can to improve our performance we are working on a tactical plan specifically 

for  discharge  compliance.  This  will  cover  both  WTWs,  and  STWs,  and  include  root  cause  analysis,  data 

interpretation and identify any additional training or governance required. 

We are disappointed to have had failures again this year and we recognise these failures have an impact on the 

environment,  people,  and  wildlife  though  in  each  case  the  impact  was  relatively  minor  and  transient.  The 

development of a new tactical plan (similar to what we have done for flooding) will help us to improve in this area. 

This will be across both water and wastewater so we can share learning and implementation. 

The  industry  average  (ten  water  and  sewerage  companies)  performance  for  discharge  compliance  has  been 

between 98.2% and 99.2% over the last eight years. Last year there was only 1.79% (max 99.42% and min 97.63%) 

difference  between  the  highest  and  lowest  performing  company  showing  the  high  standards  achieved  across 

England and Wales. 

We make sure that our treatment works meet the required discharge standards by taking regular samples that are 

analysed for the levels of substances, including phosphorous and ammonia, and other specific substances that 

may  accumulate  to  cause  a  problem  in  the  water  environment.  We  have  a  strong  record  for  meeting  numeric 

discharge compliance limits (with additional reporting following a failure until you have reported 12 consecutive 

months of numeric compliance) at our STWs. These numeric permits apply to 160 of our largest STWs and 44 

WTWs. Future permits will tighten as legislation changes. This will introduce new challenges and standards over 

the next five years and beyond, as well as tightening existing permit standards. We will therefore need to adopt 

new treatment technologies and increase our emphasis on very efficient operational control.  

The  pressures  of  increasing  population,  new  housing,  industrial  development,  and  climate  change  will  also 

challenge our performance. We commit to doing our best to deliver against challenging new standards over 2020-

25. We must also plan to meet future new and tighter standards and satisfy our obligations in working towards 

meeting ‘Good’ Water Framework Directive (WFD) status in our rivers. 

Finally, as one of four asset health metrics, longer term performance is strongly linked to the delivery of appropriate 

levels of capital maintenance. Our PR24 Business Plan will set out our proposals in more detail, however delivery 

of this plan will in turn be dependent on.the provision of appropriate levels of funding for capital/asset maintenance 

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activities. We do not consider that the current regulatory approach to setting funding allowances is sustainable in 

the longer term, a topic we will elaborate on further in our Business Plan.   

To get back on track in 2023/24, a tactical plan to improve performance is currently in development and will aim to 

see us reach over 99% compliance.  

The tactical plan will address three key areas in both water and wastewater: 

1. 

2. 

3. 

Known risks. 

Continuous improvements. 

Trend analysis/data analytics and knowledge sharing/operator interventions procedural changes. 

Examples of intervention activities are shown in the table below (this is not comprehensive and will evolve as the 

tactical plan develops). To improve performance, we are making sure we carry out work at any sites with a history 

of any level of sample failures, to prevent a reoccurrence. We are also continuously improving our approach to 

scrutinising our compliance data. 

Our aim is zero failures. This will be challenging but is important in meeting our environmental purpose and to meet 

our objective to be a Four Star company in the Environment Agencies’ Environmental Performance Assessment 

(EPA). 

Table 3 

ACTION  

DESCRIPTION  

TARGET 

DATE  

Address known risks  

We have carried out extensive investigations to find the root cause of any 

Sherburn 

failures or observed compliance risks and are implementing measures at 

WWTW due 

specific sites to prevent a reoccurrence. These include improving operating 

2024 

procedures and introducing preventive maintenance schedules along with 

extra infrastructure. By taking regular samples that are analysed for 

compliance, including phosphorous and ammonia, and specific substances 

that may accumulate to cause a problem in the water environment, we can 

also take a more proactive approach. We remain committed to achieving 

maximum compliance and are focusing on targeting known risks by putting 

in place interventions at sites with one or more individual sample fails 

(previously it would have been three). This includes investing in cleaning, 

filtration and investigating ammonia issues.  

Lanchester 

WWTW due 

2025 

Continuous 

We’re running a programme of compliance controls including further 

End 2024  

improvement  

improving visibility and scrutiny of compliance data, via a new ‘compliance 

hub’, including data from retailers to facilitate trade effluent management. 

Our wastewater teams will employ investigation and interventions at the first 

failure, and we are investing in cleaning, filtration, and ammonia issues. Our 

wastewater teams have an increased focus on discharge compliance and 

internal reporting requirements.  

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Performance data and 

We’ll make sure data is high quality using Mcert and other quality audit 

analytics  

requirements. We’re focusing on making sure data is correctly interpreted, 

meets reporting obligations and that any necessary actions as a result of the 

data are accurately programmes and resourced to avoid non-compliance.  

Bathing water compliance - PR19NES_BES19 

We have achieved this PC.  

Our  stretching  bespoke  measure  is  to  contribute  to  all  the  region’s  bathing  waters  being  ‘Good  or  Excellent’. 

Previously for 2015-20 our PC was to contribute to all the regions bathing waters being ‘Sufficient or better’.  

Under the bathing water regulations, high amenity beaches are designated as bathing waters and classified every 

year  as  either:  Excellent,  Good,  Sufficient  or  Poor.  These  classifications  are  linked  to  the  levels  of  bacteria 

measured  in  sea  water  during  the  bathing  season  (May-September).  ‘Sufficient’  is  the  minimum  acceptable 

standard. 

Bathing water classifications were assessed for the 2022 bathing season with 32 out of 34 bathing waters either 
Good (7) or Excellent (25).  

The two bathing waters that haven’t met our PC of ‘Good’ or ‘Excellent’ are Marsden (‘Sufficient’) and Cullercoats 
(‘Poor’).  

Marsden classification deteriorated from Good in 2019 to Sufficient in 2021 having been significantly impacted by 

higher-than-normal sample results in both August 2018 and August 2019 that were linked to rainfall events. Our 

Water industry national environment programme (WINEP) investigation in 2020/21 found that local diffuse sources 

represent  the  predominant  cause  and  removal  of  our  only  asset,  a  storm  overflow,  would  not  improve  the 

classification.  

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The definition for this PC includes a specific exemption where it can be proven that our assets are not contributing 

to  any  deterioration  in  classification.  The  EA  provided  written  statements  to  confirm  that  Marsden  meets  the 

exemption  criterion  for  the  2021  bathing  season  and  again  for  the  2022  season.  Therefore,  our  reported 

performance is 33/34 (or 97.06%) for this year that comprises of 32 beaches rated as Excellent or Good along with 

Marsden rated as Satisfactory but with a written exemption confirmed by the EA. 

Cullercoats has been classified as Poor since 2018 having deteriorated from Good in 2016  and to Sufficient in 

2017.  Due  to  the  break  in  classification  for  2020,  the  5-year  consecutive  count  before  de-designation  for  Poor 

bathing waters has been reset in 2021. This means that the earliest Cullercoats could be de-designated due to five 

consecutive Poor classification under the regulations will now be after the 2025 season. 

Our  WINEP  investigation  found  that  contaminated  groundwater  is  the  most  likely  primary  reason  for  the 

deterioration in bathing water quality and that there is no evidence that our assets have an impact. This study built 

on the extensive partnership investigations with the EA and local authority  carried out since 2017 and included 

targeted investigations and surveys to determine the most likely cause. An uncharted polluted drainage culvert 

belonging to the local authority, that was identified in a previous study in 2011 and capped off from the beach, was 

also investigated further. Groundwater flow in the culvert have been shown to contain high levels of bacteria and 

to improve bathing water quality, this was diverted into our combined sewerage network in December 2022. We 

continue  to  have positive engagement  with the  Cullercoats Collective, a  local interest  group  with  wider-ranging 

membership  including  members  of  Surfers  Against  Sewage,  but  with  a  broad  town-wide  remit.  We  remain 

committed  to  working  with  our  partners  including  North  Tyneside  Council  and  the  EA  to  improve  the  seawater 

quality at Cullercoats for our customers, local businesses, and recreational users. 

Our Water Ranger volunteers help us to monitor environmental conditions and improve the coastal area. In our 

engagement  with  local  community  groups,  we  provided  training  to  Markse  Litter  Action,  Seascapes  beach 

volunteers, Saltburn Countryside Volunteers, Tees Valley Wildlife Trust and the Friends of the Lower Path. The 

community groups are passionate about protecting the environment and their local area, especially the beach and 

nearby waterways. Training gave them an in-depth understanding of our wastewater system and included the Bin 

The Wipe campaign. 

Our bathing waters continue to be amongst the cleanest in the country. We were ranked second in this measure 

in 2022 for the percentage of Excellent and Good coastal bathing waters in comparison with water companies in 

England. 

Case study: NE Catchment Hub - Industry-leading partnership with The Rivers Trust 

Water is best managed at a regional level, and within the North East we’re working with The Rivers Trust to create 

a regional hub to develop improvements for water quality and the wider environment. 

We’ve  created  the  North  East  Catchments  Hub,  a  first  for  the  industry,  and  with  it  comes  three  full  time  roles 

covering  the  Tyne,  Wear  and  Tees  river  catchments,  bringing  together  the  best  local,  regional  and  national 

expertise to benefit our region 

Those  three  roles,  plus  a  part-time  managerial  role,  will  help  us  and  our  partners  to  invest  effectively  in 

improvements to watercourses and the wider environment. 

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By  working  in  partnership,  with  the  Catchments  Hub  as  the  coordinating  presence,  we  can  do  more  than  any 

individual  organisation  can  do  alone,  by  combining  expertise  and  best  practice,  and  considering  alternative, 

sustainable ways to invest for environmental benefit. 

In the past year, we have invested around £300,000 in the Catchments Hub, identifying eight catchment and nature-

based schemes which have been put forward for inclusion in our 2025-30 Business Plan. 

The catchment  and  nature-based  solutions  have  multiple  benefits.  By  focusing  on  cross-catchment partnership 

working, rather than end-of-pipe schemes at Sewage Treatment Works, we can save an estimated £51.7m, helping 

keep customer bills down, and also minimise our carbon and climate impacts while delivering substantial water 

quality benefits. 

Pollution incidents (Category 1-3 Wastewater) - PR19NES_COM09 

We have once again achieved this PC.  

We aim to avoid all pollution and our PC for all wastewater category 1, 2 and 3 incidents is a common measure for 

pollution using the Environment Agency’s (EA) EPA methodology.   

Our 2022 performance for category 1-3 wastewater pollution incidents has improved further with 60 incidents (19.98 

against our PC of 23 incidents per 10,000km of sewer) and we have earned a reward of £0.902m.  

In the Environment Agency (EA) assessment of our performance for incidents attributable to Storm Malik in January 

2022, an extratropical cyclone that caused damage throughout our region with severe winds and multiple power 

outages, they found all but one incident to have caused no impact (category 4 incidents). The decision also reflects 

that after full investigation by the EA these incidents were deemed to be outside of our control. 

We are very pleased that we had zero serious category 1 and 2 pollution incidents in 2022 from our water and 

wastewater assets having previously reported very low occurrences at one (category 2) in 2021. Our continued 

aim is to have zero serious incidents. 

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Power  issues  remains  one  of  the  main  reasons  behind  the  increase  in  wastewater  category  3  incidents  that 

particularly impact sewage pumping stations (SPS). These are connected to incoming power supplies where power 

cuts or very small interruptions, often referred to as a ‘brown-out’, can cause significant issues to our powered 

sites.  Internal  power  issues  can  also  occasionally  affect  our  service.  We  continue  to  put  in  place  measures  to 

increase our power resilience, such as improved arrangements for generators and engagement with our power 

Distribution Network Operator (DNO) to address risks.  

Our  focus  is  on  continuous  improvement  in  pollution  performance  through  our  company-wide  zero-tolerance 

approach as set out in our published Pollution Incident Reduction Plan (PIRP). We constantly examine all aspects 

of  pollution  to  target  our  efforts  in  effectively  reducing  the  number  of  incidents.  In  doing  this,  we  share  our 

experiences and learn from others, such as through the industry Pollution Reduction Task Force and our innovation 

networks. An example of a recent innovation is the full deployment of a smart network management technology. 

This uses advanced machine language learning, together with hyperlocal rainfall forecasting, to accurately predict 

the normal performance of our assets and provide alerts of issues occurring. This increases our capability to detect 

these issues and respond to prevent pollutions from happening.  

For  our  water  assets,  there  were  21  category  3  pollutions  incidents  in  2022  that  were  mainly  from  our  supply 

network (20) with one incident from a water treatment works. These incidents typically involve a burst water main 

and chlorinated water impacting a nearby watercourse. Focus on raising standards in this area has included the 

completion  of  environmental  training  across  the  water  directorate,  deployment  of  new  innovative  mitigation 

measures and dispatch of strategically placed emergency response trailers.  

The EA expects that we will pro-actively ‘self-report’ at least 80% of all pollution incidents to it rather than rely on 

others to point out a problem. This is part of the package of pollution measures reported annually in the EPA. We 

consistently achieve high levels of self-reporting in surpassing the 80% requirement with continued improvement 

to 91% in 2022 compared with 89% in 2021 and 81% for 2020. From 2020 onwards, the EA also expects a self-

reporting level of 90% or more for sewage pumping stations (SPSs) and sewage treatment works (STWs). We 

achieved 92% self-reported in 2022 having previously attained 100% in 2021 and 2020. 

We remain an upper quartile company for pollution  incident performance and  are proud to have delivered zero 

serious pollutions incidents across all our assets and operations in 2022.  

Longer  term  our  performance  against  this  metric  remains  susceptible  to  external  factors  in  particular  weather 

events such as storms or flooding which are expected to increase in frequency due to climate change and which 

can disrupt the operation of our assets, particularly if they affect power supplies. Our PR24 Business Plan will set 

out  robust  proposals  to  address  this,  however  delivery  of  these  proposals  will  be  dependent  on  provision  of 

associated funding. 

Case study: Stormharvester – preventing pollution with help from AI  

We are always looking for ways to improve our processes and understand our network better. Working with industry 

specialists Stormharvester, we’ve harnessed machine learning and more than 1,300 sensors across our network 

to keep track of rainfall, make predictions and allow us to intervene to prevent spills.  

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Using more than 1,300 sensors across our assets - everything from storm tanks to pumping stations to manholes 

-  we’ve  been able  to collect  data  and  use hyperlocal  rainfall  forecasting  to  enable  us  to  increase our blockage 

detection and asset performance, while reducing spills, pollutions, and flood events.  

The system collects data form each sensor and machine learns the normal operating thresholds for that site, it can 

then recognise and highlight anomalies in near real time.  

In the first six months of operation, the project with Stormharvester alerted us to possible incidents which resulted 

in 110 teams being dispatched to investigate further, and 39 pollutions were avoided. 

Water Industry National Environment Programme (WINEP) - PR19NES_BES31 

Delivery  of  Water 
PR19NES_NEP01 

Industry  National  Environment  Programme  requirements  - 

These  are  two  bespoke  PCs  which  are  reputational  only  until  2025,  when  a  penalty  could  apply  for 

underperformance.  

Measured  by  the  cumulative  number  of  WINEP  schemes  completed  each  year  across  our  operating  areas 

(including both Northumbrian Water and Essex & Suffolk Water), it is limited to schemes that were confirmed on 1 

April 2019 within the WINEP and therefore had certain (green) status. Only sites signed off by the Environment 

Agency (EA) can count towards the measure.  

The  WINEP  is  a key part  of  the  overall  programme  of  measures  to meet  the  requirements  of  the  Environment 

Agency (EA)’s Water Industry Strategic Environmental Requirements (WISER) document. This includes objectives 

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to meet Water Framework Directive (WFD) ‘Good’ status in our rivers by 2027 and prevent deterioration in status, 

together  with  other  international  regulatory  drivers,  including  the  Urban  Wastewater  Treatment  (UWWT)  and 

Habitats Directives.  

The  EA  sets  an  expectation  in  its  WISER  guidance  that  companies  will  deliver  100%  of  the  environmental 

improvement  schemes  listed  in  WINEP.  All  our  forecasted  WINEP  deliverables  (post  accepted  changes)  for 

2022/23, have been completed for sign off. The agreed number of deliverables for year three (2022/23) was 111, 

we are pleased to say that these are all complete making the cumulative delivered 439. We are confident that we 

will deliver 100% of the schemes by the end of the five-year period.  

We  work  very  closely  with  our  local  EA  team  to  make  sure  we  have  a  common  understanding  of  the  specific 

requirements of our obligations, and to make sure the mitigation measures we implement will satisfy the WINEP’s 

environmental objectives. We have regular engagement with local EA representatives and provide information, as 

required to make sure we agree on key decisions throughout a scheme’s delivery cycle. A governance process 

has been agreed, based on an EA guidance document, to avoid late decisions on any changes to the obligations 

and in developing the evidence requirements for EA sign off on completion. These include procedures for Change 

Protocol and for WINEP measures sign off. 

Our targets for the first four years are reputational only, but if we should fail to complete the agreed total by 31 

March 2025, we would pay a financial penalty in 2024/25. The EA also reports WINEP delivery performance in its 

Environmental  Performance  Assessment  (EPA).  For  this  it uses  its  revised  delivery profile  and hence  the  EPA 

indicates that we are on track with WINEP delivery. 

The  measure  specifically  tracks  the  completion  of  the  required  schemes  in  each  year  and  Ofwat  specified 

performance  for  2022/23  will  be  reported  based  on  the  latest  WINEP  programme  on  31  March  2023,  and  the 

schemes delivered by this date. We have consistently delivered 100% of schemes since its introduction in 2011. 

OUTCOME 12: We take care to protect and improve the environment in everything we 
do, leading by example 

AMBITIOUS  GOAL:  Be  leading  in  the  sustainable  use of  natural  resources,  through 
achieving zero avoidable waste by 2025 and being carbon neutral by 2027 

• Greenhouse gas emissions – bespoke  

• Bioresources – bespoke 

Our ambition is to be the first water company to achieve Net Zero carbon emission by 2027 and we continue to 

remain on track to achieve this. 

Greenhouse gas emissions - PR19NES_BES21 

The chart below shows the reduction in our emissions compared to 2019/20 baseline figures.  

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This is a bespoke PC that incentives us to reduce greenhouse gas emissions arising from our operational activities. 

The baseline was re-calculated for 2019/20 using the newest carbon accounting workbook. 

This year we have reduced our operational emissions to just 23 thousand tonnes of CO2e – down from 69 thousand 

tonnes in 2019/20. 

This  is  a  small  increase  compared  to  last  year  –  the  company’s  high  performance  in  this  area  means  that 

maintaining performance at the current level is challenging. 

We have reduced emissions by: 

• 

Installing our first large scale solar arrays across 5 sites (with more planned in 2023). 

•  Being the first and are the only water company to use 100% of our sewage sludge to create energy (or 

power from poo), and we’ve enhanced our activities in energy creation further with the implementation 

our second Gas to Grid plant at Bran Sands. 

•  Using biomethane purchased through the market to reduce our reliance on natural gas. 

•  Continuing to be efficient in our travel – avoiding unnecessary journeys and travelling by public transport. 

•  Migrating our bioresources fleet onto HVO (a form of biodiesel) wherever possible. 

• 

Leading the industry with our offshore wind Power Purchase Agreement (PPA), which was the first of its 

type in the UK. This 10-year deal has us sourcing approximately 30% of our electricity demand from the 

Race bank offshore wind farm. 

•  Powering all sites using renewable electricity. 

•  Using electric vehicles wherever possible. 

We are on track to achieve zero avoidable waste by 2025. This will mean eliminating, re-using, or recycling 90% 

of our waste from operations, developing resource recovery technologies and working with partners to contribute 

to the circular economy in their regions. 

For our performance in this area, we are receiving a reward of £7.183M. 

Ofwat has asked us to re-verify previous year’s performance to ensure the ODI revenues have been fully reflective 

of our performance. We are confident our reporting has been good and accurate, but any identified historic issues 

may result in minor amendments to our in-year ODI performance. 

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2022/23 SWOT Analysis in Relation to Emissions Reporting and Performance 

Strengths 

Weaknesses 

•  With  respect  to  Market  Based  Reporting,  the 
timing of APR production and associated audit 
does not align perfectly with some aspects of 
the  timing  for  certification  for  market-based 
emissions (REGO and RGGO certificates) and 
assumptions  have  to  be  made  which  are 
reconciled/checked in future years. 

• 

The  latest  2022/23  audit  identified  a  minor 
correction  in  relation  to  emissions  associated 
with  grit  and  screenings  in  our  2019/20 
emissions which are now correctly categorised 
as  outsourced  activity,  so  this  has  now  been 
resolved. 

•  Validating  scope  3  emissions  in  long  and 
complex  supply  chains  remains  challenging. 
We 
could  be 
accelerated by sector wide sharing of reporting 
methodologies. 

improvements 

consider 

•  Positive audit report in relation to 2022/23 Scope 1,2 and 
mandatory  Scope  3  emissions  in  relation  to  both 
compliance  with  ISO  14064-1:2006  along  with  the 
Enviromark Solutions Carbon Reduce Programme. 

• 

The  Audit  Report  also  confirmed  a  data  quality 
assessment  of  “Good” in  relation  to  NWL’s  inventory  of 
emissions  and  that  excluded  emissions  did  not  exceed 
5% of NWL’s total footprint. 

•  Consistent  outperformance  of  our  GHG 

for 
operational  emissions.  Positive  recognition  from  our 
Water Forum (CCG) in relation to this. 

target 

• 

• 

The first company to use 100% of our sewage sludge to 
create  energy  via  advanced  anaerobic  digestion 
processes  (AAD)  before  all  sludge  being  beneficially 
recycled to land. 

100%  use  of  renewable  electricity,  including  the  first 
Power Purchase Agreement (PPA) for an offshore wind 
farm in the UK.  

•  Northumbrian  Water  has  an  embedded  and  mature 
approach  to  innovation  with  multiple  projects  in  our 
innovation  pipeline  that  could  aid  future  emissions 
reductions, 
treatment, 
including  algal  wastewater 
ammonia  recovery  and  real  time  power  emissions 
optimisation. 

Opportunities 

Threats 

• 

Further  certification  to  CEMARS  (Certified  Emissions 
Measurement  and  Reduction  Scheme)  would  further 
strengthen our reporting. 

•  We consider there is greater opportunity for future sector 
reporting  to  allow  greater  recognition  of  carbon  offsets 
(and  insets)  where  these  have  a  high  confidence  of 
emissions reductions and assured benefits. 

•  Similarly,  there  is  scope  to  strengthen  incentives  on 
companies to innovate by using actual emissions factors 
associated  with  purchased  electricity  in  future  reporting 
rather  than  grid  average  factors  –  which  reduces  the 
scope  for  innovation.  A  similar  principle  applies  to 
chemical purchases. 

• 

Industry reporting capability – via the Carbon Accounting 
Workbook  –  is  continually  improving  and  there  is  an 
opportunity  to  reflect  this  in  company  reporting  by 
permitting  use  of  the  latest  available  version  of  the 
workbook in each reporting year. 

•  Continual improvement in the science and measurement 
identify  areas  where  emissions 

of  emissions  may 
reduction efforts need to be concentrated. 

from 

international  standards 

•  Possible  future  divergence  of  water  industry 
reporting 
for 
carbon  reporting/accounting  may  introduce 
unnecessary  complexity  along  with  market 
distortions  which  may  reduce  customer  and 
environmental benefit.1 

• 

intensive) 

There is a natural tension between the desire 
to  reduce  emissions  and  the  need  to  comply 
with  ever  more  stringent  (and  hence  more 
energy 
treatment  standards  – 
particularly wastewater treatment standards as 
Industry  National 
driven  by 
Environment  Programme 
In 
(WINEP). 
particular,  this  needs  to  be  recognised  and 
resolved 
in  some  way  when  baseline 
performance  is  established  against  which 
future reductions are assessed. 

the  Water 

1 As per our response to Ofwat dated 6/3/2023 re PR24 operational greenhouse gas emissions PC definitions  

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Case study: Emission Possible - Solar 

As part of our ambitious target to reach Net Zero by 2027, we’re installing solar arrays at treatment works across 

our operating areas. Not only does this make help us reduce our carbon footprint, but it also makes our network 

more resilient. Water and wastewater treatment are energy intensive activities, and solar power helps us generate 

green  energy  and  reduce  our  carbon  output  while  we  also  explore  innovative  ways  to  reduce  our  energy 

consumption overall. 

In 2022, we took a big step forward in our pursuit of Net Zero by 2027. Most notably an array of 3,600 solar panels 

was  installed  at  Lumley  Water  Treatment  Works  in  Co.  Durham  -  the  first  of  six  sites,  including  Sedgeletch, 

Billingham, Newton Aycliffe, Broken Scar and Blyth. There is also Bran Sands, where our Green Power Station 

has added solar power to existing Green Gas production. 

Bioresources - PR19NES_BES22 

We have achieved this PC.  

This bespoke PC is reputational only. The measure for bioresources performance is the percentage of sewage 

sludge treated and converted to biosolids at one of our two Advanced Anaerobic Digestion (AAD) sites and the 

percentage of biosolids that are beneficially recycled to land.  

Our  performance  has  remained  at  100%  achievement,  therefore  maintaining  our  industry  leading  performance 

which was first achieved as early as 2014/15. 

We  continue  to  lead  the  sector  as  the  most  efficient  company  in  this  area  driving  innovation  and  operational 

excellence. 

Key enablers in continually delivering this leading status have been:  

•  Continued  optimisation  of  two  strategically  located  AAD  treatment  centres  accommodating  all  of  our  sludge 

volumes. 

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• Harnessing the opportunity of upgrading biogas generated by the AAD process to biomethane, and injection into 

the natural gas grid at both sites.  

• An efficient logistics strategy encompassing a network of six sludge handling centres throughout the region and 

onward transportation of sludge cake to one of our two AAD sludge treatment centres.  

• Final nutrient rich biosolids recycled safely and beneficially to agriculture under the Biosolids Assurance Scheme 

(BAS). 

The  continued  deployment  of  our  biosolids  to  the  region’s  agricultural  land  provides  plant  nutrients  including 

phosphate, nitrogen and sulphur.  

The use of biosolids continues to offer farmers an economically viable fertiliser alternative which has a considerable 

benefit in carbon footprint reduction compared to manufactured providers.  

We continue to lead the sector being the only Water and Sewage Company (WaSC) that processes 100% of sludge 

through AAD operations then allowing 100% of the final biosolids to be deployed to the region’s landbank.  

Throughout 2020-25 the level of regulatory uncertainty has increased potentially impacting on our current, future 

and long-term strategic operating models. These current uncertainties include the final positioning of the pending 

Environment Agency (EA) Sludge Strategy, future interpretations of the Farming Rules for Water (FRfW) and the 

potential of considerable reductions in landbank availability. 

The sector continues to collaborate in understanding the likely impact of future regulatory changes whilst actively 

seeking improvements in efficiencies. This is reflected in Ofwat’s publication of the Bid Assessment Framework 

(BAF) which promotes the trading of sludge between companies to the benefit of customers in terms of affordability 

efficiencies.  

We have proactively used this mechanism to formally approach both United Utilities and Yorkshire Water to offer 

our services to deliver efficiencies while initiating discussions with other WaSCs. 

To support this collaborative philosophy we are also a key partner in the Innovation in Water Challenge - Unlocking 

bioresource market growth using a collaborative decision support tool. 

This project in collaboration with Anglian Water (main sponsor), Thames Water and Yorkshire Water (key partners) 

aims to provide WaSCs with the support necessary to overcome existing barriers and unlock the benefits of market 

collaboration by integrating into a single decision support platform. 

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AMBITIOUS GOAL: Demonstrate leadership in catchment management to enhance natural 
capital and deliver net gain for biodiversity 

• Water environment improvements – bespoke  

Water environment improvements - PR19NES_BES20 

- 

We have achieved this PC. This is a bespoke measure.  

This is the second full year of our programme following feasibility work in 2020/21, and the third year of reporting 

for the ODI.  

Linking improvements to public access is an innovative partnership approach to investing in the environment. All 

water environments are in scope, including lakes and reservoirs, streams and rivers, canals, wetlands, coasts, and 

beaches. Improvements must cover at least two out of three aspects of access and recreational facilities, wildlife 

and biodiversity, and water quality, and must include elements above our regulatory obligations. 

This year, we have continued to outperform our performance commitment of 10 km, achieving 39.3 km of water 

environment improvements through delivery of 15 partnership projects across our NW and ESW operating areas. 

We also have a further 25.3 km of projects in delivery in year three which will be signed off in future years.  

In  total  through  the  first  three  years  of  the  2020-25  Business  Plan,  we  have  improved  circa  100km  of  water 

environment for our customers in our regions.  

We  have  continued  to  work  closely  with  the  Water  Environment  Governance  Group  (WEGG),  an  independent 

group made up of external expert stakeholders who are passionate about improving the environment. The WEGG 

helps steer our activity and approves and signs off projects against the ODI.  

Our Bluespaces funding scheme which provides the platform for developing and delivering partnership projects to 

support this is working well, and we have a further 18 partnership projects approved in the pipeline for years four 

and five.  

We will receive a reward of £0.177m for our performance this year.  

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We committed to reinvest at least 50% of any reward received above costs in new water environment projects. For 

years four and five, we will continue to invest towards meeting our internal target of 248 km improvements by 2025. 

The level of investment annually will be substantially above the 50% reward reinvestment level we committed to. 

In  2022-23,  we  have  invested  £200,000  in  water  environment  improvements,  including  in  staff  resources  and 

investment in projects.  

This  year,  we have also been  developing our  ambition  for  the  future  through  business  planning,  engaging  with 

partners and stakeholders to plan for the water environment improvements that could be achieved in our regions 

from  2025-30,  and  engaging  with  the  Environment  Agency  and  Ofwat  on  the  best  way  to  include  Bluespaces 

improvement schemes in our Business Plan.  

The 2022/23 Governance Statement from Richard Powell OBE, Chair of the WEGG, demonstrates that we have 

addressed Ofwat’s specific reporting and assurance requirements for this ODI. More detail can be found on the 

Water Environment Governance Group pages on our website. 

Case study – Bluespaces activity - Delivering 250km of water environment 
improvements 

In 2022/23 we worked to improve bluespaces in more than 20 locations across our operating areas. This included 

path improvements at Holywell Dene, fish and dormouse conservation at Roman River and Layer Brook, wetland 

creation at Longdike Burn, stream and beach cleans at Limekiln Gill, and waymarking improvement at RSPB North 

Warren. 

This work is supported and externally assured by our Water Environment Governance Group, whose independent 

members include an academic, The Rivers Trust and the Environment Agency. 

Our bluespaces improvement projects must make a difference to a site in at least two of the following areas: access, 

facilities and recreation; wildlife and biodiversity; water quality. We anticipate investing around £1m over the five 

years of our Business Plan for 2020-25 to support partner projects to improve water environments. 

CATCHMENT MANAGEMENT  

Catchment management covers the whole water cycle and links across our water, wastewater, and conservation 

activities. We carry out catchment activities across our own network and assets, and in partnership with others, 

working  to  influence  and  to  make  shared  decisions  to  improve  the  environment  and  showing  leadership  in 

integrated catchment management. Our goal is to demonstrate leadership in catchment management to enhance 

natural capital and deliver net gain for biodiversity. 

In the areas upstream of our drinking water sources we work with farmers, land managers and other stakeholders 

to address the risks to good water quality. We do this through raising awareness about pollution risks and providing 

grants to support changes where needed. For example, our Field to Tap scheme offers grants to farmers and land 

managers for equipment or land-use changes that will reduce the risk of diffuse or direct pollution to rivers and 

reservoirs. We also support wider environmental improvements through partners, such as peatland restoration, 

and  we  are  leading  on  two  holistic  catchment  improvements  projects  in  the  South  Tyne  (NW)  and  Blackwater 

(ESW) catchments, which focus on improving river habitat and biodiversity to support good water quality. 

During 2022/23 we delivered the following:  

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Field to Tap – farm advice and grants programme: 

• 

• 

Advisory visits to 29 new farms and follow-up visits to farms where we had previously offered grants.   

47  grants  were  offered;  £297,430  of  grant  funding  was  paid  to  farmers  in  our  highest  risk  areas  with 

farmers matching our grant with an equal contribution towards the improvements/changes. A further £134,723 in 

grant funding has been agreed and will be paid when the farmer completes the work. Grants were for on-farm 

interventions such as clean and dirty water separation, muck storage, pesticide handling areas, bunded pesticide 

storage, cover crops, precision spraying equipment, rainwater harvesting equipment, and soils assessments. Over 

95% of our offered grants were completed. 

• 

Our Catchment Advisors attended 44 events, from local farmer groups to catchment partnership meetings, 

to talk about the risks of catchment activities to raw water quality. They helped organise and sponsored the Farm 

Business Update events in our catchments in Essex and Suffolk, and organised and sponsored three Farm Update 

North events in the North East. These events signpost farmers to opportunities for environmental improvements 

and grants from a wide range of organisations and Government.   

South Tyne and Blackwater Holistic Water Management Projects: 

• 

Seven partner projects have been supported to deliver biodiversity and river habitat improvements through 

partnerships; in all cases the grant applicants had secured additional funding, effectively leveraging our financial 

support into delivering larger projects to benefit the wider environment. Partnership meetings have been held, as 

well as site visits to view the river restoration work that has been carried out to date.   

• 

On  the  River  Blackwater  the  holistic  project  has  been  tied  in  with  farmer  engagement  and  the 

establishment  of a  cluster  group  on  the  River  Pant,  a  tributary  of  the  Blackwater system.  We  are  working  with 

partners to develop a river restoration plan for the Blackwater, from which we may be able to develop projects for 

further  support  during  2020-25,  but  that  will  also  build  foundations  for  future  river  habitat  and  biodiversity 

improvements across the catchment. 

• 

On the South Tyne we plan to carry out direct farmer engagement during 2020-25 to identify opportunities 

for river restoration, as well as continuing our leadership of the South Tyne Catchment Partnership, a subgroup of 

the highly successful CaBa Tyne Catchment Partnership.   

Peatland Restoration 

• 

In 2022/23 we paid our final tranche of £100,000 of funding to the Peatscapes Partnership to support peat 

restoration as part of the Tees-Swale project, addressing issues of colour in our raw water sources in the Tees 

catchment.  This brings our total funding of peatland restoration during 2020-25 to £300,000, which the Peatland 

Partnership has leveraged into a much bigger investment in peatland restoration across the North Pennines. 

Berwick Nitrates Investigation and Field Trials 

• 

The WINEP Investigation into rising nitrates in our groundwater sources in the Berwick area required us 

to look at both catchment management interventions and the underlying hydrogeology to improve our knowledge 

of the nitrate issue and better understand the actions that could be taken to prevent further deterioration.  

• 

We engaged with farmers in the geographic catchment overlying the aquifer and trialled a range of on 

farm interventions to help change behaviour around nutrient applications and to improve Nitrogen Use Efficiency 

(NUE) in the catchment. Although the investigation has now concluded we continue to engage with farmers across 

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the catchment and are working on developing a farmer-led support group to continue the discussion around best 

practice to minimise nitrate inputs to groundwater.   

Case study – Branch Out - Delivering benefits for our natural environment 

Our Branch Out fund supports projects which deliver benefits for our natural environment, build resilience for wildlife 

and reconnect the public with the habitats around them. As well as the main Branch Out fund awarding grants of 

up to £25,000, we also have funds aimed at Invasive Non-Native Species and Priority Habitats. 

Our Branch Out fund supports projects which bring benefits to water, wildlife and communities. Through the fund, 

we  enable  local communities to  take  action  which  can make  a  difference  to  the  natural  environment  within our 

operating areas, because a healthy environment is crucial to top quality drinking water. 

The joy of our Branch Out, Invasive Non-Native Species and Priority Habitat funds is that every project is different. 

That variety is in evidence in some of the projects we’ve supported in the past year. 

We’ve  provided  a  £9,000  grant  to  help  fund  new  gardens  at  the  Locomotion  railway  museum  in  Shildon, 

encouraging the flora and fauna commonly found on railway embankments, planting new native hedgerows and 

habitats for hedgehogs and bats. 

A £2,000 grant has helped enhance the Gosforth Nature Reserve - one of the oldest in the North East, founded in 

1929. The support from the Branch Out fund helps increase biodiversity through wildflower planting and woodland 

habitat enhancements, as part of a project which also replaced a nesting platform for common terns. 

The Wear Rivers Trust received two grant awards totalling £32,000, which will support a project tackling Invasive 

Non-Native Species along the River Wear, as well as a specific effort to manage and treat Giant Hogweed as part 

of a project called ‘Old Durham Beck Renewed’. 

These  projects,  and  others  like  them  improve  habitats  and  make  our  natural  environment  safer  and  more 

accessible. 

THEME SIX: BUILDING SUCCESSFUL ECONOMIES IN OUR REGIONS 

OUTCOME 13: We are proud to support our communities by giving time and resources to 
their important causes  

AMBITIOUS GOAL: Be the most socially responsible water company 

Our responsible business practices have again been recognised through significant external accreditations over 

the past year.  

We were named on the World’s Most Ethical Companies list, compiled by Ethisphere, for the 12th time – one of 

only two UK companies, and the only water and sewerage company in the world to be named in the list. This is 

based on information requested by Ethisphere on issues including environmental sustainability, governance and 

social responsibility, which is judged against set criteria and benchmarked against companies around the world. 

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For the second successive year, we were the only water company awarded the Good Business Charter, supported 

by the Confederation of British Industry and the Trades Union Congress. This involves demonstrating good practice 

against  a  series  of  key  components,  including  employment  practices,  environmental  responsibility,  fair  tax  and 

procurement. 

We also again continued to meet our long-standing commitment to reinvest at least 1% of our profits in community 

activities. 

During 2022/23 we have moved forward with implementation of our community investment strategy, aided by the 

removal of Covid restrictions enabling the re-starting of events and engagement activities. 

Our strategy is focused on three areas where we believe we should take lead in our communities because they 

are central to our Purpose. We deliver community investment activity in these areas through financial contributions, 

volunteering  (including  our  Just  an  Hour  scheme  through  which  38%  of  our  employees  supported  297  good 

causes), education impact, and playing a leadership role. 

Our key areas of focus are: 

Ending Water Poverty – alongside our action detailed elsewhere in this report, we supported this goal through 

backing  a  series of  Christmas  appeals in our  operating areas  – Mission  Christmas in Tyneside,  Kids  Inspire  in 

Essex and Winter Wonderland in Suffolk. Across the year we volunteered for food and clothing banks, and made 

donations to PACT House, Zoe’s Place, Consett Community Trust in our northern operating area and Hope House, 

Kids Inspire and Home Start in our southern area. 

Water for Health – our Powered By Water schools programme went from strength to strength in 2022/23, delivering 

hydration  messages  to  10,233  children,  and  introducing  the  course  to  visitors  to  the  community  museums  we 

support at Museum of Power in Langford, Essex, and Tees Cottage in Darlington. We also successfully launched 

new fundraising events for WaterAid including a football tournament and fun run. 

Protecting the Water Environment – we extended training on our Water Ranger citizen science programme for 

a series of community groups in our coastal areas - Marske Litter Action, Seascapes beach volunteers, Tees Valley 

Wildlife Trust, Saltburn Countryside Volunteers and the Friends of the Lower Path. We also played a key role in 

the launch of a new partnership initiative, Net Zero North East England, which is co-chaired by our chief executive 

Heidi Mottram and brings together cross-sectoral activity to reduce emissions in our North East region. 

Looking  ahead  we  have  agreed sponsorship and  begun  to  promote  two  major  charity  appeals  in  our  operating 

areas taking place in summer 2023 – the Shaun the Sheep trail supporting St Oswald’s Hospice in Newcastle, and 

‘Herd in the  City’ supporting Havens  Hospices in  Southend.  We  will use  these  as opportunities  to  promote our 

messages about sustainable water use, particularly to school students. 

We  continue  to  hold  a  number  of  accreditations  that  demonstrate  our  commitment  to  responsible  business 

practices, including: 

• 

• 

ISO 14001 Environmental Management 

ISO 15001 Asset Management 

•  BITC Responsible Business Tracker  – which showed us to be leading in our cohort for Governance & 

transparency, Supply chain, Digital transformation and Nature stewardship 

•  BSI for inclusive services 

• 

Living Wage employer 

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•  Disability Confident employer 

Case study – Community Investment Programme - Supporting childrens’ sport and 
their health 

Through  our  Powered  by  Water  programme,  we’ve  sponsored  Newcastle  Eagles’  Hoops4Health  tournament, 

encouraging teams from schools across Northumberland and Tyne and Wear to take part, get active, and learn 

about the benefits of staying hydrated. 

We have long played an active role in the community, including as founder members of WaterAid as far back as 

1981. 

Last  year  we combined our  fundraising  efforts on behalf  of WaterAid  with our  Powered  by  Water  programme’s 

sponsorship  of  the  Newcastle  Eagles  Hoops4Health  tournament  -  part  of  a  longstanding  partnership  with  the 

Eagles. That tournament sees more than 4,000 schoolchildren from across Northumberland and Tyne and Wear 

compete  in  a  series  of  basketball  tournaments,  culminating  in  a  final  day  where  250  children  from  the  best 

performing teams met at the Vertu Arena, home of Newcastle Eagles. 

While our Powered by Water programme sponsored the Hoops4Health tournament, on that final day we joined 

forces with the Newcastle Eagles Community Foundation to raise hundreds of pounds for WaterAid. 

Powered  by  Water  is  our educational  programme  which  teaches children  about  the benefits  and  importance  of 

staying hydrated, while WaterAid focuses on getting clean water and sanitation to the millions of people around the 

world who lack access to that basic human right. 

Sam Blake, CEO of the Newcastle Eagles Community Foundation said: “We have a mutually beneficial relationship 

with  the  Powered  by  Water  team  that  grows  stronger  year  on  year.  “It’s  been  a  pleasure  to  work  alongside 

Northumbrian Water and support WaterAid as they campaign for clean water for all — something most of us take 

for granted.” 

Our  Corporate  Affairs  Director,  Louise  Hunter  said:  “We  are  proud  of  our  longstanding  partnership  with  the 

Newcastle Eagles, who along with our other partners help us teach tens of thousands of youngsters every year 

about the importance for water for health.” 

OUTCOME 14: We work in partnership with companies and organisations to achieve the 
goals that are most important to our customers  

AMBITIOUS GOAL: Spend at least 60p in every £1 with suppliers in our regions 

We have achieved this PC. After making strong and sustained progress since 2017/18 we are delighted to have 

surpassed this target again over the past year, with local spending in 2022 at 62.60%. 

As  one  the  largest  businesses  in  the  regions  where  we  operate,  and  in  keeping  with  our  commitment  to  our 

communities, we believe it is important to maximise the positive impact of our spending. We therefore prioritise 

working with a supply chain that upholds our social, economic, and environmental standards and shares our vision 

of continuous improvement. 

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To calculate our local procurement spending, we established a baseline by defining local procurement and mapping 

suppliers to local and non-local categories. We define ‘local spend’ as spending with suppliers with a postcode that 

falls within its operating areas. This is based on the ‘pay site’ defined on the supplier’s invoices.  

In  calculating  local  procurement  expenditure,  we  include  both  capex  and  opex,  but  exclude  certain  spend 

categories,  such  as  power,  banking  payments  and  inter-company  payments.  Excluding  these  items  removes 

approximately 20% of total expenditure.  

For  smaller  companies,  the  invoice  location  is  generally  near  where  the  company  is  based  and  where  their 

employees  work  and  live.  However,  for  companies  operating  over  larger  geographical  areas,  using  invoice 

postcodes is less effective. Examples include temporary staffing contractors and capital framework partners who 

have a head office out of our regions but source our requirements from our local areas. To address this, a manual 

adjustment is made to better reflect where their employees work and live. 

In the last year we updated our Responsible Procurement Strategy, through which we have developed the ‘Impact 

Initiative  7’.  This  sets  out  a  series  of  key  activities  within  seven  key  initiatives,  which  we  believe  will  make  the 

biggest positive difference when sourcing goods and services. 

As  part  of this,  to  enable  us  to  achieve  the strategy’s  outcome to  protect  relationships with  local  suppliers  and 

continue to create awareness and opportunities, we have identified four key activities: 

• 

Maintain 60p in every £1 of supply chain spend with local businesses in our operating regions in the North 

East, Essex and Suffolk. 

• 

Build and maintain external relationships with local organisations to offer business mentoring and provide 

meet the buyer events. 

• 

Provide  a  pipeline  of  tendering  opportunities  on  our  website  and  use  social  media  platforms  such  as 

LinkedIn to alert businesses of upcoming opportunities. 

• 

Membership  of  the  County  Durham  Pound  –a  collaborative  group  of  local  partners  who  seek  to  work 

together  to  increase  collective  local  spending,  create  business  Opportunities  for  local  SMEs,  VCSEs  and other 

local businesses. 

Several actions over the past year have helped to get us to this level: 

• 

Targeted local supplier engagement at ‘Meet the Buyer’ events such as the chamber of commerce expo 

and Business Durham, to enable local suppliers to gained insights and access to opportunities.  

• 

We relaunched our ‘Procurement in the Community’ educational pack designed for local SME’s to inform 

them about the procurement process and wider Utility procurement. 

• 

We have established a great network with other North East organisations through the County Durham 

Pound group who have similar same goals and challenges to us regarding local spend and social value. This will 

assist us with spend analysis to show leakage outside of the local area and where new opportunities lie. 

Our focus now will be on at least maintaining this level until 2025 and beyond and considering how we can do more 

to make sure the economic benefit of this spending is as big as possible. 

As a responsible employer, we play an important role in the success of our local economies in our three operating 

regions, North East, Essex and Suffolk. Spending more money in our own economy will benefit our businesses, 

14 July 2023 
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protect,  and  create  local  jobs  which  in  turn  will  result  in  more  money  being  spent  in  the  local  areas  and  their 

economies will grow as a result. Without a robust local procurement strategy, we risk not realising the benefits of 

a strong local economy, the diverse chain it can create and ultimately revenue may reduce if unemployment rises, 

and our customers struggle to pay utility bills. 

Over the last six months of 2022, as part of the County Durham pound group, we have started to measure the 

social and local economic value to the Durham region. We have currently recorded £4.9m local spend within the 

county Durham region. Out of the 12 partners in the county Durham pound group, only seven of them are currently 

reporting on local spend and we are currently spending the highest in the region.  

To make sure we continue to improve building successful economies in our region(s) we have identified actions: 

a) 

Improve / promotion with our supplier partners to ‘cascade’ our approach to local spend. Encourage our 

Tier 1 Capex partners to ‘think local’ as part of their delivery model. 

b) 

Ensure the local supply chain is engaged at procurement strategy development. For example, can larger 

contracts / requirements be split into Lots to provide opportunity for local SME’s (where commercially viable) who 

may struggle to deliver the full work package. This may also drive innovation / new ideas. 

c) 

Continue  to  engage  with  Durham  County  Family  to  deliver  social  value  benefits  in  our  regions  where 

possible through our supply chains. 

We will also continue to engage in local supply chain and wider community. We will look at how technology can 

support us to continue to be visible.   

We have established a great network with other North East organisations through the Durham County Pound group 

which has the same goals and challenges as ourselves in terms of local spend and social value commitments. We 

continue to work with the group which has secured funding for its members to have access to support into 2023, 

to continuing reporting on social value and spend analysis to show leakage outside of the local area and where 

new opportunities lie.  

Case study: Local Spend / Social Value  

We’re proud to spend more than 60p in every £1 locally, working with a supply chain which helps uphold our social, 

economic and environmental standards. We’re working to maximise the impact of that local  spend and open up 

more opportunities for local SMEs to work with us. 

As one of the largest businesses in the regions we operate in, we know our spending power can have a positive 

impact on our local economies.  

We have analysed the impact this had in our local economy. This showed £138.9m was estimated to have been 

re-spent across our operating area by our suppliers on local employees and the local supply chain in 2022/23, and 

of that £51.1m was spent on employing local people. 

Our  suppliers  created  2,131  jobs  and  239  apprenticeships,  supported  by  their  contracts  with  us,  and  donated 
72,694 hours of community volunteering. 

Over the past few years, we’ve worked hard to develop, and widen, these relationships, including working closely 

with external organisations to reach new audiences with our procurement opportunities. 

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Two  examples  are  our  work  with  North  East  England  Chamber  of  Commerce  and  Business  Durham  in  our 

Northumbrian  Water  operating  area,  where  ‘Meet  the  Buyer’  events  have  allowed  targeted  local  supplier 

engagement, sharing insight into our buying and access to opportunities. 

We’ve also relaunched our ‘Procurement in the Community’ educational pack, which is designed to help local SMEs 

understand our procurement process, and that of the wider utility sector. 

Through our engagement with our local business communities, we’ve found broad support and a great appetite for 

action amongst our peers - an example is the County Durham Pound group of likeminded businesses, who share 

similar goals and work collectively to improve local spend and social value. 

That  group  -  which  consists  of  11  companies  and  public  sector  organisations  working  in  Co.  Durham  -  has 

contributed more than £320m of social value in its first year. 

All  this  work  combines  into  our  responsible  procurement  strategy,  which  aligns  to  the  UN’s  Sustainable 

Development Goals and outlines what we call the ‘Impact Initiative 7’ (ii7). 

The ii7 sets key activities within seven areas - environment, local spend, diversity, skills, innovation, social value 

and modern slavery - which will help us, and our supply chain have the biggest possible positive impact. 

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REGULATORY ACCOUNTING STATEMENTS 

& 

ADDITIONAL REGULATORY INFORMATION 

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DIRECTORS’ RESPONSIBILITIES AND DECLARATIONS 

for the year ended 31 March 2023 

CONDITION F – REGULATORY ACCOUNTING STATEMENTS 

The  Directors are  responsible  under  Condition  F  of the Instrument  of  Appointment  granted  by  the  Secretary  of 

State for the Environment to the Company as a water and sewerage undertaker under the Water Industry Act 1991 

for: 

• 

ensuring that appropriate accounting records are maintained by the Appointee which are consistent with the 

Regulatory Accounting Guidelines published by Ofwat; 

• 

preparing a set of regulatory accounting statements each financial year in accordance with the Regulatory 

Accounting Guidelines; and 

• 

complying with all other requirements set out in the Regulatory Accounting Guidelines. 

RISK AND COMPLIANCE STATEMENT 

The Board confirms that: 

• 

it  considers  the  Company  has  full  understanding  of,  and  is  meeting,  all  its  relevant  statutory,  licence  and 

regulatory obligations and has taken steps to understand and meet customer expectations; 

• 

it has satisfied itself that the Company has sufficient processes and internal systems of control to fully meet its 

obligations; and 

• 

the Company has appropriate systems and processes in place to allow it to identify, manage, mitigate and 

review its risks. 

Ongoing compliance with our obligations in future will be dependent in particular on: 

• 

successfully securing adequate/sustainable funding levels for capital maintenance in order to maintain asset 

health in the medium and long term; 

• 

securing funding to allow sufficient investment in climate adaptation, to protect our services from deteriorating 

climate trends and increased prevalence of severe weather events; and 

• 

given the substantial uplift in investment requirements from AMP8 onwards, successfully concluding work to 

secure the deliverability and financeability of our PR24 business plan. 

As stated above the Board has concluded that it has a full understanding of the Company’s statutory obligations 

and  can  confirm  that  these  have  been  materially  met.  However,  the  table  below  reports  departures  which  are 

included for transparency.  

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Legislation 

Duty 

Detail of departure 

Environmental 
Permitting 
England and 
Wales – 
Regulation 12 

Compliance with 
Environmental 
Permits 

As for last year, the Board notes that the Company continues to comply fully 
with the Ofwat and EA investigations into environmental permit compliance in 
relation to flow to full treatment at wastewater treatment works, and was 
disappointed to identify potential non-compliance at four smaller sites. 

Water Resources 
Act 1991 – 
Section 24a 

Abstraction 
Licences 

Water Industry Act 
1991 – Section 68 

Duties of water 
undertakers and 
water supply 
licensees with 
respect to water 
quality 

Water Industry Act 
1991 – Section 
199 

Sewer maps 

Water Supply – 
Water Quality 
Regulations – 
Regulation 29 

Water treatment 
to minimise 
contamination 
from pipes 

These sites have now been remediated. Quarterly updates for stakeholders 
are provided on our web site. 

We marginally exceeded the Redgrave Group annual licensed quantity due to 
elevated non-household demand. This increasing trend is driving new 
schemes in our revised draft WRMP24.  A moratorium on new non-domestic 
demand is in place to reduce the risk of further or greater exceedances. 

A new Rickinghall WTWs (in supply April 2024) will also reduce the risk of 
further exceedances. 

NWL records approximately 100 compliance sample fails per annum as part 
of regulatory monitoring. Whilst every effort is made to mitigate any non-
compliances and prevent them from re-occurring, the response is sometimes 
not immediate and requires capital investment. An example is an iron failure 
linked to deterioration of the supplying distribution main. Until remedial action 
is complete, the reference to wholesomeness cannot be claimed within the 
year of sampling. This scenario currently applies to around 5-10% of the 2022 
water quality programme. 

In addition, NWL is part way through a transformation programme agreed 
with DWI around water treatment and service reservoir and tower asset 
health, and discharge from associated legal notices is not expected to be 
achieved until end of AMP8. 

In common with other wastewater companies in England and Wales not all 
sewers are mapped, in particular those that were transferred assets from 
local authorities.  Records are updated regularly to reflect any changes 
identified in sewer locations or attributes but the cost of full surveys of all 
sewer assets is generally deemed to be uneconomic. 

We model lead risk across all supply areas annually and set treatment targets 
for phosphate accordingly. We don’t dose phosphate everywhere. The 
reason for the departure is that we only take a limited set of lead samples 
every year (compliance and operational) to inform our models and risk 
assessment, but we know that there are over 500k lead communication pipes 
(company-owned) and a likely equivalent of customer lead supply pipes still 
in existence. Phosphate treatment has performed well but is not a long term 
sustainable solution to the lead risk. 

The only long term solution is to remove lead piping entirely from supplies. 
This needs an integrated, multi-stakeholder approach that extends beyond 
the water sector. 

We have plans to reduce lead piping in both AMP8 and our Long-Term 
Delivery Strategy.  

Water Supply – 
Water Quality 
Regulations – 
Regulation 31 

Application and 
introduction of 
substances and 
products 

The requirements of Reg 31 are understood and applied internally, but the 
knowledge of applicable products and their associated instructions for use 
(IFU) are shown to be inconsistent across the supply chain. This has led to 
further internal risk assessments on products used, and even aborted work. 

This situation is not unique to NWL and is recognised quite broadly across 
the water sector. NWL is helping to lead on a new scheme supported by the 
Energy and Utilities Skills Register to create a standard training course 
equivalent to the national Water Hygiene Card to make sure all employees 
(internal and supply chain) who would need Reg 31 awareness are deemed 
competent and hold evidence to demonstrate it. 

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DISCLOSURE OF INFORMATION TO AUDITORS 

So far as each current Director is aware, there is no relevant audit information of which the Company’s auditor is 

unaware and each Director has taken all the steps that he or she ought to have taken as a Director in order to 

make  himself  or  herself aware  of any  relevant  audit  information  and  to establish  that  the  Company’s auditor is 

aware of that information. 

CONDITION P (Ring-fencing Certificate) 

As  required  by  Condition  P  of  our  Licence,  the  Board  has  provided  this  ring-fencing  certificate  to  Ofwat  in 

accordance with the requirements and expectations set out in Information Notice IN 20/01. 

The Directors certify that, in their opinion: 

• 

the Appointee will have available to it sufficient financial resources and facilities to enable it to carry out, for at 

least the next 12 months, its Regulated Activities (including the investment programme necessary to fulfil the 

Appointee’s obligations under the Appointment); 

• 

the Appointee will, for at least the next 12 months, have available to it management resources and systems of 

planning and internal control which are sufficient to enable it to carry out its Regulated Activities; 

• 

the Appointee has available to it sufficient rights and resources, other than financial resources, to enable a 

special  administrator  to  manage  the  affairs,  business  and  property  of  the  Appointee,  should  a  special 

administration order be made; and 

• 

all contracts entered into with any Associated Company include all necessary provisions and requirements 

concerning  the standard  of  service  to be  supplied  to  the  Appointee,  to  ensure  that  it  is able  to  meet  all  its 

obligations as a water and sewerage undertaker. 

In providing this certificate, the Directors have considered the following main factors: 

Financial resources and facilities: 

• 

the financial strength of the  Company at the balance sheet date and financial performance, which is in line 

with expectations and reviewed at each Board meeting, most recently in July 2023; 

• 

• 

the key financial ratios over the next 12 month planning horizon, as reflected in investment grade credit ratings; 

the fact that the Company has in place £450m of committed bank facilities as back up liquidity, maturing in 

December 2025, which was undrawn at 31 March 2023; 

• 

the  Treasury  Strategy  approved  by  the  Board  in  April  2022  and  the  subsequent  establishment  of  a  £6bn 

European Medium Term Note (EMTN) programme which enables the Company to raise new financing in a 

timely manner as required; and 

• 

the Directors assessment that the Company should be able to manage its business risks, continue to operate 

and meet its liabilities as they fall due over the seven years to March 2030, reported in the viability statement. 

Management resources 

• 

the balance and effective operation of the Board, on which Independent Non-executive Directors (INEDs) are 

the  largest  group,  as  described  in  the  Corporate  Governance  report  in  our  Annual  Report  and  Financial 

Statements; 

• 

the work of the Nomination Committee for the appointment of senior positions; 

14 July 2023 
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• 

• 

the experience and broad-ranging skills and experience of the INEDs and Executive Leadership Team; 

the engagement of staff, demonstrated by the 87% response rate to our annual Great Place to Work survey, 

and award of Great Place to Work Certified Employer Status again; 

• 

the  further  development  and  embedding  of  our  Inclusion  and  Diversity  Strategy  called  TIDE  (Together  for 

Inclusion, Diversity and Equity). 

Systems of planning and internal control 

• 

the  Company’s  formal  governance  and  risk  management  arrangements  which  are  monitored  by  the  Audit 

Committee, Risk & Compliance sub-committee and Board. 

• 

the work of the Board and its Committees to monitor the risk and control systems throughout the year, including 

conducting a robust assessment of principal risks and an annual review of the effectiveness of the Company’s 

risk management and internal control systems, oversight of the work carried out by external auditor, internal 

audit  and  other  assurance  providers,  and  monitoring  compliance  with  procedures  to  prevent  bribery  and 

receiving reports on any whistleblowing allegations; 

• 

the monitoring and review throughout the year of the principal risks and uncertainties facing the business by 

the Risk & Compliance Sub-committee; 

• 

the Company’s robust business continuity arrangements. 

Rights and resources other than financial resources 

• 

the Company’s business model comprising its Purpose, Vision, Strategic Themes, Values and Reputation and 

how these are delivered, as set out in Our Purpose report; 

• 

the robust IT infrastructure and investment in recent years in major technology transformation programmes for 

billing and customer contact and asset management and field working; 

• 

our asset management governance structure, certified under ISO 55001 and the development of our service 

planning framework. 

Contracting  

• 

• 

the approval by the Board of all significant contracts; 

disclosure of all transactions with associated companies, of which no new arrangements were entered into 

during the year; 

• 

an internal audit of compliance with RAG 5.07 Guideline for transfer pricing, which confirmed that there were 

no areas of significant non-compliance but identified a small number of areas for improvement in disclosure 

which have been reflected in this APR. 

Material issues or circumstances.  

The Directors considered all material circumstances, including in its approval of the going concern statement and 

viability statement.  No other material issues or circumstances were identified. 

Deloitte  LLP  have  carried  out  assurance  on  the  ring-fencing  certificate,  in  accordance  with  the  Company’s 

Instrument of Appointment. The assurance was in the form of agreed upon procedures and the assurance report 

has been submitted separately to Ofwat. 

This certificate was approved by the Board on 14 July 2023. 

14 July 2023 
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CONDITION P26 (Credit Rating) 

The Directors confirm that throughout 2022/23 the Appointee has ensured that it, and an Associated Company as 

issuer of debt on its behalf, has maintained an issuer credit rating which is an investment grade rating. 

VIABILITY STATEMENT 

The PR19 settlement remains extremely challenging and does not constitute a ‘fair balance between risk 

and return’ resulting in less financial headroom in the near term to 2025 

When considering long-term viability, the Directors note that, in their opinion, the PR19 FD and the amendments 

made  by  the  CMA  in  March  2021  still  resulted  in  a  settlement  which  is  extremely  challenging.  The  level  of 

asymmetric risk in the settlement package is significant and not matched by the level of return.  Allowed costs are 

insufficient  for  an  efficient  company  like  NWL  to  deliver  the  stretching  service  levels  set  out  in  the  FD  for  its 

customers.  This also results in lower financial headroom available for the management of downside shocks, such 

as the unprecedented increase in power prices experienced in the last 18 months, placing pressure on credit ratings 

as reflected in the downgrade by S&P to BBB (stable).  In the round it does not provide a ‘fair balance between risk 

and return”. 

The Directors confirm that over the long-term the business remains financially resilient but have concerns 

about the rate of return at PR24 

Financial forecasts over longer-term timeframes are inherently subject to more risk that the assumptions adopted 

will not be realised. As set out above, the Directors have confirmed that the business remains a going concern. In 

considering the longer-term viability, the Directors note the challenges inherent in the PR19 FD referred to above 

and that some of the downside stress test scenarios would place pressure on projected credit ratings in the next 

two years, particularly higher operating and capital costs. The longer-term view beyond two years assumes that 

the 2024 price review will provide a sufficient rate of return to enable the Company to finance its functions for the 

period  2025-30,  as  well  as  setting  stretching  but  achievable  targets  and  allowing  sufficient  totex  to  enable  an 

efficient company to meet its obligations and service level targets. This is consistent with Ofwat’s statutory duty to 

ensure that efficient companies are financeable. 

This  statement  and  the  supporting  analysis  takes  account  of  the  latest  internal  forecast  of  the  investment 

requirements for the 2025-30 period and beyond, consistent with our draft long-term strategy. This is still subject 

to review and challenge by Ofwat in its forthcoming price review (“PR24”) and so is uncertain. For the purpose of 

stress testing we have therefore looked at a range of capital investment scenarios. These scenarios suggest a 

capital programme 2-3 times larger than historical levels from previous five-year periods driven principally by the 

need  to  deliver  new  infrastructure  demanded  by  legal  requirements.  The  scale  of  this  investment  programme 

creates a need for additional equity investment under most scenarios. Our stress test scenarios include this equity 

injection  as  a mitigant  where we  believe  it  would  be  required.  This  is also  reflected  in  the  Board’s  discussions 

around distributions.  

The Directors have assessed the future prospects of the Company and consider that it should be able to manage 

its business risks, continue to operate and meet its liabilities as they fall due over the seven years to March 2030 

given the long-term nature of the business. Whilst the Directors consider that the business will remain financeable 

with  regards  to  its  obligations  to  debt  financing  and  credit  ratings,  they  remain  significantly  concerned  that  the 

14 July 2023 
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‘early-view’ returns Ofwat has set out in its PR24 methodology are not sufficient to attract the necessary investment 

that  is  likely  to  be  needed  to  meet  the  new  capital  needs  and,  in  the  round,  offer  reasonable  returns  on  that 

investment. 

Following  from  the  above,  our  Board  can  confirm  that  we  would  be  financeable  over  the  long  term  to  2030 

specifically  in  relation  to  debt.  However,  we  do  not  think  that  Ofwat’s  ‘early-view’  weighted  cost  of  capital  is 

consistent with the risks faced by our equity investors.   

This confirmation is given based on the latest information and evidence available to NWL 

In arriving at their conclusion, the Directors have taken into account: 

• 

• 

the Licence which is in place on a rolling 25 year basis; 

the controls and protections provided by the independent regulatory regime including the primary duty of Ofwat 

to ensure that efficient companies are able to finance their functions, including earning a reasonable return on 

the capital invested; 

• 

revenue  from  wholesale  and  household  retail  price  controls  to  March  2025  provided  by  the  PR19  FD,  as 

revised by the CMA in March 2021; 

• 

the financial strength of the Company at the balance sheet date and the fact that the Company has a £450m 

committed bank facility as back up liquidity, which was undrawn, maturing in December 2025 with the intention 

of extending until 2030 in due course, and a further of £150m loan facilities which were drawn after the balance 

sheet date; 

• 

the  Treasury  Strategy  approved  by  the  Board  in  April  2022  and  the  subsequent  establishment  of  a  £6bn 

European  Medium  Term  Note  programme  which  enables  the  Company  to  raise  new  financing  in  a  timely 

manner as required; 

• 

the  key  financial  ratios  over  the  planning  horizon  of  the  Company’s  financial  forecast  to  March  2028  and 

extended forecast to March 2030, as reflected in investment grade credit ratings; 

• 

the development of the PR24 business plan, including plans to address the financeability challenge created 

• 

• 

• 

by the potential scale of the AMP8 capital programme; 

the Board’s dividend policy; 

the extent to which equity could be raised in NWL if required; 

the principal risks and uncertainties facing the Company and the mitigating controls, as described on pages 

57 to 62 of the Annual Report & Financial Statements, which are monitored by the Audit Committee, R&CSC 

and Board; and 

• 

the work of the Audit Committee, on behalf of the Board, to review and approve the baseline plan and stress 

test  scenarios  and  to  review  the  outputs  of  the  stress  testing  in  the  context  of  the  Company’s  financial 

resilience. 

To support the Directors in their assessment of viability, the Audit Committee carried out a thorough review 

process. 

This included discussing and approving appropriate updates to the Board approved plan to reflect latest economic 

projections, in particular inflation assumptions and discussing an appropriate forward testing period. This concluded 

that  the  base  forward  plan  should  be  updated  to  reflect  the  latest  inflation  forecast  published  by  the  Bank  of 

England’s Monetary Policy Committee in May 2023. 

The Audit Committee also discussed and approved the range and severity of stress test scenarios to be applied to 

the baseline plan, taking account of the principal risks of the business. The stress tests are set out in detail below. 

14 July 2023 
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The Audit Committee then reviewed the detailed outcomes of the stress testing and the potential impact on the 

Company’s key financial ratios and discussed appropriate mitigating actions which could be taken if the need arose. 

Following this process, the Audit Committee recommended approval of the viability statement to the Board. 

The Directors have chosen a period of seven years to March 2030 to assess the viability of the Company 

This period has been chosen to align with the business planning process for the regulatory price review period to 

March 2025, and the next price review period to March 2030. Whilst the Directors do not believe that it is possible 

to test financial resilience beyond March 2025 to the same level of robust detail, given uncertainty of revenue and 

returns  past  this  point,  they  have  performed  an  assessment  of  viability  beyond  the current  price  control  period 

against an extended plan applying reasonable assumptions for the next price review which includes a sufficient 

rate of return to enable the Company to finance its functions. 

The financial forecast has been stress tested under a number of plausible and severe adverse scenarios 

linked to the businesses’ principal risks.  

The scenarios were selected after considering the principal risks and uncertainties facing the Company  and the 

key  economic  and  financial  variables  which  could  impact  on  the  forecast.  The  combined  impact  of  multiple 

scenarios has also been tested.  

The  stress  tests  were  assessed  in  the  context  of  NWL’s  overarching  financial  objective  of  maintaining  prudent 

investment grade credit ratings, and the Board’s target of retaining regulatory gearing of around 70%. Whilst the 

viability  statement  relates  specifically  to  NWL,  both  rating  agencies  take  account  of  NWGL  metrics  in  their 

methodologies, therefore, the impact on both NWL and NWGL financial plans have been considered. 

The table below sets out the stress tests performed, how they map to the principal risks, the severity of the adverse 

scenarios  applied,  the  outcome  in  the context  of  the  key  financial  ratios and  potential mitigating  actions  where 

required. 

14 July 2023 
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1 

2 

3 

4 

5 

Defined benefit 
pension scheme 
returns to deficit 
position and higher 
deficit repair 
contributions 

Higher operating 
costs, including 
energy and chemical 
prices 

Higher capital costs, 
reflecting input cost 
pressures 

6 

Higher totex costs 

7 

8 

Impact of incident 
crystallising one of 
the principal risks 
identified on pages 
57 to  of the Annual 
Report & Financial 
Statements. 

Regulatory penalty 
for poor performance 
or non-compliance 
with obligations 

Ref 

Stress Test 

Principal Risk 

Scenarios 

Outcome 

Mitigation 

Lower inflation, 
reducing allowed 
revenue and RCV 
growth 

Regulatory and 
political changes 

Up to 1% per annum 
lower than base 
forecast, sustained 
over period  

Increased borrowing 
costs for raising new 
and refinanced debt 

Regulatory and 
political changes 
Funding and liquidity 
risk 
Financial 
performance 

Up to 2% higher than 
base forecast 

Regulatory and 
political changes 

Deficit up to £100m 
and increased deficit 
repair payments up 
to £10m pa 

Application of the 
Board’s dividend 
policy and possible 
equity raising 

Increased gearing 
and lower interest 
cover creates risk of 
credit rating 
downgrade if low 
inflation sustained 
through AMP8 

No material impact 
on ratios in AMP7 but 
sustained increase 
through AMP8 would 
impact interest cover 
and FFO creating a 
risk of credit rating 
downgrade 

Increasing interest 
rates should be 
reflected in PR24 
cost of debt 
Application of the 
Board’s dividend 
policy and possible 
equity raising 

No material impact 
on ratios 

Not required 

Customer and 
stakeholder trust and 
confidence 
Water/wastewater 
service failure 
Supply chain failure 
Asset health 
deterioration 
Effect of climate 
change 
Regulatory and 
political changes 
Financial 
performance 

Water/wastewater 
service failure 
Cyber security 
Asset health 
deterioration 

Health & safety 
Water/wastewater 
service failure 
Asset health 
deterioration 

Up to 10% increase 
in current planned 
spend 

Up to 10% increase 
in current plan 

Combination of 
scenarios 5 and 6 

Significant cost 
increases would 
affect gearing, 
interest cover and 
FFO credit ratios 
over the seven year 
period creating a risk 
of credit rating 
downgrade 

Strong management 
of costs and efficient 
delivery of outcomes 
through innovation. 
Application of the 
Board’s dividend 
policy and possible 
equity raising 

One off impact of up 
to £50m 

One-off impact would 
not have a material 
impact on ratios 

Not required 

One off penalty of up 
to 10% of regulated 
revenue 

One-off impact would 
not have a material 
direct impact on 
ratios 
Reputational impact 
could affect 
stakeholder  views of 
the business over 
longer term 

Financial mitigation 
not required but 
would need to 
demonstrate 
improved 
performance to retain 
stakeholder trust and 
confidence 

14 July 2023 
PAGE 133 OF 211 

 
 
 
 
 
 
 
Ref 

Stress Test 

Principal Risk 

Scenarios 

Outcome 

Mitigation 

Customer and 
stakeholder trust and 
confidence 

Up to 2% pa 

No material impact 
on ratios 

Not required 

Up to £15m pa 

No material impact 
on ratios 

Not required 

9 

Sustained 
deterioration in 
household revenue 
collection due to cost 
of living pressures 

10 

Net ODI penalty 

11 

Adverse outcome of 
PR24 compared to 
base plan 
assumptions 

12 

Combined impact of 
adverse economic 
movements 

Water/wastewater 
service failure 
Supply chain failure 
Asset health 
deterioration 
Effect of climate 
change 

Regulatory and 
political changes 

Lower revenue 
allowance than base 
plan assumption 

Scenarios 1, and 2 

13 

Combined impact of 
adverse company 
performance 

Scenarios 6, 8 and 
10 

To be assessed 
through PR24 
process, including 
option to refer to 
CMA. 

Application of the 
Board’s dividend 
policy and possible 
equity raising 
Increasing interest 
rates should be 
reflected in PR24 
cost of debt 

AMP8 financing 
plans may need to 
brought forward to 
fund any 
advancement of 
capex. 
Strong management 
of cost and 
performance would 
reduce the impact. 
Application of the 
Board’s dividend 
policy and possible 
equity investment. 

No impact in AMP7 
Insufficient returns in 
AMP8 impeding the 
ability to raise finance 
and creating a risk of 
rating downgrade 

No material impact 
on ratios in AMP7. 
Sustained impacts 
through AMP8 would 
affect gearing, 
interest cover and 
FFO ratios creating a 
risk of rating 
downgrade 

Increased costs in 
AMP7, including  
advancement of 
AMP8 investment, 
would affect gearing, 
interest cover and 
FFO ratios and  
create some risk of 
credit rating 
downgrade in AMP7 
Higher costs and 
penalties would 
impact gearing, 
interest cover and 
FFO ratios over the 
period and result in 
credit rating 
downgrade in AMP8 

The baseline plan is compatible with retaining the Company’s investment grade credit ratings.  

None  of  the  stress  test  scenarios  undermined  the  Company’s  long  term  financial  resilience.  However,  certain 

scenarios, specifically higher operating and capital costs, a substantial increase in the cost of raising new finance 

into AMP8 or a sustained period of low inflation in AMP8, indicated a risk of a credit rating downgrade which would 

trigger  the  cash-lock up provisions in  the  Company’s Licence, preventing payment  of  dividends. In  the  Board’s 

opinion, even the most severe scenarios were not indicative of falling below investment grade credit rating. 

14 July 2023 
PAGE 134 OF 211 

 
 
 
 
 
 
 
To  the  extent  that  any  of  these  scenarios,  in  isolation  or combination,  would  place  retention  of  the  Company’s 

investment grade credit rating or liquidity position at risk, the Board would seek to take mitigating actions. This 

includes: 

• 

additional controls on discretionary costs and capital expenditure phasing, taking care not to impact on service 

levels to customers; 

flexible and efficient financing of new debt; 

the Board’s dividend policy, which allows equity to be retained in NWL if required; and 

discussions with shareholders in respect of any equity raising that may be required. 

• 

• 

• 

The Board engaged Deloitte LLP to provide third party assurance, in the form of agreed upon procedures. 

BOARD  STATEMENT  ON  ACCURACY  AND  COMPLETENESS  OF  DATA  AND 

INFORMATION 

In  the  opinion  of  the  Board,  based  on  the  governance  and  assurance  arrangements  in  place,  the  data  and 

information contained in this Annual Performance Report and provided to Ofwat during the year is complete and 

has a high degree of accuracy.  Our Data Assurance Statement provides a detailed review of the assurance work 

carried out in the year and the findings of our assurance providers, upon which this opinion is based.  

Governance Arrangements & Assurance Framework 

The Board is committed to providing regulatory data and information that is accurate, clear and transparent in order 

to  maintain  the  trust  of  our  customers  and  stakeholders.    The  Board  takes  ownership  of  the  arrangements  for 

governance and assurance of regulatory submissions and reporting.  This is monitored and controlled through the 

Board’s Audit Committee and Risk & Compliance Sub-committee, which report regularly to the Board. 

The Board has put in place a comprehensive assurance framework, shown in the diagram below.  This has Board 

oversight  at  its  core,  supported  by  a  risk  management  framework  and  multiple  layers  of  internal  and  external 

assurance. 

14 July 2023 
PAGE 135 OF 211 

 
 
 
 
 
The Risk & Compliance Sub-committee, on behalf of the Board, carried out its annual review of the effectiveness 

of the Company’s risk management and internal control systems. This review confirmed that the Company has 

strong systems of internal control and robust processes in place to enable it to identify, evaluate and manage the 

risks  it  faces  and  to  ensure  that  its  obligations  are  met.  These  systems  and  processes  are  embedded  in  the 

organisation  and  are  reviewed  regularly  by  the  Board,  its  Committees  and  Sub-committee.  The  annual  review 

confirmed that the risk management and internal control systems have operated effectively through the year and 

that there have been no significant failings or weaknesses.  

Activities in the Year 

We  are  no  longer  required  to  publish  an  Assurance  Plan  however  we  do  provide  stakeholders  with  an  annual 

Assurance Statement which details our approach to assurance and the assurance arrangements we have in place. 

This reports also details any material findings and includes full copies of the audit reports received from external 

providers. 

The Board, through the work of its Audit Committee, has continued to improve regulatory data through the year. 

This plan was designed to address areas of risk identified in reports from our assurance providers for the 2021/22 

APR, as well as areas where the source of data has changed during the year and where there are new reporting 

requirements. This included: 

•  more resource being provided to ensure that conflicting data from the field can be corrected quickly rather than 

it being a retrospective annual exercise; 

• 

• 

improving accuracy in the use of complex spreadsheets; and 

streamlining business process for reporting bioresources data. 

As part of the approval process for this APR, the Audit Committee received assurance reports from the Internal 

Audit manager, the external technical assurer, PricewaterhouseCoopers LLP, and the financial auditor, Deloitte 

LLP. Greenhouse gases require specific third-party assurance from an appropriately qualified company to the ISO 

14 July 2023 
PAGE 136 OF 211 

 
 
 
 
 
standard  14064.  Their  assurance  has  been  completed  and  their  opinion  is  included  in  the  Data  Assurance 

Statement. 

These all confirm there were no significant issues to report. 

Conclusion 

The Board is satisfied that the governance and assurance arrangements it has put in place are comprehensive and 

robust  and  have  operated  effectively  throughout  the  year.    On  this  basis,  the  Board  is  confident  that  the  data 

reported has a high degree of accuracy.  However, no assurance process can give an absolute guarantee of total 

accuracy, especially given the extremely large volume of data in the APR and the fact that some of the reported 

information is dependent on expert judgement and assumptions, for example accounting separation data. 

By order of the Board 

Andrew J Hunter 

Chairman 

Heidi Mottram 

CEO 

Alan Bryce 

Senior Independent 

Non-Executive Director 

Dominic Chan 

H L Kam 

Duncan Macrae 

Non-Executive Director 

Non-Executive Director 

Non-Executive Director 

Jacquie McGlade 

Bridget Rosewell 

Richard Sexton 

Independent Non-Executive Director 

Independent 
Director 

Non-Executive 

Independent Non-Executive 
Director 

Peter Vicary-Smith 

Independent Non-Executive Director 

14 July 2023 

14 July 2023 
PAGE 137 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REGULATORY ACCOUNTING POLICIES AND DISCLOSURES 
for the year ended 31 March 2023 

(a)  Regulatory Accounts - Basis of Accounting 

The Regulatory Accounting Statements, on pages 125  to 181 of the APR, have been prepared in accordance 

with  the  Regulatory  Accounting  Guidelines  (RAGs)  issued  by  Ofwat.  They  have  been  prepared  on  a 

consistent basis to the Company’s Financial Statements, with the following exceptions: 

• 

income relating to energy generation and meter reading, which is recorded as revenue in the statutory 

accounts, has been recorded as negative operating expenditure; 

• 

rental income and amortisation of deferred capital income, which are recorded as revenue in the statutory 

accounts, have been recorded as other income below operating profit; 

• 

profit on disposal of fixed assets, which is recorded as operating costs in the statutory accounts, has 

been recorded as other operating income; 

• 

borrowing  costs  that  are  directly  attributable  to  the  acquisition  or  construction  of  an  asset,  which  are 

capitalised in the statutory accounts, are charged to the income statement; and 

• 

The  net  innovation  fund  receipt  has  been  accrued  in  operating  costs  in  the  Statutory  accounts  but 

removed from the Regulatory accounts, in accordance with Ofwat guidance. 

The information reported in the Regulatory Accounting Statements relates to NWL’s Appointed business only, 

except where stated. The Appointed business comprises Regulated Activities, defined in Condition A of the 

Licence  to  be  ‘functions  of’  and  the  ‘duties  imposed  on’  a  water  and  sewerage  undertaker  by  the  Water 

Industry Act 1991. Such duties are consequently those necessary for the Company to fulfil its duty as a water 

and sewerage undertaker. 

The  accounts  have  been prepared on  a going  concern  basis  which  assumes  that  the  Company  will  have 

adequate funding to meet its liabilities as they fall due in the foreseeable future. 

(b)  Revenue recognition  

The revenue recognition policy is the same in the regulatory and statutory accounts, other than the exceptions 

related  to  income  from  energy  generation,  meter  reading,  rental  income  and  deferred  capital  income,  as 

explained above. 

RAG 1.09 requires companies to recognise all revenue billed to properties which receive a service, other than 

if confirmed as void, and to assume that it is probable that this will be collected, disapplying IFRS 15 in this 

respect. NWL complies with this requirement. 

Revenue  from  water  and  sewerage  charges  billed  to  customers  is  recognised  pro-rata  over  the  period  to 

which it related. For consumption by measured customers which has not yet been billed, revenue is estimated 

and accrued using a defined methodology based upon historical usage and the relevant tariff per customer. 

Invoices raised or payments received where the service has not been provided are not recognised in revenue 

in the year but are treated as receipts in advance. 

Additional charges added to a customer’s account as a result of debt recovery activity, such as court costs or 

solicitors’ fees, are recognised as negative operating costs when payment is received in both the statutory 

and regulatory accounts. They are not recognised in revenue. 

14 July 2023 
PAGE 138 OF 211 

 
 
 
 
 
Charges for water and sewerage services remain due in full whilst a property contains furnishings and fittings 

or when a property is unfurnished and water is being used for any purpose including refurbishment. If the 

Company has turned off the supply of water at the mains to a property at a customer’s request, then water 

supply charges are not payable. 

If the supply of water is turned off and the property is unfurnished the property is considered unoccupied and 

charges are not payable. If, however, the supply of water is turned off and the property remains furnished it 

is considered ready for occupation and in this case sewerage charges in respect of the drainage of surface 

water and contribution to highway drainage continue to be payable. 

If a property is recorded as empty in the billing system an empty property process is followed. The purpose 

of this process is to verify whether the property is occupied or not and, if occupied, to identify the chargeable 

person and raise a bill.  No bills are raised in the name of ‘the occupier’. 

The empty property process comprises a number of steps including an initial letter asking the occupier to 

either contact the Company or return a completed registration form, a check of the property record against 

Land Registry information, signs of an active credit reference file at the property and visits to the property by 

Company representatives. If these steps confirm that a property appears to be empty, then the supply may 

be turned off. 

New properties are charged from the date a meter is installed, if consumption is being recorded on the meter. 

If the property is unoccupied but water is being registered, the developer will be charged.  Once the developer 

is no longer responsible for a property, if no new occupier has been identified the property will be treated as 

unoccupied and the empty property process followed, as outlined above. 

A  retrospective  review  has  confirmed  that  the  measured  household  income  accrual  at  31  March  2022  of 

£59.9m was slightly higher than the amounts subsequently billed to customers of £55.9m. 

(c)  Bad debt policy  

The policy for bad and doubtful debts is applied consistently between the statutory and regulatory accounts. 

(i)  Bad debt write offs 

Debt is only written off after all available economic options for collecting the debt have been exhausted and 

the debt has been deemed to be uncollectable. This may be because the debt is considered to be impossible, 

impractical, inefficient or uneconomic to collect. 

Situations where this may arise and where debt may be written off are as follows: 

•  where the customer has absconded without paying and strategies to trace their whereabouts and collect 

outstanding monies have been fully exhausted; 

•  where the customer has died without leaving an estate or has left an insufficient estate on which to levy 

execution; 

•  where the customer does not have any assets or has insufficient assets on which to levy execution; 

•  where the value of the debt makes it uneconomic to pursue; 

•  where  county  court  proceedings  and  attempts  to  recover  the  debt  by  debt  collection  agencies  have 

proved unsuccessful; and 

•  where the customer has been declared bankrupt, is in liquidation or is subject to insolvency proceedings 

or a debt relief order and no dividend has been or is likely to be received. 

14 July 2023 
PAGE 139 OF 211 

 
 
 
 
For debt to be written off there must be a legitimate charge against the debtor. If it is considered that part or 

all of the debt is incorrect or unsubstantiated, then such elements are dealt with through the issue of a credit 

note.  

(ii)  Bad debt provisioning  

The Company’s detailed bad and doubtful debts provision policy has remained unchanged during the year 

and  has  been  consistently  applied  in  the  current  and  prior  periods.  The  bad  debt  provision  is  charged  to 

operating costs to reflect the Company’s assessment of the risk of non recoverability of debtors. It is calculated 

by applying expected recovery rates to debts outstanding at the end of the accounting period. These recovery 

rates take into account the age of the debt, payment history and type of debt. 

Higher provisioning percentages are applied to categories of debt which are considered to be of greater risk, 

including those with a poor payment history as well as to those of greater age. Bad debt provisioning rates 

are reviewed annually to reflect the latest collection performance data from the Company’s billing system. 

Actual amounts recovered may differ from the estimated levels of recovery which could impact on operating 

results. A comparison of the provision against historical collection rates is carried out at the end of each year 

to validate and, if necessary, adjust the level of provision. 

An  assessment  of  the  potential  impact  of  cost  of  living  pressures  caused  by  high  energy  costs  and  the 

consequent  inflationary  pressures  was  made  at  31  March  2022  and  an  additional  provision  of  £2m  was 

created.  Cash collection has been sustained through the year, therefore management has concluded that 

this provision is no longer required and it has been released at 31 March 2023. 

The  provision  has  reduced  from  £94.2m  at  31  March  2022  to  £92.3m  at  31  March  2023,  reflecting  cash 

collection, write off of £12.6m of debt considered to be unrecoverable and the release of the £2m cost of living 

provision. 

(d)  Capitalisation policy 

The policy for the capitalisation of costs as items of property, plant and  equipment and intangible assets is 

applied consistently between the statutory and regulatory accounts, in accordance with IAS16 Property, Plant 

and Equipment and IAS38 Intangible Assets. 

The application of this policy is summarised below. Further detail is provided in the accounting separation 

methodology statement published on our websites. 

The cost of construction or purchase of new or replacement infrastructure and non-infrastructure assets is 

capitalised.  Cost  includes  any  costs  directly  attributable  to bringing  the  asset  into  condition  for  use  in  the 

business, including directly attributable overhead costs but excluding general overhead costs. The costs of 

infrastructure and non-infrastructure assets are depreciated over their useful economic lives. 

On the infrastructure network, capital replacement of assets includes any renewal of a full pipe length of main 

or sewer and replacement of ancillaries such as stop taps, valves, meter chambers and manhole covers. 

Subsequent maintenance expenditure is treated as an operating cost unless it provides an enhancement of 

economic benefits in excess of the expected standard of performance such as an extension in the estimated 

useful life or an increase in capacity, in which case it is capitalised. Examples of maintenance costs charged 

as operating costs include pipe and tank cleaning, inspections, surveys and zonal studies. 

(e)  Accounting separation policy 

14 July 2023 
PAGE 140 OF 211 

 
 
 
 
Cost allocations have been prepared in accordance with RAG 2.09 and RAG 4.11 for the definitions for the 

regulatory accounting tables. All costs are recorded in the accounting records by cost centre. Cost centres 

are  defined  either  as  a  direct  department,  comprising  operational  and  customer  functions,  or  a  support 

department. Direct departments are mostly directly allocated to service activities based on the nature of the 

function,  although  some  costs  require  apportionment  on  an  appropriate  basis.  Support  departments  are 

apportioned across the price controls either based upon a specific analysis of the costs or by apportionment 

by an appropriate cost driver. Once allocated to the appropriate price control the costs are then allocated to 

service activities pro-rata to full time equivalent staff numbers of the direct departments. 

Fixed assets directly involved in the activities within each business unit are recorded against that business 

unit using direct allocation per the location or asset type. Where an asset is utilised in more than one business 

unit, the asset is allocated to the business unit of principal use and costs are recharged to other different 

business units on the same basis used to allocate operating expenditure. 

Further detail is provided in the accounting separation methodology statement published on our website. 

(f)  Statement of Directors’ remuneration and standards of performance 

Directors’ remuneration is fully disclosed in the NWL Annual Report and Financial Statements for the year 

ended 31 March 2023, in the Remuneration Committee Report on pages 88 to 99 This is published on our 

website. To avoid duplication, this information has not been replicated within the APR. 

The  Remuneration  Committee  Report  has  been  produced  in  accordance  with  section  35A  of  the  Water 

Industry Act 1991. It also has regard to the requirements of the Large and Medium-sized Companies and 

Groups  (Accounts  and  Reports)  (Amendment)  Regulations  2013  in  respect  of  Directors’  remuneration 

reporting for quoted companies, albeit in the context of a company which is not a listed public limited company. 

14 July 2023 
PAGE 141 OF 211 

 
 
 
 
1A  INCOME STATEMENT 

financial performance for the 12 months ended 31 March 2023 

Adjustments 

Differences 
between 
statutory and 
RAG 
definitions  
£'m   

(32.5)  
20.4  
1.8  
(10.3)  

11.4  
-  
(10.0)  
-  

Statutory  
£'m 

849.9  
(638.3)  
-  
211.6  

-  
1.4  
(244.9)  
0.8  

Non-
appointed  
£'m   

Total 
adjustments  
£'m 

(34.7)  
28.0  
(0.3)  
(7.0)  

(1.1)  
-  
-  
-  

(67.2)  
48.4  
1.5  
(17.3)  

10.3  
-  
(10.0)  
-  

Total 
appointed 
activities  
£'m   

782.7  
(589.9)  
1.5  
194.3  

10.3  
1.4  
(254.9)  
0.8  

(31.1)  

(8.9)  

(8.1)  

(17.0)  

(48.1)  

-  
(8.9)  

0.3  
1.8  
(6.8)  

-  

(0.3)  

-  
(0.3)  

-  
(8.1)  

0.4  
(0.1)  
(7.8)  

-  

(0.4)  

-  
(0.4)  

-  
(17.0)  

0.7  
1.7  
(14.6)  

(17.9)  
(66.0)  

(2.4)  
26.7  
(41.7)  

-  

(110.8)  

(0.7)  

-  
(0.7)  

4.1  

(1.7)  
2.4  

(17.9)  
(49.0)  

(3.1)  
25.0  
(27.1)  

(110.8)  

4.8  

(1.7)  
3.1  

-  
2.5  
32.3  
34.8  

Revenue 
Operating costs 
Other operating income 
Operating profit 

Other income 
Interest income 
Interest expense 
Other interest expense  

Profit before tax and fair value 
movements 

Fair value gains/(losses) on 
financial instruments 
Profit before tax 

UK Corporation tax 
Deferred tax 
Profit for the year 

Dividends 

Tax analysis 
Current year 
Adjustments in respect of prior 
years 
UK Corporation tax 

Analysis of non-appointed revenue 

Imported sludge 
Tankered waste 
Other non-appointed revenue 
Revenue 

14 July 2023 
PAGE 142 OF 211 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
  
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
 
 
 
Differences between Statutory and Regulatory Definitions 

Differences between statutory and RAG definitions are explained in note (a) of the Regulatory Accounting Policies and Disclosures. 

The differences which result in a change to profit for the year reflect the following accounting treatments: 

• 

capitalisation  of  borrowing  costs,  which  are  capitalised  in  the  Statutory  Financial  Statements  but  charged  to  the  Income 

Statement in the Regulatory Accounting Statements, along with the associated depreciation and deferred tax; and  

• 

Innovation Fund costs, which are provided in the Statutory Financial Statements but removed from the Regulatory Accounting 

Statements, along with the associated tax. 

Other changes are presentational in nature: 

• 

income relating to energy generation and meter reading has been reclassified from revenue in the statutory accounts to negative 

operating costs; 

• 

rental income, amortisation of deferred income and other contributions to capital investment have been reclassified from revenue 

in the statutory accounts to other income; and 

• 

profit on disposal of fixed assets has been reclassified from operating costs in the statutory accounts to other operating income. 

Interest Analysis 

Interest expense comprises: 

Bank overdrafts and loans 

Loans from financing subsidiary 

Amortisation of issuance costs 

Accretion on index-linked debt 

Obligations under leases 

Interest expense 

£’m 

(5.6) 

(98.0) 

(3.4) 

(142.0) 

(5.9) 

(254.9) 

NWL has a financing subsidiary, Northumbrian Water Finance Limited, which raises listed debt on its behalf. The debt is then loaned 

to NWL at the same terms. 

Other interest expenses represents interest cost on pension plan obligations. 

14 July 2023 
PAGE 143 OF 211 

 
 
 
  
 
 
 
1B  STATEMENT OF COMPREHENSIVE INCOME 

financial performance for the 12 months ended 31 March 2023 

Adjustments 

Differences 
between 
statutory and 
RAG 

Non-

Statutory 
£'m 

definitions   
£'m   

appointed   
£'m   

Total 
adjustments 
£'m 

Total 
appointed 
activities  
£'m   

Profit for the year 
Actuarial gains/(losses) on post 
employment plans 
Other comprehensive income 

Total Comprehensive income for 
the year 

(27.1)  

(6.8)  

(7.8)  

(14.6)  

(41.7)  

(31.4)  
(2.7)  

-  
-  

-  
-  

-  
-  

(31.4)  
(2.7)  

(61.2)  

(6.8)  

(7.8)  

(14.6)  

(75.8)  

14 July 2023 
PAGE 144 OF 211 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
1C  STATEMENT OF FINANCIAL POSITION 

financial performance for the 12 months ended 31 March 2023 
(Registered number 02366703) 

Adjustments 

Differences 
between 
statutory and 
RAG 

Statutory 
£'m 

definitions   
£'m   

Non-

appointed   
£'m   

Total 
adjustments 
£'m 

Total 
appointed 

activities   
£'m   

Non-current assets 
Fixed assets 
Intangible assets 
Investments - loans to group 
companies 
Investments - other 
Total non-current assets 

Current assets 
Inventories 
Trade & other receivables 
Cash & cash equivalents 
Total current assets 

Current liabilities 
Trade & other payables 
Capex creditor 
Borrowings 
Current tax liabilities 
Provisions 
Total current liabilities 

Net current assets / (liabilities) 

Non-Current liabilities 
Trade & other payables 
Borrowings 
Financial instruments 
Retirement benefit obligations 
Provisions 
Deferred income - G&C's 
Deferred income - adopted 
assets 
Deferred tax 
Total non-current liabilities 

4,998.2  
55.0  

1.9  
-  
5,055.1  

8.0  
246.3  
146.6  
400.9  

(182.8)  
(37.4)  
(208.5)  
-  
(0.1)  
(428.8)  

(27.9)  

-  
(3,420.6)  
(87.1)  
17.9  
(3.8)  
(398.0)  

(169.5)  
(619.6)  
(4,680.7)  

(69.7)  
(2.7)  

-  
-  
(72.4)  

0.1  
3.0  
-  
3.1  

(145.2)  
-  
146.0  
-  
-  
0.8  

3.9  

-  
-  
-  
-  
-  
-  

-  
17.2  
17.2  

(103.7)  
(0.1)  

(1.9)  
-  
(105.7)  

(0.5)  
(5.4)  
(1.7)  
(7.6)  

7.5  
0.4  
-  
-  
-  
7.9  

0.3  

-  
-  
-  
(0.3)  
-  
78.9  

-  
5.5  
84.1  

Net assets 

346.5  

(51.3)  

(21.3)  

(173.4)  
(2.8)  

(1.9)  
-  
(178.1)  

(0.4)  
(2.4)  
(1.7)  
(4.5)  

(137.7)  
0.4  
146.0  
-  
-  
8.7  

4.2  

-  
-  
-  
(0.3)  
-  
78.9  

-  
22.7  
101.3  

(72.6)  

4,824.8  
52.2  

-  
-  
4,877.0  

7.6  
243.9  
144.9  
396.4  

(320.5)  
(37.0)  
(62.5)  
-  
(0.1)  
(420.1)  

(23.7)  

-  
(3,420.6)  
(87.1)  
17.6  
(3.8)  
(319.1)  

(169.5)  
(596.9)  
(4,579.4)  

273.9  

14 July 2023 
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1C  STATEMENT OF FINANCIAL POSITION (continued) 

financial performance for the 12 months ended 31 March 2023 

Adjustments 

Differences 
between 
statutory and 
RAG 

Statutory 
£'m 

definitions   
£'m   

Non-

appointed   
£'m   

Total 
adjustments 
£'m 

Total 
appointed 

activities   
£'m   

122.7  

223.8  
346.5  

-  

(30.6)  

(30.6)  

92.1  

(51.3)  
(51.3)  

9.3  
(21.3)  

(42.0)  
(72.6)  

181.8  
273.9  

Equity 
Called up share capital 
Retained earnings & other 
reserves 
Total Equity 

Approved by the Board of Directors on 14 July 2023 and signed on their behalf by:  

H Mottram 

Differences Between Statutory and Regulatory Definitions 

Differences between statutory and RAG definitions are explained in note (a) of the Regulatory Accounting Policies and Disclosures. 

The change in net assets and total equity reflects the different treatment of borrowing costs, which are capitalised in the Statutory 

Financial  Statements  but  charged  to  the  income  statement  in  the  Regulatory  Accounting  Statements,  along  with  the  associated 

depreciation and deferred tax; and the removal of the provision for Innovation Fund costs from the Regulatory Accounts along  with 

the associated tax. Other changes reflect the disaggregation of cash balances and trading balances between the appointed and non-

appointed businesses. 

14 July 2023 
PAGE 146 OF 211 

 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
   
   
 
 
 
  
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
1D  STATEMENT OF CASH FLOWS  

financial performance for the 12 months ended 31 March 2023 

Adjustments 

Differences 
between 
statutory and 
RAG 
definitions 

Statutory 

Non-
appointed 

Total 
adjustments  

(10.3) 
11.4 
(2.1) 
- 
1.0 
- 
1.8 
(1.8) 
- 

- 
- 

- 

- 
- 
- 
- 

- 

- 

- 
- 
- 

- 

- 

Operating profit 
Other income 
Depreciation 
Amortisation - G&C's 
Changes in working capital 
Pension contributions 
Movement in provisions 
Profit on sale of fixed assets 
Cash generated from operations 

Net interest paid 
Tax paid 
Net cash generated from 
operating activities 

Investing activities 
Capital expenditure 
Grants & Contributions 
Disposal of fixed assets 
Other 
Net cash used in investing 
activities 

Net cash generated before 
financing activities 

Cashflows from financing 
activities 
Equity dividends paid 
Net loans received 
Cash inflow from equity financing 
Net cash generated from 
financing activities 

211.6 
- 
151.0 
- 
(2.2) 
(39.1) 
(14.8) 
- 
306.5 

(99.7) 
3.1 

209.9 

(282.8) 
15.4 
6.2 
- 

(261.2) 

(51.3) 

(110.8) 
248.7 
- 

137.9 

Increase / (decrease) in net cash 

86.6 

Net interest paid comprises: 

Interest paid 

Interest received 

Net interest paid 

£’m 

(101.2) 

1.5 

(99.7) 

Total 
appointed 
activities  
£'m  
194.3   
10.3  
145.8  
-  
(2.5)  
(38.9)  
(6.0)  
(1.5)  
301.5  

(99.7)  
3.1  

204.9  

(280.6)  
15.4  
5.9  
-  

(7.0) 
(1.1) 
(3.1) 
- 
(1.3) 
0.2 
7.0 
0.3 
(5.0) 

- 
- 

(17.3) 
10.3 
(5.2) 
- 
(0.3) 
0.2 
8.8 
(1.5) 
(5.0) 

- 
- 

(5.0) 

(5.0) 

2.2 
- 
(0.3) 
- 

1.9 

2.2 
- 
(0.3) 
- 

1.9 

(259.3)  

(3.1) 

(3.1) 

(54.4)  

- 
1.7 
- 

1.7 

- 
1.7 
- 

1.7 

(110.8)  
250.4  
-  

139.6  

(1.4) 

(1.4) 

85.2  

14 July 2023 
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1E  NET DEBT ANALYSIS as at 31 March 2023 

Appointed Business only 

Borrowings (excluding preference shares) 
Preference share capital 
Total borrowings 
Cash 
Short term deposits 
Net Debt 

Gearing 
Adjusted Gearing 

Interest 
Full year equivalent nominal interest cost 
Full year equivalent cash interest payment 

Indicative interest rates 
Indicative weighted average nominal interest 
rate 
Indicative weighted average cash interest rate 

Time to maturity 
Weighted average years to maturity 

Interest rate risk profile 

Fixed rate 

  Floating 
rate 

Index linked 

RPI 

  CPI/CPIH 

Total 

£'m   

£'m   

£'m   

£'m   

£'m 

2,142.7  

19.5  

1,203.5  

117.4  

3,483.1 
- 
3,483.1 
0.7 
- 
3,483.8 

68.3% 
68.3% 

93.3  
93.3  

0.4  
0.4  

180.4  
15.4  

12.2  
0.3  

286.3 
109.4 

4.36%  
4.36%  

1.88%  
1.88%  

14.96%  
1.28%  

10.34%  
0.24%  

8.21% 
3.14% 

8.9  

5.0  

14.8  

16.0  

11.2 

14 July 2023 
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1F 

FINANCIAL FLOWS for the 12 months ended 31 March 2023 and for the price review to date  

12 months ended 31 March 2023 

Average 2020-25 

% 

£'m 

% 

£'m 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Regulatory equity (£m) 

1,665.4  

1,665.4  

1,266.6    

1,625.2  

1,625.2  

1,230.8    

Return on regulatory equity 

4.42  

3.36  

4.42  

73.6  

56.0  

56.0  

4.39  

3.32  

4.39  

71.3  

54.0  

54.0 

Financing 

Impact of movement from notional gearing 

Gearing benefits sharing 

Variance in corporation tax 

Group relief 

Cost of debt 

Hedging instruments 

Return on regulatory equity including Financing 
adjustments  

Operational Performance 

Totex out / (under) performance 

ODI out / (under) performance 

C-Mex out / (under) performance  

D-Mex out  / (under) performance  

Retail out / (under) performance 

Other exceptional items 

Operational performance total  

1.06  
-  
1.65  
-  
4.35  
0.42  

1.29    
-    
2.17    
-    
6.66    
0.55    

17.6  
-  
27.5  
-  
72.5  
6.9  

16.3    
-    
27.5    
-    
84.5    
6.9    

1.07  
-  
0.87  
-  
1.74  
0.31  

1.32    
-    
1.14    
-    
2.70    
0.41    

17.3  
-  
14.5  
-  
29.0  
5.2  

16.7 
- 
14.5 
- 
34.2 
5.2 

4.42  

10.84  

15.09  

73.6  

180.5  

191.2  

4.39  

7.31  

9.96  

71.3  

120.0  

124.6 

-0.42  
-0.24  
0.17  
0.04  
-0.55  
0.15  
-0.85  

-0.55    
-0.31    
0.23    
0.06    
-0.72    
0.19    
-1.10    

(6.9)  
(3.9)  
2.9  
0.7  
(9.2)  
2.4  
(14.0)  

(6.9)    
(3.9)    
2.9    
0.7    
(9.2)    
2.4    
(14.0)    

(0.53)  
(0.18)  
0.12  
0.02  
(0.68)  
0.07  
(1.18)  

6.13  

6.35  

-  

(0.70)    
(0.23)    
0.15    
0.03    
(0.89)    
0.09    
(1.55)    

8.41  

6.35  

-    

(8.8)  
(3.0)  
1.9  
0.3  
(11.3)  
1.1  
(19.8)  

(8.8) 
(3.0) 
1.9 
0.3 
(11.3) 
1.1 
(19.8) 

71.3  

100.2  

104.8 

103.2  

103.2  

78.2 

-  

- 

RoRE (return on regulatory equity) 

4.42  

9.99  

13.99  

73.6  

166.5  

177.2  

RCV growth 

10.69  

10.69  

10.69  

178.0  

178.0  

135.4  

4.39  

6.35  

Voluntary sharing arrangements  

-  

-    

-  

-    

Total shareholder return 

15.11  

20.68  

24.68  

251.6  

344.5  

312.6  

10.74  

12.48  

14.76  

174.5  

203.4  

183.0 

14 July 2023 
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12 months ended 31 March 2023 

Average 2020-25 

% 

£'m 

% 

£'m 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Notional 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
notional 
regulatory 
equity 

Actual 
returns and 
actual 
regulatory 
equity 

Dividends  

Gross Dividend 
Interest Receivable on Intercompany loans 

Retained Value 

Cash impact of 2015-20 performance adjustments 

Totex out / under performance 

ODI out / under performance  

Total out / under performance  

3.18  

11.93  

5.64  
-  
15.04  

7.41  

53.0  

-    

17.27  

198.6  

93.8  
-  
250.7  

93.8  

3.18  

-    

218.8  

7.56  

-  
-  
-  

-    
-    
-    

-  
-  
-  

-    
-    
-    

5.35  
-  
7.13  

0.11  
-  
0.11  

7.07  

51.7  

-    

7.69  

122.8  

87.0  
-  
116.4  

0.14    
-    
0.14    

1.7  
-  
1.7  

87.0 
- 
96.0 

1.7 
- 
1.7 

14 July 2023 
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Explanation of Financial Flows 

The purpose of this table is to provide transparency of financial flows to investors, comparing actual flows, and the main elements of 

performance which contribute to these flows, against the financial flows assumed by Ofwat under the notional structure at the last 

price review. 

The table shows performance for 2022/23 and cumulative performance for the first three years of the 2020-2025 price control period. 

All of the financial values are expressed in the same 2017/18 price base as the PR19 price review. Where prior year numbers have 

been restated within the cumulative performance, this is explained below. 

Return on regulatory equity (RORE) 

At PR19, the base notional RORE was set at 4.42% for 2022/23. The regulatory equity base represents the proportion of RCV funded 

as equity rather than debt. Ofwat’s notional structure for PR19 assumed net debt at 60% of RCV, equating to base regulatory equity 

of 40%, or £1,665m at March 2023. 

NWL’s actual average gearing in 2022/23 was 69% (closing gearing 68.3%), due to having higher net debt than assumed by Ofwat’s 

notional structure, resulting in actual regulatory equity of 31% of RCV, or £1,267m. 

Financing 

This section of the report relates to performance from financing and tax. 

Gearing is calculated as net debt divided by RCV. NWL’s average gearing was 69%, remaining above Ofwat’s notional structure 

assumption of 60% but below our target level of around 70%. The more efficient capital structure has generated a financing benefit 

of £16.3m. The CMA redetermination removed the gearing sharing mechanism for NWL, though it would not have come into effect 

during the year if it had been applied. 

Corporation tax reports the difference current tax funded in the FD and the actual tax rate applied to profit before fair value, adjusted 

for capital allowances. The Company made a loss before tax in the year, due to the impact of very high inflation on index-linked debt 

interest charges. As a result, the tax charge was significantly lower than assumed in the FD, with a variance of £27.5m in 2022/23. 

This  also  included  the  impact  of  accelerated  ‘super  deductions’  on  capital  investment.  A  reconciliation  of  our  current  tax  to  FD 

allowance is provided on page 156. All tax losses acquired from related parties in the year were paid for in full. 

The tax performance reported in 2020/21 included a deferred tax adjustment which, after subsequent consideration, has now been 

removed from the calculation. The cumulative tax variance is: 

£m 

2020/21 

2021/22 

2022/23 

Average 

Variance in corporation tax 

0.258 

15.634 

27.492 

14.461 

Cost of debt performance is reported in real terms, rather than nominal. As reported in table 4H, over 60% of the Company’s debt is 

at fixed rate and not impacted by indexation. In 2022/23, the real cost of debt was 3.24% lower than allowed in the FD due to high 

CPIH inflation, generating a £91.4m outperformance on cost of debt. This included £6.9m in respect of interest rate swaps. 

In previous years, the impact of hedging instruments has been calculated including the impact of fair value gains and losses on 

hedging instruments. Following a review of the updated Regulatory Accounting Guidelines, the basis of the calculation has been 

revised to exclude fair value movements. The restated cost of debt and hedging returns are shown below: 

14 July 2023 
PAGE 151 OF 211 

 
 
 
 
 
 
 
£m 

Cost of debt 

2020/21 

2021/22 

2022/23 

Average 

(18.191) 

36.192 

84.461 

34.154 

Hedging instruments 

4.543 

4.157 

6.914 

5.205 

The net effect of financing and tax in the year was an outperformance of FD allowance by £135.2m, or 10.67% of actual regulatory 

equity. 

Operational Performance 

This section of the report explains the impact of operational performance on wholesale totex, ODIs and retail costs, each of which is 

explained elsewhere in this report. 

Wholesale totex performance reflects the performance presented in table 4C, and excludes variations due to timing of expenditure. 

The underperformance of £6.8m reflects overspends on the water price controls and underspends on the wastewater price controls, 

net of customer cost sharing, as explained in the commentary to table 4C on  page 195. Following publication of the March 2022 

APR, Ofwat highlighted an error in the RAG guidance. The restated cumulative totex performance is shown below: 

£m 

2020/21 

2021/22 

2022/23 

Average 

Totex performance 

7.107 

(26.709) 

(6.938) 

(8.847) 

ODI performance against our PCs is reported in the tables in section 3, with table 3H reporting the summary incentive rewards and 

penalties  (excluding  C-MeX  and  D-MeX  rewards  as  explained  below).  The  reported  performance  for  the  year  for  in-period 

adjustments is a net penalty of £3.9m. Our performance against each ODI is explained earlier in this report. 

In the previous year, the reported performance included the full impact of Storm Arwen on interruptions to supply. Following our 

representations, Ofwat removed 50% of the penalty in its final determination of ODIs. The restated cumulative ODI performance is 

shown below: 

£m 

2020/21 

2021/22 

2022/23 

Average 

ODI performance 

1.862 

(7.003) 

(3.918) 

(3.020) 

Performance rewards on C-MeX and D-Mex are based on comparative performance across the sector and are not finalised until 

later in the year. For the purposes of this table, the performance is reported a year in arrears so the rewards of £2.9m for C-MeX and 

£0.7m for D-MeX relate to 2021/22 performance. We have achieved 1st place overall for C-MeX in 2022/23 and expect to earn a 

larger reward which will be reported in next year’s APR. 

Retail costs were higher than the PR19 allowance by £9.2m, as explained in the narrative to table 2C and due in part to the allowance 

not being increased each year for inflation. Cumulative performance has been updated so that the numbers reflect the correct price 

base: 

£m 

2020/21 

2021/22 

2022/23 

Average 

Retail performance 

(16.666) 

(8.149) 

(9.155) 

(11.323) 

Exceptional items of £2.4m reflects the company’s share of benefits from the disposal of surplus land and properties, as reported in 

table 2L. 

The net effect of operational performance in the year was an underperformance of FD allowance by £14.0m, 1.10% of regulatory 

equity. 

14 July 2023 
PAGE 152 OF 211 

 
 
 
 
 
 
 
 
Total Shareholder Return 

The  total  shareholder  return  comprises  base  RORE,  financing  performance,  operational performance and  growth  in  the  RCV  as 

allowed in the FD. Our total shareholder return of £312.6m performance comprises £177.2m RORE and £135.4m growth in RCV, 

reflecting the high levels of inflation in the latter part of the year. 

Retained Value 

Our  dividend  policy  is  set  out  on  page  177  and  we  explain  how  this  dividend  policy  is  applied  on  pages  179-181.  The  dividend 

reported in the table is for dividends paid during the year, reflecting a final dividend for 2021/22 and an interim dividend for 2022/23, 

rebased to 2017/18 prices. This resulted in retained value of £218.8m for 2022/23. 

14 July 2023 
PAGE 153 OF 211 

 
 
 
 
APPOINTED BUSINESS TAXATION 

The  rate  of  UK corporation tax  for  the current  year  was  19%.  The  movement  in the  Company's  deferred  tax  liabilities  has  been 

calculated at 25%. 

Current tax for the Appointed business is derived by adjusting the Company's statutory position by the amount relating to the activities 

of the Non-appointed business. The Appointed business credit for the year of £1.5m (£4.1m charge in the income statement and 

£5.6m credit in the other comprehensive income statement) relates to £1.5m receivable from fellow group companies in respect  of 

tax  losses  that  will  be  surrendered  by  the  Appointed  business.  The  surrenders  have  not  required  the  disclaimer  of  any  capital 

allowances by the Appointed business and payments for the losses will be made at the full rate of corporation tax. 

The prior years' corporation tax credit of £1.7m reflects revisions to tax reliefs for capital expenditure and R&D claims made. 

The current corporation tax credit of £1.5m reflects a swing of £6.9m compared to the credit of £8.4m in 2021/22 and is explained 

by the decrease in profit before tax and fair value movements (-£17.0m), additional tax reliefs for capital expenditure (notably super 

deductions)  (-£11.3m),  the  omission  of  the  prior year  one off  deduction  on  the  change  of  basis  of  accounting  for  'software  as  a 

service' (+£4.2m), additional tax relief available on pension contributions paid in excess of accounts service and finance costs (-

£8.8m), tax losses (+£38.5m), and other small variances (-£1.3m). 

The deferred tax credit for the Appointed business is derived by adjusting the Company's statutory credit of £17.7m (£25m credit in 

the income statement and £7.3m credit in the other comprehensive income statement) by amounts relating to accounting differences 

(i.e. capitalised interest: charge of £2.0m; Innovation Fund: credit £0.2m) and the activities of the Non-appointed business (credit of 

£0.1m).  The resulting Appointed business credit of £19.4m includes £19.1m for the current year and £0.3m for prior years related 

to the matters referred to above.  Deferred tax in the year and at the balance sheet date is all provided at 25%, being the rate at 

which temporary differences are expected to reverse. 

An  explanation  of  why  the  current  tax credit  for  the  Appointed  business  is lower  than  the  result  of  applying  the  standard  rate  of 

corporation tax to profit before tax is provided in the table below: 

14 July 2023 
PAGE 154 OF 211 

 
 
 
 
 
 
 
Profit before tax and fair value movements 

Profit before tax and fair value movements multiplied by standard rate of corporation 
tax of 19% 
EFFECTS OF: 
Expenses incurred that are not deductible for tax purposes 
Non-taxable income 
Super deductions claimed in excess of cost 
Depreciation in respect of non-qualifying items 
Tax reliefs claimed for capital expenditure in excess of accounts depreciation 
Grants and contributions received in excess of accounts amortisation 
Pension contributions paid in excess of accounts service and finance costs 
Other temporary differences 
Tax losses carried forward 
Deferred tax movements not at the standard rate for the year 
Adjustments in respect of prior periods 
UK:UK transfer pricing adjustments 
Balancing payment payable 
Appointed current tax charge per line 1A.12 

Total appointed 
activities 
£'m 

(48.1) 

(9.1) 

0.1 
(0.3) 
(4.0) 
0.7 
(31.0) 
9.3 
(2.5) 
(0.3) 
46.5 
(5.3) 
(1.7) 
(0.7) 
0.7 
2.4 

Future tax charges will be affected by the following matters: 

The company expects to continue to incur high levels of capital expenditure during the remainder of the 2020-25 regulatory review 

period which should result in claims for tax reliefs in excess of depreciation. 

The  temporary  increase  in  the  rate  of  capital  allowances  (super-deductions)  included  in  Finance  Act  2021  applied  to  qualifying 

expenditure incurred in the two years ended 31 March 2023 under contracts entered into on or after 3 March 2021. Such expenditure 

attracts allowances of 130% (compared to the normal 18%) in the case of assets with an economic life of less than 25 years, and 

50% (compared to the normal 6%) in the case of assets with an economic life of 25 years or more. The additional allowances were 

a contributory factor to the Company incurring tax losses in the current year. 

In his 2023 Budget, the Chancellor introduced the expensing regime to replace super-deductions which introduces a 100% first year 

capital allowance for assets with an economic life of less than 25 years and 50% for assets with an economic life of 25 years or more 

for a three year period from 1 April 2023. As a result, the Company expects to continue to generate a tax loss over the remainder of 

the 2020-25 regulatory review period. 

14 July 2023 
PAGE 155 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CURRENT TAX RECONCILIATION TO FD 

An allowance for corporation tax was made in the Final Determination (FD) at PR19.  Actual performance differs to the FD for  a 

number of reasons.  As far as current tax is concerned, the charge for the year is reconciled to the FD allowance as follows: 

Current tax charge (at 19%) allowed in price limits 
Net decrease in profit before tax and depreciation 
Increase in allowable pension contributions 
Increase in tax reliefs for capital expenditure 
Increase in capital allowances due to 'super deductions' 
Decrease in amortisation of grants and contributions 
Decrease in provisions 
Other 
Tax losses arising in the year 
Adjustment in respect of prior years 
Appointed current tax credit per line 1A.12 

APPOINTED BUSINESS TAX STRATEGY 

Scope 

Total appointed 
activities 
£'m 

18.0 
(27.6) 
(1.3) 
(14.8) 
(4.0) 
(1.2) 
(0.3) 
(0.1) 
35.4 
(1.7) 
2.4 

The Company is required, by section 3.32 of RAG 3.14, to publish details of its Tax Strategy relating to the Appointed Business within 

the Annual Performance Report.  For the avoidance of doubt, the Company has a single Tax Strategy which applies to its Appointed 

and Non-appointed businesses, as well as to its subsidiaries. 

The Tax Strategy set out below is for the Company’s financial year ended 31 March 2023 in order to satisfy the requirements of 

Schedule 19, Finance Act 2016. 

Aim 

The Company is committed to fully complying with all the statutory tax obligations that are imposed on it, including the provision of 

tax returns, the payment and recovery of taxes at the right time, and the provision of all relevant information to HM Revenue and 

Customs (HMRC) to support the amounts of tax concerned. 

The Company’s Board owns and approves the Tax Strategy which comprises the following four components: 

a) Tax governance arrangements 

The Board reviews and approves all significant investment and business operating decisions directly or delegates the appropriate 

authority.  The Company’s Audit Committee considers significant tax related matters as part of its monitoring of internal controls and 

financial reporting arrangements. 

Day-to-day management of the Company’s tax affairs is delegated to the Tax Manager and to other appropriately qualified staff who 

have responsibility for specific taxes.  All staff with responsibility for tax report to members of the Company’s senior management 

team which, in turn, reports to the Board. 

14 July 2023 
PAGE 156 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company's tax affairs are conducted in a business-like manner in accordance with the Company's commitment to corporate 

responsibility. 

b) Tax risk management framework 

The Company’s Risk Committee oversees the risk assessment process applied by the business which includes an assessment of 

tax risks.   

As far as possible, through the activities of its Board, Committees and personnel responsible for tax matters, the Company seeks to 

manage the level of tax risk arising from its operations by ensuring appropriate processes and controls are in place. 

The Company only takes tax positions which are justifiable and based on law, with advice taken from reputable professional firms 

where  necessary.    In  accordance  with  internal  governance  procedures,  any  transaction  that  is  likely  to  have  material  tax 

consequences must be referred to the Board. 

To help manage tax risk, the Company’s taxation affairs are only handled by appropriately qualified and experienced staff and, where 

necessary, training is given to non-tax staff who are involved in processes which have tax implications. 

The  Company  does  not  tolerate  or  condone  any  form  of  tax  evasion,  whether  committed  or  facilitated  by  its  own  staff  or  any 

associated persons (e.g. agents and other persons who perform services for or on behalf of the Company) and manages this risk by 

the use of appropriate processes. 

c) Approach to tax planning 

The  Company  considers  tax  as  part  of  its  business  decision  making  process.    When  entering  into  commercial  transactions,  the 

Company seeks to obtain the benefit of tax incentives, reliefs and exemptions available under UK tax legislation, consistent with the 

purpose and the letter of the law. 

The tax affairs of the Company are arranged and managed in response to, and in support of, its business or commercial activities.  

Related party transactions are managed and documented to ensure they are in compliance with local tax law and practice. 

d) Relationship with HMRC 

The Company seeks to have a transparent and constructive relationship with HMRC on all taxation matters and keeps HMRC aware 

of significant transactions and business developments.  All contact with HMRC is conducted in a professional and courteous manner. 

The Company seeks to obtain certainty from HMRC at the earliest opportunity on the tax treatment of complex or uncertain issues 

or to establish the appropriate understanding or interpretation of the law.  Discussions with HMRC are held at least annually to review 

past and present tax risks and agree on the steps required to take matters forward.  Resolution of any disputed matters will be sought 

through open discussion and negotiation with HMRC, but the Company is prepared to litigate in cases where it believes the technical 

basis of a decision is incorrect. 

The Company takes an active role in the development of the UK’s legislative framework through participation at company or industry 

level in Government consultations on significant new tax laws. 

Publication date: 14 July 2023. 

14 July 2023 
PAGE 157 OF 211 

 
 
 
 
 
2A  SEGMENTAL INCOME STATEMENT for the 12 months ended 31 March 2023 

Residential 

Business 

Revenue - price control 
Revenue - non price control 

Operating expenditure - excluding PU recharge 
impact 
PU opex recharge 
Operating expenditure - including PU recharge 
impact 
Depreciation - tangible fixed assets 
Amortisation - intangible fixed assets 

Other operating income 

Operating profit 

Surface water drainage rebates 

retail   
£'m   

61.3  
-  

(53.6)  
(3.0)  
(56.6)  

(2.1)  
(2.1)  

-  

0.5  

retail   
£'m   

-  
0.2  

-  
-  
-  

-  
-  

-  

Water 
resources   
£'m   

Water 
Network+   
£'m   

Wastewater 

Network+    Bioresources     
£'m     

£'m   

101.2  
-  

(80.0)  
(0.4)  
(80.4)  

(5.9)  
-  

327.8  
8.6  

(196.6)  
8.4  
(188.2)  

(68.9)  
(6.6)  

259.3  
-  

(113.9)  
(4.6)  
(118.5)  

(52.2)  
(0.1)  

24.3    
-    

(0.5)    
(0.3)    
(0.8)    

(7.9)    
-    

Total  
£'m 

773.9  
8.8  

(444.6)  
0.1  
(444.5)  

(137.0)  
(8.8)  

0.4  

0.9  

0.1  

0.1    

1.5  

0.2  

15.3  

73.6  

88.6  

15.7    

193.9  

0.2  

14 July 2023 
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2B  TOTEX ANALYSIS: WHOLESALE  

for the 12 months ended 31 March 2023

Base operating expenditure 
Power 
Income treated as negative 
expenditure 
Abstraction charges/ discharge 
consents 
Bulk Supply/Bulk discharge 
Renewals expensed in year 
(Infrastructure) 
Renewals expensed in year (Non-
Infrastructure) 
Other operating expenditure  
(including Location specific costs & 
obligations) 
Local authority and Cumulo rates 
Total base operating expenditure 

Other operating expenditure 
Enhancement operating expenditure  
Developer services operating 
expenditure 
Total operating expenditure 
excluding third party services 
Third party services 
Total operating expenditure 

Grants and contributions - operating 
expenditure 

Capital expenditure 
Base capital expenditure 
Enhancement capital expenditure 
Developer services capital 
expenditure 
Total gross capital expenditure 
excluding third party 
Third party services 
Total gross capital expenditure 

Grants and contributions - capital 
expenditure 

Water 

resources   
£'m   

Water 
Network+   
£'m   

Wastewater 

Network+   Bioresources     
£'m     

£'m   

Total 
£'m 

20.6  

(0.3)  

39.6  
1.2  

0.6  

0.2  

7.5  
4.2  
73.6  

1.2  

-  

74.8  
5.6  
80.4  

38.1  

43.6  

5.2    

107.5 

-  

0.4  
-  

0.4  

5.8  

111.7  
27.0  
183.4  

0.9  

-  

184.3  
3.9  
188.2  

-  

3.8  
-  

1.7  

2.7  

58.5  
7.7  
118.0  

0.2  

0.2  

118.4  
0.1  
118.5  

(19.5)    

(19.8) 

-    
-    

-    

0.2    

13.3    
1.6    
0.8    

-    

-    

0.8    
-    
0.8    

43.8 
1.2 

2.7 

8.9 

191.0 
40.5 
375.8 

2.3 

0.2 

378.3 
9.6 
387.9 

-  

-  

-  

-    

- 

21.8  
2.4  

-  

24.2  
-  
24.2  

117.3  
22.0  

20.5  

159.8  
-  
159.8  

66.7  
30.8  

1.5  

99.0  
-  
99.0  

3.5    
-    

-    

3.5    
-    
3.5    

209.3 
55.2 

22.0 

286.5 
- 
286.5 

-  

13.1  

2.0  

-    

15.1 

Net totex 

104.6  

334.9  

215.5  

4.3    

659.3 

Cash expenditure 
Pension deficit recovery payments 
Other cash items 
Totex including cash items 

0.6  
-  
105.2  

12.9  
-  
347.8  

6.1  
-  
221.6  

0.3    
-    
4.6    

19.9 
- 
679.2 

14 July 2023 
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2C  COST ANALYSIS: RETAIL 

for the 12 months ended 31 March 2023 

Operating expenditure 
Customer services 
Debt management 
Doubtful debts 
Meter reading 
Services to developers 
Other operating expenditure 
Local authority and Cumulo rates 
Total operating expenditure excluding third party services 

Depreciation 
Depreciation (tangible fixed assets) on assets existing at 31 March 
2015 

Depreciation (tangible fixed assets) on assets acquired after 1 April 
2015 
Amortisation (intangible fixed assets) on assets existing at 31 
March 2015 
Amortisation (intangible fixed assets) on assets acquired after 1 
April 2015 

Recharges 
Recharge from wholesale for legacy assets principally used by 
wholesale (assets existing at 31 March 2015) 
Income from wholesale for legacy assets principally used by retail 
(assets existing at 31 March 2015) 

Recharge from wholesale assets acquired after 1 April 2015 
principally used by wholesale 
Income from wholesale assets acquired after 1 April 2015 
principally used by retail 
Net recharges costs 

Total retail costs excluding third party and pension deficit repair 
costs 
Third party services operating expenditure 
Pension deficit repair costs 
Total retail costs including third party and pension deficit repair 
costs 

Debt written off 

Capital expenditure 

Residential 
£'m 

Business 
£'m 

15.5  
4.5  
18.0  
2.0  

9.4  
0.2  
49.6  

0.4  

1.7  

-  

2.1  

0.9  

(0.1)  

2.3  

(0.1)  
3.0  

56.8  

-  
4.0  

60.8  

12.6  

3.2  

-  
-  
-  
-  
-  
-  
-  
-  

-  

-  

-  

-  

-  

-  

-  

-  
-  

-  

-  
-  

-  

-  

-  

Total 
£'m 

15.5 
4.5 
18.0 
2.0 
- 
9.4 
0.2 
49.6 

0.4 

1.7 

- 

2.1 

0.9 

(0.1) 

2.3 

(0.1) 
3.0 

56.8 

- 
4.0 

60.8 

12.6 

3.2 

14 July 2023 
PAGE 160 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Other operating expenditure includes the net retail expenditure for the following household retail activities which are 
part funded by wholesale: 
Demand-side water efficiency - gross expenditure 
Demand-side water efficiency - expenditure funded by wholesale  
Demand-side water efficiency - net retail expenditure 

1.1  
1.1  
-  

Customer-side leak repairs - gross expenditure 
Customer-side leak repairs - expenditure funded by wholesale 
Customer-side leak repairs - net retail expenditure 

Comparison of actual and allowed expenditure 
Cumulative actual retail expenditure to reporting year end 
Cumulative allowed expenditure to reporting year end 
Total allowed expenditure 2020-25 

1.2  
1.2  
-  

175.5  
147.1  
247.5  

Retail revenue and cost reconciliation to FD 

Household retail revenue, reported in table 2I, was £61.3m, which was £1.1m lower than allowed in the FD. 

Household retail costs excluding pension deficit repair costs, in table 2C above, were £56.8m, which was £6.8m higher than allowed 

in the FD. 

The retail cost base is higher than the allowance in the FD, reflecting inflationary pressures on staff and other costs which were not 

allowed in the FD. 

14 July 2023 
PAGE 161 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2D  HISTORIC COST ANALYSIS OF TANGIBLE FIXED ASSETS 

for the 12 months ended 31 March 2023 

Residential 

Water 

Wastewater 

Retail    Business retail   
£'m   

£'m   

resources   Water Network+   
£'m   

£'m   

Network+    Bioresources     
£'m     

£'m   

Cost 
At 1 April 2022 
Disposals 
Additions 
Adjustments 
Assets adopted at nil cost 
At 31 March 2023 

Depreciation 
At 1 April 2022 
Disposals 
Adjustments 
Charge for year 
At 31 March 2023 

Net book amount at 31 March 
2023 

Net book amount at 1 April 2022  

Depreciation charge for year 
Principal services 
Third party services 
Total 

30.9   
(0.1)   
1.1   
-   
-   
31.9   

(25.2)   
0.1   
0.1   
(2.1)   
(27.1)   

4.8   

5.7   

(2.1)   
-   
(2.1)   

-   
-   
-   
-   
-   
-   

-   
-   
-   
-   
-   

-   

-   

-   
-   
-   

335.8   
(0.2)   
24.2   
(0.2)   
-   
359.6   

(75.5)   
0.1   
-   
(5.9)   
(81.3)   

278.3   

260.3   

(5.6)   
(0.3)   
(5.9)   

3,457.4   
(11.5)   
152.6   
0.3   
2.6   
3,601.4   

(1,294.5)   
7.2   
-   
(68.9)   
(1,356.2)   

3,054.0   
(0.7)   
99.1   
(0.2)   
24.2   
3,176.4   

(886.6)   
0.7   
0.1   
(52.2)   
(938.0)   

2,245.2   

2,238.4   

2,162.9   

2,167.4   

(68.9)   
-   
(68.9)   

(52.2)   
-   
(52.2)   

204.4     
(0.4)     
3.5     
0.1     
-     
207.6     

(141.8)     
0.4     
(0.2)     
(7.9)     
(149.5)     

58.1     

62.6     

(7.9)     
-     
(7.9)     

The net book value includes £265.2m in respect of assets in the course of construction.

Total 
£'m 

7,082.5 
(12.9) 
280.5 
- 
26.8 
7,376.9 

(2,423.6) 
8.5 
- 
(137.0) 
(2,552.1) 

4,824.8 

4,658.9 

(136.7) 
(0.3) 
(137.0) 

2 August 2023 
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2E  ANALYSIS OF ‘GRANTS AND CONTRIBUTIONS’: WATER RESOURCES, WATER NETWORK+ 

AND WASTEWATER NETWORK+ 
for the 12 months ended 31 March 2023 

Grants and contributions - water resources 
Diversions - s185 
Other contributions (price control) 
Price control grants and contributions 
Diversions - NRSWA 
Diversions - other non-price control 
Other contributions (non-price control) 
Total 

Value of adopted assets 

Grants and contributions - water network+ 
Connection charges 
Infrastructure charge receipts 
Requisitioned mains 
Diversions - s185 
Other contributions (price control) 
Price control grants and contributions before deduction of 
income offset 
Income offset 
Price control grants and contributions after deduction of 
income offset 
Diversions - NRSWA 
Diversions - other non-price control 
Other contributions (non-price control) 
Total 

Value of adopted assets 

Grants and contributions - wastewater network+ 
Receipts for on-site work 
Infrastructure charge receipts 
Diversions - s185 
Other contributions (price control) 
Price control grants and contributions before deduction of 
income offset 
Income offset 

Price control grants and contributions after deduction of 
income offset 
Diversions - NRSWA 
Diversions - other non-price control 
Other Contributions (non-price control) 
Total 

Value of adopted assets 

Fully 
recognised 
in income 
statement   
£'m   

Capitalised 
and 
amortised (in 
income 
statement)   
£'m   

Fully netted 

off capex   
£'m   

Total   
£'m   

-  
-  
-  
-  
-  
-  
-  

-  

-  
-  
-  
1.0  
-  

1.0  
-  

1.0  
0.7  
-  
0.1  
1.8  

-  

-  
-  
0.2  
(0.1)  

0.1  
-  

0.1  
-  
0.3  
-  
0.4  

-  

-  
-  
-  
-  
-  
-  
-  

-    

9.2  
1.2  
5.1  
-  
0.1  

15.6  
4.2  

11.4  
-  
-  
-  
11.4  

2.6    

-  
0.7  
-  
0.8  

1.5  
-  

1.5  
-  
-  
-  
1.5  

-  
-  
-  
-  
-  
-  
-  

-  
-  
-  
-  
-  

-  
-  

-  
-  
-  
-  
-  

-  
-  
-  
-  

-  
-  

-  
-  
-  
-  
-  

-  
-  
-  
-  
-  
-  
-  

-  

9.2  
1.2  
5.1  
1.0  
0.1  

16.6  
4.2  

12.4  
0.7  
-  
0.1  
13.2  

2.6  

-  
0.7  
0.2  
0.7  

1.6  
-  

1.6  
-  
0.3  
-  
1.9  

24.2    

24.2  

14 July 2023 
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Movements in capitalised grants and contributions 
Brought forward 
Received in year (above) 
Adopted assets 
Transferred from receipts in advance 
Amortisation (in income statement) 
Carried forward 

Water  
resources   

Water  
network+   

Wastewater 

network+   

£'m  

0.6  
-  
-  
-  
-  
0.6  

£'m  

£'m  

261.0  
11.4  
2.6  
2.1  
(3.7)  
273.4  

190.9  
1.5  
24.2  
0.4  
(2.3)  
214.7  

Total  
£'m  

452.5  
12.9  
26.8  
2.5  
(6.0)  
488.7  

Grants and contributions falling within the wholesale price control, and therefore also reported on table 2B, comprise 
connection charges, infrastructure charge receipts and requisitioned mains and sewers. 

14 July 2023 
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2F  RESIDENTIAL RETAIL 

for the 12 months ended 31 March 2023 

Residential revenue  
Wholesale charges 
Retail revenue 

Total residential revenue 

Retail revenue 
Revenue Recovered ("RR" ) 
Revenue sacrifice 
Actual revenue (net) 

Adjustment 
Allowed revenue ("R" )  
Net adjustment  

Customer information 
Actual customers ("AC" )  
Reforecast customers  

Revenue   
£'m   

Number of 
customers   
000s   

Average residential 
revenues 
£ 

544.6    
61.3    

605.9    

61.3    
-    
61.3    

62.4    
1.1    

1,971.7    
1,961.4    

Other residential information 
Average residential retail revenue per customer  

31.1 

14 July 2023 
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2G & 2H 

NON-HOUSEHOLD WATER AND WASTEWATER REVENUES BY TARIFF TYPE 

NWL  exited  the  NHH  retail  market  at  1  April  2017  and  transferred  its  NHH  retail  business  to  an  acquiring  licenced 
retailer, NWGB, another subsidiary of NWGL. 

In accordance with RAG 4.11, as NWL has exited all NHH market activities, we are no longer required to publish tables 
2G and 2H. 

NWL  still  provides  wholesale  water  and  wastewater  services  to  NHH  properties  in  our  areas  of  supply.  The  NHH 
wholesale revenue for the year ended 31 March 2023 was £168.0m, as reported in table 2I. 

14 July 2023 
PAGE 166 OF 211 

 
 
 
 
Total 
£'m 

182.0 
241.8 
5.2 
429.0 

Total 
£'m 

132.4 
2.1 
1.0 
77.3 
46.6 
23.1 
1.1 
283.6 

2I  REVENUE ANALYSIS for the 12 months ended 31 March 2023 

Wholesale charge - water 
Unmeasured 
Measured 
Third party revenue 
Total wholesale water revenue 

  Household  
£'m  

Non- 
household  
£'m  

180.5  
156.2  
0.8  
337.5  

1.5  
85.6  
4.4  
91.5  

Total  
£'m  

182.0  
241.8  
5.2  
429.0  

Water 
resources  
£'m  

Water 
network+  
£'m  

45.9  
54.8  
0.5  
101.2  

136.1  
187.0  
4.7  
327.8  

  Household  
£'m  

Non- 
household  
£'m  

Wastewater 

Total  
£'m  

network+   Bioresources  
£'m  

£'m  

120.8  
1.9  
0.9  
70.9  
42.5  
21.2  
1.1  
259.3  

11.6  
0.2  
0.1  
6.4  
4.1  
1.9  
-  
24.3  

Wholesale charge - wastewater 
Unmeasured - foul charges 
Unmeasured - surface water charges   
Unmeasured - highway drainage 
charges 
Measured - foul charges 
Measured - surface water charges 
Measured - highway drainage 
charges 
Third party revenue 
Total wholesale wastewater revenue   

Wholesale charge - Additional Control 
Unmeasured 
Measured 
Total wholesale additional control 
revenue 

131.7  
0.3  
0.2  
38.1  
23.4  
12.3  
1.1  
207.1  

-  
-  
-  

0.7  
1.8  
0.8  
39.2  
23.2  
10.8  
-  
76.5  

-  
-  
-  

132.4  
2.1  
1.0  
77.3  
46.6  
23.1  
1.1  
283.6  

-    
-    
-    

Wholesale Total 

544.6  

168.0  

712.6    

Retail revenue 
Unmeasured 
Measured 
Other third party revenue 
Retail Total 

Third party revenue - non-price control 
Bulk supplies - water 
Bulk supplies - wastewater 
Other third party revenue 

Principal services - non-price control 
Other appointed revenue 

Total appointed revenue 

27.1  
34.2  
-  
61.3  

-  
-  
-  
-  

27.1    
34.2    
-    
61.3    

3.5    
-    
5.0    

0.3    

782.7    

14 July 2023 
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2I  REVENUE ANALYSIS for the 12 months ended 31 March 2023 (continued) 

Wholesale revenue control reconciliation to FD 

Charges  for  2022/23  were  set  in  accordance  with  the  price  controls  set  by  Ofwat  in  its  PR19  Final  Determination  subsequently 

adjusted by the CMA appeal process.  

During the COVID-19 pandemic we have seen an increase in household consumption due to the impact of various lockdown periods 

and customers working from home. This increased consumption trend has now stopped, and we are seeing reduced levels due to 

people now returning to workplaces.  Various initiatives have continued during the year which have led to a reduction in the number 

of household voids to a void rate of 3.39% at the year end. 

For  our  non-household  charging  base,  during  the  year  we  have  seen  consumption  increase  slightly  in  line  with  the  return  to 

workplaces noted above. Non-household voids have remained relatively stable. 

Wholesale water revenue in 2022/23 was £2.7m (0.8%) lower than the revenue cap income allowance. This is all within the network+ 

price control.    Also  within  the  network+  price  control,  grants  and  contributions  income  was  £8.8m  (42%)  lower  than  the  allowed 

revenue for the period, this is partly due to the ongoing impact of the COVID-19 pandemic and the subsequent economic downturn 

which has slowed down construction.  

Wholesale wastewater revenue in 2022/23 was £2.2m (0.8%) lower than the revenue cap income allowance.  This is split between 

the  network+  and  bioresources  price  controls  which  were  £1.8m  (0.7%)  lower  and  £0.4m  (1.6%)  lower  respectively.   Within  the 

network+ price control, grants and contributions income is £2.3m (59%) lower than the allowed revenue for the period, this is partly 

due to the ongoing impact of the COVID-19 pandemic and the subsequent economic downturn which has slowed down construction.  

The revenue imbalances in the table above (for water resources and the network+ controls) will be incorporated into the Revenue 

Forecasting Incentive model and will be corrected within charges for 2024/25 against the relevant price controls. 

14 July 2023 
PAGE 168 OF 211 

 
 
 
 
 
2J  INFRASTRUCTURE NETWORK REINFORCEMENT COSTS for the 12 months ended 31 March 

2023 

Wholesale water network+ (treated water distribution) 
Distribution and trunk mains 
Pumping and storage facilities 
Other 
Total 

Wholesale wastewater network+ (sewage collection) 
Foul and combined systems 
Surface water only systems 
Pumping and storage facilities 
Other 
Total 

Network 
reinforcement 
capex  
£'m  

On site / site 
specific capex 
(memo only) 
£'m 

3.8  
1.2  
-  
5.0  

-  
-  
-  
-  
-  

- 
- 
- 
- 

- 
- 
- 
- 
- 

2K  INFRASTRUCTURE CHARGES RECONCILIATION for the 12 months ended 31 March 2023 

Impact of infrastructure charge discounts 

Infrastructure charges 

Discounts applied to infrastructure charges 

Gross infrastructure charges 

Comparison of revenue and costs 

Variance brought forward 

Revenue 

Costs 

Variance carried forward 

Water 

  Wastewater 

£'m 

1.2 

0.1 

1.3 

- 

1.2 

(5.0) 

(3.8) 

£'m 

0.7 

0.1 

0.8 

- 

0.7 

- 

0.7 

Total 

£'m 

1.9 

0.2 

2.1 

- 

1.9 

(5.0) 

(3.1) 

Reconciliation of infrastructure charges and network reinforcement costs 

Infrastructure charges are set at a level to fund investment in reinforcement of our networks, to meet the demand arising from new 

development of household properties. We are required to ensure that revenue from infrastructure charges broadly matches network 

reinforcement expenditure over a five year rolling period. 

We review infrastructure charges annually, taking account of extra capacity expected to be required as a result of new developments 

in  the  following  five  years.  Our  forecast  reflects  applications  received  for  the  provision  of  new  infrastructure,  pre-development 

enquiries and a longer term view of local authority plans and strategic studies. 

14 July 2023 
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Water 

During  2022/23,  expenditure  on  water  network  reinforcement  projects  was  greater  than  infrastructure  charges  receipts.  The  net 

position  at  the  end  of  2022/23  was  that  the  cumulative  expenditure  on  water  network  reinforcement  is  £0.3m  more  than  the 

infrastructure charge income received (2021/22: £3.5m less). The projected network reinforcement expenditure over the next five 

years is expected to be significant to support new development growth.  Our plan is to increase water infrastructure charges to fund 

the next five year’s reinforcement expenditure.  

Wastewater 

During 2022/23, expenditure on wastewater network reinforcement projects was less than infrastructure charges receipts. The net 

position at the end of 2022/23 was that the  cumulative expenditure on wastewater network reinforcement is £0.9m less than the 

infrastructure charge income received (2021/22: £0.3m less). The projected network reinforcement expenditure over the next five 

years has been reassessed and is not expected to be significant. Wastewater infrastructure charges are expected to remain at their 
reduced level. 

2L  LAND SALES for the 12 months ended 31 March 2023 

Water 
resources 
£'m 

Water 
Network+ 
£'m 

Wastewater 
Network+ 
£'m 

Total 
£'m 

Land sales – proceeds from disposals of protected 
land 

0.6  

5.1  

-  

5.7 

Land Sales during 2022/23 

Land sales includes three property disposals. 

One of these was above the threshold set in our Licence for reporting to Ofwat: 

•  Boldon House, Pity Me, Durham  
We can confirm that all qualifying disposals were reported to Ofwat. 

14 July 2023 
PAGE 170 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2M  REVENUE RECONCILIATION: WHOLESALE for the 12 months ended 31 March 2023 

Water 
resources  

Water 
network+   

Wastewater 
network+ 

  £'m 

  £'m 

  £'m 

  Bioresources   Total 
  £'m 

  £'m 

Revenue recognised  
Wholesale revenue governed by price control 
Grants & contributions (price control) 
Total revenue governed by wholesale price control   101.2 

  101.2 

- 

  327.8 
  12.4 
  340.2 

  259.3 
  1.6 
  260.9 

  24.3 
- 
  24.3 

  712.6 
  14.0 
  726.6 

101.2 

  321.8 

  258.7 

  24.7 

  706.4 

Calculation of the revenue cap 
Allowed wholesale revenue before adjustments (or 
modified by CMA) 
Allowed grants & contributions before adjustments 
(or modified by CMA) 
Revenue adjustment 
Other adjustments 
Revenue cap 

- 
- 
- 

  101.2 

  21.1 
- 
- 

  4.0 
- 
- 

  342.9 

  262.7 

Calculation of the revenue imbalance  
Revenue cap  
Revenue Recovered  
Revenue imbalance  

  101.2 
  101.2 

- 

  342.9 
  340.2 
  2.7 

  262.7 
  260.9 
  1.8 

- 
- 
- 
  24.7 

  24.7 
  24.3 
  0.4 

  25.1 
- 
- 

  731.5 

  731.5 
  726.6 
  4.9 

14 July 2023 
PAGE 171 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2N  RESIDENTIAL RETAIL SOCIAL TARIFFS for the 12 months ended 31 March 2023 

Number of residential customers on social tariffs 
Residential water only social tariffs 
Residential wastewater only social tariffs 
Residential dual service social tariffs  

Number of residential customers not on social tariffs 
Residential water only no social tariffs 
Residential wastewater only no social tariffs 
Residential dual service no social tariffs 

Social tariff discount 
Average discount per water only social tariffs customer 
Average discount per wastewater only social tariffs customer 
Average discount per dual service social tariffs customer 

Revenue 
£'m 

Number of 
customers 
000s 

14.9  
1.0  
42.2  

763.0  
67.5  
1,083.1  

Social tariff cross-subsidy - residential customers 
Total customer funded cross-subsidies for water only social tariffs 
customers 
Total customer funded cross-subsidies for wastewater only social tariffs 
customers 
Total customer funded cross-subsidies for dual service social tariffs 
customers 
Average customer funded cross-subsidy per water only social tariffs 
customer 
Average customer funded cross-subsidy per wastewater only social tariffs 
customer 
Average customer funded cross-subsidy per dual service social tariffs 
customer 
Social tariff cross-subsidy - company 
Total revenue forgone by company to fund cross-subsidies for water only social 
tariffs customers 
Total revenue forgone by company to fund cross-subsidies for wastewater only 
social tariffs customers 
Total revenue forgone by company to fund cross-subsidies for dual service 
social tariffs customers 
Average revenue forgone by company to fund cross-subsidy per water only 
social tariffs customer 
Average revenue forgone by company to fund cross-subsidy per wastewater 
only social tariffs customer 
Average revenue forgone by company to fund cross-subsidy per dual service 
social tariffs customer 

Social tariff support - willingness to pay 
Level of support for social tariff customers reflected in business plan 
Maximum contribution to social tariffs supported by customer engagement 

1.1  

0.1  
4.1  

-  

-  

-  

Average 
amount 
per 
customer 
£ 

- 
- 
- 

- 
- 
- 

76.8 
125.1 
96.1 

1.5 

1.9 
3.6 

- 

- 

- 

2.1 
3.4 

14 July 2023 
PAGE 172 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2O  HISTORIC COST ANALYSIS OF INTANGIBLE FIXED ASSETS for the 12 months ended 31 March 2023 

Cost 
At 1 April 2022 
Disposals 
Additions 
Adjustments 
Assets adopted at nil cost 
At 31 March 2023 

Amortisation 
At 1 April 2022 
Disposals 
Adjustments 
Charge for year 
At 31 March 2023 

Net book amount at 31 March 2023 

Net book amount at 1 April 2022 

Amortisation for year 
Principal services 
Third party services 
Total 

Residential 
Retail  
£'m  

Business 
Retail  
£'m  

Water 

Wastewater 

Resources   Water Network+  
£'m  

£'m  

Network+   Bioresources  
£'m  

£'m  

36.8  
-  
2.0  
0.1  
-  
38.9  

(10.0)  
-  
-  
(2.1)  
(12.1)  

26.8  

26.8  

(2.1)  
-  
(2.1)  

-  
-  
-  
-  
-  
-  

-  
-  
-  
-  
-  

-  

-  

-  
-  
-  

-  
-  
-  
-  
-  
-  

-  
-  
-  
-  
-  

-  

-  

-  
-  
-  

91.5  
-  
7.3  
(0.2)  
-  
98.6  

(66.9)  
-  
-  
(6.6)  
(73.5)  

25.1  

24.6  

(6.6)  
-  
(6.6)  

0.9  
-  
-  
0.1  
-  
1.0  

(0.8)  
-  
-  
(0.1)  
(0.9)  

0.1  

0.1  

(0.1)  
-  
(0.1)  

0.3  
-  
-  
-  
-  
0.3  

(0.1)  
-  
-  
-  
(0.1)  

0.2  

0.2  

-  
-  
-  

Total 
£'m 

129.5 
- 
9.3 
- 
- 
138.8 

(77.8) 
- 
- 
(8.8) 
(86.6) 

52.2 

51.7 

(8.8) 
- 
(8.8) 

The net book value includes £5.9m in respect of assets in the course of construction. 

14 July 2023 
PAGE 173 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DISCLOSURE OF TRANSACTIONS WITH ASSOCIATES 

Services supplied to the appointee by associated companies: 

Nature of transaction 

  Company 

Holding company charges 

  NWGL 

Public liability insurance 
(deductible infill policy) 

Vehicle maintenance and capital 
finance charge 

Corporation tax group relief 
surrendered by regulated 
business 
Corporation tax group relief 
surrendered by regulated 
business 

Three Rivers 
Insurance Company 
Limited (TRICL) 
Vehicle Lease and 
Service Limited 
(VLS) 
Caledonian 
Environmental 
Levenmouth 
Treatment Services 
Limited 

Reiver Finance 
Limited 

Turnover of 

associate   
£'m   

6.9  

0.4  

Terms of supply   

No market  

Value 
£'m 

2.200 

No market  

0.305 

20.5  

Competitive letting  

15.146 

15.9  

18.3  

No market  

1.509 

No market  

0.050 

Services supplied by the appointee to associated companies: 

Nature of transaction 

  Company 

Sale of materials 
Rental of garage and service 
charges 
Service charge in compliance with 
the WROA agreement 

UK:UK transfer pricing tax 
adjustment 
UK:UK transfer pricing tax 
adjustment 

  AquaGib Limited 

VLS 
Reiver Finance 
Limited 

Northumbrian Water 
Finance Limited 
Northumbrian Water 
Group Limited 

Turnover of 

associate   
£'m   

17.2  

20.5  

18.3  

-  

6.9  

Terms of supply   

Negotiated  

Value 
£'m 

0.145 

Negotiated  

0.100 

No market  

0.199 

No market  

0.049 

No market  

0.697 

Turnover data for all companies relates to the year to 31 March 2023, with the exception of data for VLS which relates to the 
year to 31 December 2022. 

Payment for tax losses transferred between group/associated companies and UK:UK transfer pricing adjustments is calculated 
as the gross amount of the item multiplied by the corporation tax rate for the year. 

Services provided to the non-appointed business: 

Treatment of imported sludge 

Treatment of tankered waste 

The average unit cost per tonne dry solid is calculated using 
operating costs only and excluding payroll.  This gives a unit rate 
which is more than the incremental cost but less than the income 
received therefore sharing the benefit of the activity. 
The recharge comprises recovery of operating costs of operator 
time and sampling and analysis and a charge for the use of 
appointed business assets, calculated using the Biological and 
Sludge elements of the trade effluent charge set out in the 
Company’s Wholesale Charges Scheme. 

Other 

  Other assets are specifically identified to the appropriate business.  

£'m 

- 

1.084 
- 

14 July 2023 
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Information in relation to allocations and apportionments 

The appointed and non-appointed businesses operate separate accounting records including sales and purchase ledgers.  Revenue, 

operating costs, assets and liabilities are taken directly from these records. 

Revenue is separately recorded between wholesale water and wastewater and household and non-household retail services and no 

apportionment has been necessary.  Operating costs have been allocated between wholesale water and wastewater and household 

and non-household retail services in accordance with the guidance set out in RAG 4.11. 

Overhead costs incurred in the appointed business which relate to the non-appointed business have been allocated using an activity 

based approach to comply with RAG 5.07. 

Interest has been allocated between the appointed and non-appointed businesses on the basis of actual cash balances held by these 

businesses  during  the  year  at  market  rates.    Capital  costs  and  the  related  depreciation  charges  are  specifically  identifiable  to  the 

appropriate business and service. 

The  surrender  of  tax  losses  to  the  non-appointed  business  recognises  that  the  appointed  business  has  tax  losses  while  the  non-

appointed business has taxable profits which will be offset within the appointee’s tax return. 

Borrowings 

At 31 March 2023, the appointee's appointed business had the following borrowings issued by associated 
companies: 

Company 

  Loan type 

Northumbrian Water Finance plc 

Northumbrian Water Group Limited 

VLS 

  Fixed rate Eurobond   
  Fixed rate Eurobond   

Index linked 
Eurobond 
Index linked 
Eurobond 
Index linked 
Eurobond 
Index linked 
Eurobond 

  Fixed rate Eurobond   
  Fixed rate Eurobond   
  Fixed rate Eurobond   
Index linked Private 
Placement 

  Fixed rate Eurobond   
  Fixed rate Eurobond   
Feb-31  
  Overnight borrowing    On demand  
Various  
  Lease 

Maturity 
date  

Feb-23  

Apr-33  

Jul-36  

Interest rate   
%  

6.875  
5.625  

2.033  

Balance at 31 
March 2023 

£'m 

- 

344.443 

270.386 

Jan-41  

1.6274  

107.157 

Jul-49  

1.7118  

177.601 

Jul-53  

Jan-42  

Oct-26  

Oct-27  

1.7484  
5.125  
1.625  
2.375  

Oct-39   CPI + 0.242   
6.375  
Oct-34  
4.5  
5.25  

177.599 

343.086 

299.066 

298.493 

117.413 

390.953 

346.606 

33.000 

12.628 

5.5  

14 July 2023 
PAGE 175 OF 211 

 
 
 
 
 
   
   
   
   
 
 
   
   
 
 
   
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
At 31 March 2023, the appointee's non appointed business had the following loan issued to an associated company: 

Company 

  Loan type 

Bakethin Holdings Limited 

  Variable 

Guarantees or other forms of security 

Maturity 
date  

Interest rate   
%  

Jan-34  

SONIA 
minus 39bp  

Balance at 31 
March 2023 

£'m 

1.886 

There were no guarantees or other forms of security provided by the appointee to any associate during the year, other than those 

relating to amounts borrowed from NWF, outlined above. 

Omission of right 

There were no omissions by the appointee to exercise any rights which would cause the net assets to decrease. 

Waivers 

There were no waivers by the appointee of any consideration, remuneration or other payment owed to it by any associated company. 

The information in this note has been produced to comply with the requirements of RAG 5.07 Transfer Pricing in the Water Industry 

and the disclosures required by paragraph 6 of Condition F of the Company’s operating licence. 

The Directors confirm that, to the best of their knowledge, all transactions with associated companies have been disclosed. 

14 July 2023 
PAGE 176 OF 211 

 
 
 
 
   
   
   
   
 
 
   
   
 
 
   
   
   
   
 
 
 
 
 
Dividend Disclosure 

Dividends paid during the year 

During the year, the following ordinary dividends were paid by NWL to NWGL, its immediate parent company: 

Ordinary dividends paid: 

Final dividend for the year ended 31 March 2022 (31 March 2021) 

Interim dividend for the year ended 31 March 2023 (31 March 2022) 

Appointed business 

Dividend yield, as reported in table 4H 

2022/23 
£m 

2021/22 
£m 

55.4 

55.4 

110.8 

6.9% 

123.3 

58.2 

181.5 

13.2% 

Dividends paid in respect of the year 

The Board determines dividends for the year to which they relate, which typically comprises an interim dividend paid during the year 

and a final dividend paid after the year end. 

After the balance sheet date, the Board approved a final dividend of £25.3m. This equated to a 5% dividend yield for dividends paid 

in respect of 2022/23. 

Ordinary dividends paid in respect of the year: 

Interim dividend for the year ended 31 March 2023 (31 March 2022) 

Final dividend for the year ended 31 March 2023 (31 March 2022) 

Appointed business 

Dividend yield in respect of the year 

2022/23 
£m 

2021/22 
£m 

55.4 

25.3 

80.7 

5.0% 

58.2 

55.4 

113.6 

8.2% 

The Board approved a revised dividend policy during the year. 

Dividend policy 

NWL  considers  that  its  dividend  policy  should  be  transparent,  recognising  the  company’s  commitments  to  various  stakeholders 

including  customers,  employees,  specifically  pension  scheme  obligations,  and  investors,  and  with  due  attention  to  maintaining 

appropriate levels of financial resilience within the company. 

A key overarching principle behind NWL’s approach to dividends is that its owners should be able to receive a competitive and fair 

return on their investment which reflects the underlying risk profile of the business. This ensures  that there will be access to the 

necessary capital required to make investments for customer needs now and in the future. 

NWL is seeking to maintain a progressive dividend policy that takes into account long-run financial performance and ensures that an 

efficient balance sheet is maintained. In line with the businesses’ vision of being an industry leader, the policy seeks a competitive 

return consistent with a high-performing water company and to maximise returns over the long-term.  

14 July 2023 
PAGE 177 OF 211 

 
 
 
 
 
 
 
 
To deliver this the dividend policy will be based on four components: 

• 
• 

• 

• 

a base dividend component largely derived from the price control determination;  
a  performance  component  linked  to  business  performance  and  a  fair  assessment  of  outcomes  for  customers  and  the 
environment; 
a financial resilience adjustment designed to appropriately calibrate the company’s overall gearing levels with the underlying 
risk profile of the business; and 
a smoothing adjustment to take into account smaller ad-hoc movements within any year that are expected to reverse out 
over the AMP. 

These components are discussed in turn below. 

Base dividend component 

The approach to setting the base dividend is that it should broadly reflect the real cost of equity based on the capital structure as 

established in the latest regulatory determination, on the assumption that the regulatory cost of equity will always be set at a level 

that ensures the company remains financeable.  

Performance component 

The regulatory framework incentivises companies to meet or exceed regulatory targets and shares these gains or losses between 

shareholders and customers. The base dividend will be adjusted up or down to reflect business performance in 3 areas: 

totex performance: cost savings after the application of the regulatory approach to cost-sharing. 

• 
•  ODI performance: net ODI rewards from improved outcomes for customers. 
• 

financing  performance:  where  the  company  is  able  to  secure  debt  financing  at  lower  rates  than  assumed  by  the  latest 
regulatory determination. 

Financial resilience adjustment 

Financial resilience adjustments are designed to ensure the company maintains a prudent investment grade credit rating and an 

appropriate buffer to absorb relevant financial risks. To achieve this an adjustment will be made to ensure that any real terms growth 

in the regulatory capital value is funded from both debt and equity in line with an efficient capital structure.  

Smoothing adjustment 

To  provide stability  in  dividends  a  further  adjustment  may be  made  to  ensure  that over a  regulatory  cycle  there  is  a more  even 

allocation of dividends. This is because expenditure within an AMP is not evenly spread and aligned with the phasing of the price 

control determination, and unexpected events (positive and negative) can impact financial performance in the short term.  

In making these adjustments, the Board will aim to match dividends over a cumulative period of up to five years to the level required 

to deliver the policies set out under the first three components of the policy. 

14 July 2023 
PAGE 178 OF 211 

 
 
 
 
 
 
 
Application of Dividend Policy 

The Board has approved a revised dividend policy which took effect for the year ended 31 March 2023. This is set out above. 

For the year ended 31 March 2023 the Board approved payment of an interim dividend of £55.4m and, after the balance sheet date, 

approved payment of a final dividend of £25.3m.  In reaching these decisions the Board took full account of its revised dividend policy 

and, in the case of the final dividend, revised Licence Condition P30 and the associated guidance. 

The total dividend paid in respect of 2022/23 was £80.7m, comprising: 

Base return 
Totex performance 
ODI performance 
Financing performance (including inflation) 

Total return including inflation 
Less: Financing performance (including inflation) 
Financing performance (due to management action) 
Total return including performance 
Smoothing adjustment 

Total dividend in respect of 2022/23 

£m 

85.3 
(14.1) 
(0.4) 
156.7 

227.5 
(156.7) 
49.8 
120.6 
(39.9) 

80.7 

•  Base return reflects the real cost of equity based on the capital structure as established in the Final Determination. This is the 

base return that NWLs shareholders receive for the c.£1.6bn of equity capital that is currently deployed in NWL and reflecting 

the risk of that investment. 

• 

Totex  performance  represents  the  Company’s  share  of  wholesale  performance,  as  set  out  in  table  4C,  and  Retail  costs 

compared to the Final Determination allowance. Like other appointed water companies NWL receives a cost allowance from 

Ofwat every five years to deliver agreed service levels to customers. Where NWL is able to outperform the cost allowances 

customers will gain 55% of any savings made with the business retaining 45%. Similarly, if the business overspends then 55% 

of any overspend is borne by the business with 45% being borne by customers. This provides incentives to reduce costs but 

also protection for customers and the business. The base return above needs to be adjusted for totex performance. This is an 

underperformance due to NWL overspending against its allowances primarily due to increased power prices in the year, which 

are somewhat outside the control of the business, which is deducted from the base return. 

•  ODI performance reflects the rewards and penalties for the year reported in table 3H plus an estimate of the C-MeX and D-

MeX rewards which will received for performance in 2022/23. Water companies are required to deliver stretching service levels 

to customers and rewarded ‘Outcome Delivery Incentives’ (ODIs) if they exceed those targets or incur penalties if they fail to 

meet them. Incentives are set broadly based on customers’ willingness to pay for improvement or avoid service deterioration. 

This also reflects a small negative adjustment to be deducted from the base return as whilst NWL has performed well on many 

metrics including, for example, coming first in the industry for customer service (CMeX) and strong performance on pollutions 

and GHG emissions earning the business rewards it has also incurred penalties for under-performance on issues like Drinking 

Water Quality and interruptions to supply. The net effect is a small negative adjustment to be deducted from the base return.  

• 

Financing performance relates to the significant costs of financing such a large capital programme. Every five years Ofwat 

sets a framework for ensuring that companies can recover the efficient cost of financing their investment programmes, including 

debt financing. Again where companies can raise finance more cheaply than Ofwat assumes the company can gain rewards 

and customers also benefit but if financing costs are higher companies will incur penalties. Performance in this area reflects 

those elements which have arisen as a result of NWL’s Board decisions and actions comprising: The company’s share of land 

sales as reported in table 2L (i.e. where NWL has sold land the proceeds from this are shared 50:50 with customers), the benefit 

gained from the Company retaining a lower proportion of index-linked debt in comparison to the rest of the industry which has 

14 July 2023 
PAGE 179 OF 211 

 
 
 
 
 
 
hedged costs for customers against the impact of high inflation on nominal interest costs; and the difference between the real 

cost of debt and the allowance in the FD due to financing decisions that have enabled NWL to raise finance at lower costs that 

Ofwat assumed in the FD. These financing outperformance benefits are added to the base return. 

•  Smoothing adjustment takes account of future investment needs over the final two years of AMP7 which will see a significant 

increase in capital investment to deliver the Company’s obligations and maintain the health of the asset base. 

The total dividend paid in respect of 2022/23 represents a dividend yield of 5% when compared against actual year end regulated 

equity. This is different to the dividend yield reported in table 4H which is based on dividends paid during 2022/23 and includes 

dividends declared for the previous year 2021/22 (following two years in 2019-20 and 2020-21 when no dividends were paid) rather 

than for 2022/23.  

In  reaching  its  decisions  on  dividends,  the  Board  took  account  of  performance  for  customers  and  the  environment,  its  broader 

obligations and longer term financial resilience. 

•  Customer and environment – the Company has performed well overall achieving 1st place for C-MeX, zero category 1 or 2 

pollutions,  continued  improvements  in  sewer  flooding  and  strong  greenhouse  gas  performance.  The  Board  recognises  the 

challenges on water quality (CRI) and interruptions to supply performance and has committed action plans to improve these. 

Overall, for performance commitments in 2022/23, 27 were met and 18 were not, so the majority (60%) were met.   

•  Obligations  –  the  Board  has  confirmed  that  it  considers  the  Company  is  meeting  its  relevant  obligations  in  its  Risk  and 

Compliance Statement on page 126. The Company continues to cooperate with the ongoing FFT investigations and took prompt 

action  to address  the small  number  of  sites  where  there  was a  risk  that  FFT  requirements may  not  always have  been  met. 

Additional investment was made, funded by shareholders, to increase the level of monitoring and reflecting any minor detriment 

that may have arisen from those sites. 

• 

Financial resilience – the Directors have confirmed the Company’s financial resilience up to 2030 as described in the Viability 

Statement on page 130. The Company is developing it Business Plan for 2025-2030 and latest forecasts suggest a significant 

increase in capital investment which is likely to require additional equity investment. This will be addressed as the PR24 process 

progresses but the business is seeking to accelerate investment into the 2023-25 period to reduce the delivery risk of such a 

large capital programme. Additional equity may be required in 2024/25 to support the delivery of further investment with further 

equity injections required in the 2025-30 period. The Board is seeking assurance from the ultimate controllers of NWL that his 

equity can be provided. We further note that the dividend paid is less than service performance to customers and less than the 

total return including inflation outperformance and so will retain further equity capital within the business strengthening future 

financial resilience. 

The Board is satisfied that, in the round, the dividends paid in respect of 2022/23 fairly represent the Company’s overall performance 

for its customers and stakeholders. 

Final dividend for the year ended 31 March 2022 

A final dividend of £55.4m was paid in respect of the year ended 31 March 2022, though actually paid during 2022/23. This was paid in 

accordance with the previous dividend policy, as published in the 2021/22 APR. In approving this dividend, the Board took account of 

the  underlying  financial  performance  of  the  business,  excluding  non-cash  movements  in  respect  of  the  deferred  tax  restatement, 

valuation of derivatives and the impact of high inflation on index-linked debt accretion, and the Company’s five year plan which remained 

compatible with investment grade credit ratings. The Board also took into account the principal risks facing the business, continued high 

levels of customer service, performance against regulatory commitments and positive employee engagement. 

In considering performance for customers, the Board took account of the full range of performance commitments both where the PC 

was achieved and where performance fell short of the target, noting that the overall performance was a net ODI reward, excluding the 

exceptional storm Arwen event. Areas of positive performance included: 

14 July 2023 
PAGE 180 OF 211 

 
 
 
 
• 

excellent customer service results on C-MeX (top two in the industry) and D-MeX, along with further extension of affordability 

support to customers and reduction in number of void properties; 

• 

continued industry-leading performance on interruptions to supply (excluding the exceptional storm Arwen event) and positive 

outcomes on burst mains and contact levels on appearance, taste and smell of water; 

awarding of 4* EPA, reflecting excellent overall environmental performance; and 

further progress on reducing greenhouse gas emissions towards our objective of being net zero by 2027. 

• 

• 

In respect of areas requiring improvement, the Board took account of the action plans being carried out to improve these areas, including: 

• 

the  substantial  investment  to  improve  water  quality  and  compliance  risk  index  score,  working  closely  with  the  DWI  on  a 

transformation plan; 

• 

• 

additional commitment both in terms of resources and investment to reduce leakage levels; and 

innovative approaches to reduce the causes of sewer flooding, such as the Bin The Wipe campaign, as part of a broader 

flooding tactical plan. 

The Board also considered the significant interruptions to supply resulting from storm Arwen, noting that these were largely caused by 

power supply failures and recognising the tremendous effort put in by our teams to minimise disruption and return customers to supply 

as quickly as possible. 

14 July 2023 
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INDEPENDENT AUDITOR’S REPORT TO THE WATER SERVICES REGULATION AUTHORITY (THE WSRA) AND 

THE DIRECTORS OF NORTHUMBRIAN WATER LIMITED 

Opinion 

We have audited the sections of Northumbrian Water Limited’s Annual Performance Report for the year ended 31 March 2023 (“the 

Regulatory Accounting Statements”) which comprise: 

• 

the  regulatory  financial  reporting  tables  comprising  the  income  statement  (table  1A),  the  statement  of  comprehensive 

income (table 1B), the statement of financial position (table 1C), the statement of cash flows (table 1D), the net debt analysis 

(table 1E), lines 1F.1 to 1F.3, 1F.5 to 1F.8, 1F.12 to 1F.14, 1F.21 to 1F.22 and 1F.24 to 1F.26 of the statement of financial 

flows (table 1F) and the related notes; and 

• 

the regulatory price review and other segmental reporting tables comprising the segmental income statement (table 2A), 

the  totex  analysis  for  wholesale  water  and  wastewater  (table  2B),  the  operating  cost  analysis  for  retail  (table  2C),  the 

historical cost analysis of fixed assets for wholesale and retail (table 2D), the analysis of grants and contributions and land 

sales  for  wholesale  (table  2E),  the  household  water  revenues  by  customer  type  (table  2F),  the  non-household  water 

revenues by customer type (table 2G), the non-household wastewater revenues by customer type (table 2H), the revenue 

analysis  &  wholesale  control  reconciliation  (table  2I),  the  infrastructure  network  reinforcement  costs  (table  2J),  the 

infrastructure charges reconciliation (table 2K), the analysis of land sales (table 2L), the revenue reconciliation for wholesale 

(table 2M), residential retail social tariffs (table 2N) and historical cost analysis of intangible assets (table 2O) and the related 

notes. 

We have not audited lines 1F.4, 1F.9 to 1F.11, 1F.15 to 1F.20 and 1F.23 of the statement of financial flows (table 1F), the Outcome 

performance table (tables 3A to 3I) or the additional regulatory information in tables 4A to 4W, 5A to 5B, 6A to 6F, 7A to 7F, 8A to 

8D, 9A, 10A to 10E and 11A. 

In  our opinion,  Northumbrian Water  Limited’s  Regulatory  Accounting  Statements  have been  prepared,  in  all material aspects,  in 

accordance with Condition F, the Regulatory Accounting Guidelines issued by the WSRA (RAG 1.09, RAG 2.09, RAG 3.14, RAG 

4.11  and  RAG  5.07)  and  the  accounting  policies  (including  the  Company’s  published  accounting  methodology  statement(s),  as 

defined in RAG 3.14, appendix 2), set out in section 4. 

Basis for opinion 

We conducted our audit in accordance with International Standards on Auditing (UK) (“ISAs (UK)”), including ISA (UK) 800, and 

applicable law, except as stated in the section on Auditors’ responsibilities for the audit of the Regulatory Accounting Statements 

below, and having  regard  to the  guidance contained in  ICAEW  Technical  Release Tech 02/16  AAF  ‘Reporting  to  Regulators  on 

Regulatory Accounts’ issued by the Institute of Chartered Accountants in England & Wales. 

Our responsibilities under ISAs (UK) are further described in the Auditors’ responsibilities for the audit of the Regulatory Accounting 

Statements within the Annual Performance Report section of our report. We are independent of the Company in accordance with 

the ethical requirements that are relevant to our audit, including the Financial Reporting Council’s (FRC’s) Ethical Standard as applied 

to public interest entities, and we have fulfilled our ethical responsibilities in accordance with these requirements. We believe that 

the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. 

Emphasis of matter – special purpose basis of preparation 

We draw attention to the fact that the Regulatory Accounting Statements have been prepared in accordance with a special purpose 

framework,  Condition  F,  the  Regulatory  Accounting  Guidelines,  the  accounting  policies  (including  the  Company’s  published 

accounting methodology statement(s), as defined in RAG 3.14, appendix 2) set out in the statement of accounting policies and under 

the historical cost convention. The nature, form and content of the Regulatory Accounting Statements are determined by the WSRA. 

14 July 2023 
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As a result, the Regulatory Accounting Statements may not be suitable for another purpose.  It is not appropriate for us to assess 

whether the nature of the information being reported upon is suitable or appropriate for the WSRA’s purposes. Accordingly we make 

no such assessment. In addition, we are not required to assess whether the methods of cost allocation set out in the accounting 

methodology statement are appropriate to the circumstances of the Company or whether they meet the requirements of the WSRA. 

The Regulatory Accounting Statements are separate from the statutory financial statements of the Company and have not been 

prepared under the basis of international accounting standards in conformity with the requirements of the Companies Act 2006 (“UK 

IASs”). Financial information other than that prepared on the basis of UK IASs does not necessarily represent a true and fair view of 

the financial performance or financial position of a Company as shown in statutory financial statements prepared in accordance with 

the Companies Act 2006. 

The Regulatory Accounting Statements in section 4 have been drawn up in accordance with Regulatory Accounting Guidelines with 

a number of departures from IASs. A summary of the effect of these departures in the Company’s statutory financial statements is 

included in the tables within section 1. 

Our opinion is not modified in respect of this matter. 

Conclusions relating to going concern 

In auditing the Regulatory Accounting Statements, we have concluded that the directors’ use of the going concern basis of accounting 

in the preparation of the Regulatory Accounting Statements is appropriate. 

Our  evaluation  of  the directors’ assessment  of  the company’s  ability  to  continue  to  adopt  the  going  concern  basis  of  accounting 

included: 

•  Assessing  financial  facilities  including  availability  and  access  at  the  balance  sheet  date,  the  nature  of  the  facilities, 

repayment and expiration terms and associated covenants; 

•  Evaluating  management’s  going  concern  assessment  and  the  linkage  to  the  business  model  and  medium-term  risks 

including effects of changes in water availability and usage and potential regulation; 

• 

challenging assumptions used in the forecasts, including the effects of AMP 7 from the Ofwat final determination and the 

subsequent CMA final decision;  

• 

• 

evaluating the amount of headroom in the forecasts focusing on cash and covenants associated with financing activities;  

performing  sensitivity  analysis  to  assess  how  the  headroom  within  the  forecasts  is  affected  by  variations  within  the 

assumptions; and  

• 

assessing the model used to prepare the forecasts, testing of clerical accuracy of those forecasts and assessing historical 

accuracy of forecasts prepared by management. 

Based  on  the  work  we  have  performed,  we  have  not  identified  any  material  uncertainties  relating  to  events  or  conditions  that, 

individually or collectively, may cast significant doubt on the company’s ability to continue as a going concern for a period of at least 

twelve months from when the financial statements are authorised for issue.  

Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of 

this report. 

Other information 

The  other  information  comprises  all  of  the  information  in  the  Annual  Performance  Report  other  than  the  Regulatory  Accounting 

Statements and our auditors’ report thereon. The directors are responsible for the other information. Our opinion on the Regulatory 

Accounting Statements does not cover the other information and we do not express any form of assurance conclusion thereon. 

14 July 2023 
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In connection with our audit of the Regulatory Accounting Statements, our responsibility is to read the other information and, in doing 

so, consider whether the other information is materially inconsistent with the Regulatory Accounting Statements or our knowledge 

obtained in the audit, or otherwise appears to be materially misstated. If we identify an apparent material inconsistency or  material 

misstatement,  we  are  required  to  perform  procedures  to  conclude  whether  there  is  a  material  misstatement  of  the  Regulatory 

Accounting Statements or a material misstatement of the other information. If, based on the work we have performed, we conclude 

that there is a material misstatement of the other information, we are required to report that fact. 

We have nothing to report based on these responsibilities. 

Responsibilities of the Directors for the Annual Performance Report 

As  explained  more  fully  in  the  Statement  of  Directors’  Responsibilities  set  out  in  section  4,  the  directors  are  responsible  for  the 

preparation of the Annual Performance Report in accordance with Condition F, the Regulatory Accounting Guidelines issued by the 

WSRA and the Company’s accounting policies (including the Company’s published accounting methodology statement(s), as defined 

in RAG 3.14, appendix 2). 

The directors are also responsible for such internal control as they determine is necessary to enable the preparation of the  Annual 

Performance Report that is free from material misstatement, whether due to fraud or error. 

In preparing the Annual Performance Report, the directors are responsible for assessing the Company’s ability to continue as a going 

concern, disclosing as  applicable, matters  related  to  going concern and using  the  going concern basis of  accounting unless the 

directors either intend to liquidate the Company or to cease operations, or have no realistic alternative but to do so. 

Auditors’ responsibilities for the Audit of the Regulatory Accounting Statements within the Annual Performance Report 

Our objectives are to obtain reasonable assurance about whether the Regulatory Accounting Statements as a whole are free from 

material misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion. Reasonable assurance 

is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material 

misstatement  when  it  exists.  Misstatements  can  arise  from  fraud  or  error  and  are  considered  material  if,  individually  or  in  the 

aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of the Regulatory 

Accounting Statements. 

Irregularities,  including  fraud, are  instances  of non-compliance  with laws  and  regulations.  We design  procedures  in  line  with  our 

responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our 

procedures are capable of detecting irregularities, including fraud, is detailed below. 

We considered the nature of the company’s industry and its control environment, and reviewed the company’s documentation of 

their policies and procedures relating to fraud and compliance with laws and regulations. We also enquired of management about 

their own identification and assessment of the risks of irregularities. 

We obtained an understanding of the legal and regulatory framework[s] that the company operates in, and identified the key laws 

and regulations that: 

•  Had a direct effect on the determination of material amounts and disclosures in the Regulatory Accounting Statements. 

These included Regulatory Accounting Guidelines as issued by the WRSA, UK Companies Act, pensions legislation and 

tax legislation; and 

• 

do not have a direct effect on the Regulatory Accounting Statements but compliance with which may be fundamental to the 

company’s ability to operate or to avoid a material penalty. These included the company’s operating licence, regulatory 

solvency requirements and environmental regulations. 

14 July 2023 
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In common with all audits under ISAs (UK), we are also required to perform specific procedures to respond to the risk of management 

override. In addressing the risk of fraud through management override of controls, we tested the appropriateness of journal entries 

and other adjustments; assessed whether the judgements made in making accounting estimates are indicative of a potential bias; 

and evaluated the business rationale of any significant transactions that are unusual or outside the normal course of business. 

In addition to the above, our procedures to respond to the risks identified included the following: 

• 

reviewing financial statement disclosures by testing to supporting documentation to assess compliance with provisions of 

relevant laws and regulations described as having a direct effect on the financial statements; 

• 

performing  analytical  procedures  to  identify  any unusual  or  unexpected  relationships  that  may  indicate  risks of material 

misstatement due to fraud;  

• 

enquiring of management, the audit committee and external legal counsel concerning actual and potential litigation and 

claims, and instances of non-compliance with laws and regulations; and  

• 

reading  minutes  of  meetings  of  those  charged  with  governance,  reviewing  internal  audit  reports,  and  reviewing 

correspondence with HMRC and WSRA. 

A further description of our responsibilities for the audit of the Regulatory Accounting Statements is located on the Financial Reporting 

Council’s website at www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report. 

Use of this report 

This report is made, on terms that have been agreed, solely to the Company and the WSRA in order to meet the requirements of 

Condition F of the Instrument of Appointment granted by the Secretary of State for the Environment to the Company as a water and 

sewage undertaker under the Water Industry Act 1991 (“Condition F”). Our audit work has been undertaken so that we might state 

to the Company and the WSRA those matters that we have agreed to state to them in our report, in order (a) to assist the Company 

to meet its obligation under Condition F to procure such a report and (b) to facilitate the carrying out by the WSRA of its regulatory 

functions, and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other 

than the Company and the WSRA, for our audit work, for this report or for the opinions we have formed. 

Our  opinion  on  the  Regulatory  Accounting  Statements  is  separate  from  our  opinion  on  the  statutory  financial  statements  of  the 

Company for the year ended 31 March 2023 on which we reported on 14 July 2023, which are prepared for a different purpose. Our 

audit report in relation to the statutory financial statements of the Company (our “Statutory audit”) was made solely to the Company’s 

members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our Statutory audit work was undertaken 

so that we might state to the Company’s members those matters we are required to state to them in a statutory audit report and for 

no other purpose. In these circumstances, to the fullest extent permitted by law, we do not accept or assume responsibility for any 

other purpose or to any other person to whom our Statutory audit report is shown or into whose hands it may come save where 

expressly agreed by our prior consent in writing. 

Deloitte LLP 

Newcastle, United Kingdom  

14 July 2023 

14 July 2023 
PAGE 185 OF 211 

 
 
 
 
 
3A  Outcome performance - Water performance commitments (financial) 

Line description 

Common PCs - Water (Financial) 

Unit 

Performance 
level - actual 

PC 
met? 

Reward/ 
Penalty 

Forecast 
2020-25 
Reward/ 
Penalty  

£m 

£m 

Water quality compliance (CRI) 

number 

7.62 

No 

-8.531 

-31.839 

Water supply interruptions 

hh:mm:ss 

00:08:17 

No 

-2.611 

-2.302 

Leakage NW region 

Leakage ESW region 

Per capita consumption 

Mains repairs 

Unplanned outage 

% 

% 

%  

3.7 

7.5 

-5.6 

number 

154.9 

No 

-0.543 

-1.653 

Yes 

0.000 

0.056 

No 

No 

0.000 

-9.285 

-1.863 

1.089 

% 

3.51 

Yes 

0.000 

-0.929 

Bespoke PCs - Water and Retail (Financial) 

Visible leak repair time 

Voids  

Interruptions to supply greater than 12 hours 

Discoloured water contacts 

Taste and smell contacts 

Event Risk Index   

Interruptions to supply between one and three 
hours  

Abstraction incentive mechanism (AIM) 

Water environment improvements 

nr 

% 

nr 

nr 

nr 

nr 

%  

nr 

nr 

7.1 

No 

-0.471 

-2.535 

3.39 

Yes 

1.333 

6.664 

448 

Yes 

0.007 

-7.179 

7.85 

Yes 

0.992 

4.758 

1.75 

Yes 

0.263 

1.361 

166.907 

No 

-0.028 

-0.238 

124.2 

No 

-2.704 

-2.226 

N/A 

- 

0.000 

0.000 

33.1 

Yes 

0.177 

1.259 

Greenhouse Gas Emissions 

tCO2e 

45,182 

Yes 

7.183 

19.505 

Delivery of water resilience enhanced 
programme 

Delivery of lead enhancement programme 

Delivery of smart water metering enhancement 
programme 

Delivery of cyber resilience enhancement 
programme 

% 

% 

% 

% 

25.2 

Yes 

0.000 

-0.579 

12.1 

No 

0.000 

0.000 

27.3 

No 

0.000 

-4.947 

60.0 

Yes 

0.000 

0.000 

14 July 2023 
PAGE 186 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3B  Outcome performance - Wastewater performance commitments (financial) 

Line description 

Common PCs - Wastewater (Financial) 

Internal sewer flooding 

Pollution incidents 

Sewer collapses 

Unit 

Performance 
level - actual 

PC 
met? 

Reward/ 
Penalty 

Forecast 
2020-25 
Reward/ 
Penalty  

£m 

£m 

No. of internal 
incidents per 
10,000 sewer 
connections 
Pollution 
incidents per 
10,000 km of 
sewer length 
No. of sewer 
collapses per 
1,000 km of all 
sewers 

1.21 

Yes 

0.934 

0.631 

19.98 

Yes 

0.903 

4.569 

9.29 

Yes 

0.000 

0.000 

Treatment works compliance 

% 

98.52 

No 

-0.287 

-2.036 

Bespoke PCs - Wastewater (Financial) 

Sewer blockages 

External sewer flooding 

Repeat sewer flooding  

Bathing water compliance  

Delivery wastewater resilience 
enhancement programme 

Water Industry National Environment 
Programme 

nr 

nr 

nr 

% 

nr 

nr 

10,949 

Yes 

0.168 

1.425 

3,018 

No 

-0.056 

-5.870 

20 

Yes 

1.212 

4.738 

97.06 

Yes 

0.000 

0.000 

97 

Yes 

0.000 

0.000 

447 

No 

0.000 

0.000 

Delivery of Howdon STW enhancement 

months 

0 

Yes 

0.000 

0.000 

14 July 2023 
PAGE 187 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3C  Customer measure of experience (C-MeX) table 

Item 

Unit 

Value 

Annual customer satisfaction score for the customer service survey 

Number 

83.72 

Annual customer satisfaction score for the customer experience 
survey 

Number 

83.77 

Annual C-MeX score 

Number 

83.74 

Annual net promoter score 

Number 

41.50 

Total household complaints 

Number 

7,828 

Total connected household properties 

Number 

2,049,338 

Total household complaints per 10,000 connections 

Number 

38.198 

Confirmation of communication channels offered 

TRUE or FALSE 

TRUE 

3D  Developer services measure of experience (D-MeX) table 

Item 

Unit 

Value 

Qualitative component annual results 

Quantitative component annual results 

D-MeX score 

Developer services revenue (water) 

Developer services revenue (wastewater) 

Number 

Number 

Number 

£m 

£m 

81.32 

98.38 

89.85 

16.572 

1.799 

14 July 2023 
PAGE 188 OF 211 

 
 
 
  
 
 
 
 
 
 
 
3E  Outcome performance - Non financial performance commitments 

Line description 

Common 

Unit 

Performance 
level - actual 

PCL 
met? 

Risk of severe restrictions in a drought 

Priority services for customers in vulnerable circumstances - PSR reach 

% 

% 

0.0 

8.8 

Yes 

Yes 

Priority services for customers in vulnerable circumstances - Attempted contacts  % 

90.3 

Yes 

Priority services for customers in vulnerable circumstances - Actual contacts 

Risk of sewer flooding in a storm 

Bespoke PCs  

Satisfaction of Customers who receive additional non-financial support 

Awareness of additional non-financial support 

Response time to written complaints 

Customers' perception of trust 

Percentage of households in water poverty 

Gap sites 

Bioresources 

Satisfaction of Customers who receive additional financial support 

Awareness of additional financial support 

% 

% 

nr 

% 

nr 

nr 

% 

% 

% 

nr 

% 

44.0 

Yes 

16.11 

Yes 

8.5 

45.3 

7.93 

8.5 

15.27 

59.1 

No 

No 

No 

No 

No 

No 

100 

Yes 

9.2 

Yes 

41.5 

No 

British Standards Institution Award for Inclusive Services 

text 

Maintained 

Yes 

NWL Independent value for money survey 

nr 

8.2 

No 

WINEP Delivery 

Delivery of DWMPs 

text 

Met 

Yes 

% 

100 

Yes 

14 July 2023 
PAGE 189 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3H  Summary information on outcome delivery incentive payments 

Line description 

Initial calculation of 
performance 
payments (excluding 
CMEX and DMEX) 

£m (2017-18 prices) 

Initial calculation of in period revenue adjustment by price control 

Water resources 

Water network plus 

Wastewater network plus 

Bioresources (sludge) 

Residential retail 

Business retail 

Dummy control 

Initial calculation of end of period revenue adjustment by price control 

Water resources 

Water network plus 

Wastewater network plus 

Bioresources (sludge) 

Residential retail 

Business retail 

Dummy control 

Initial calculation of end of period RCV adjustment by price control 

Water resources 

Water network plus 

Wastewater network plus 

Bioresources (sludge) 

Residential retail 

Business retail 

Dummy control 

0.81 

-12.22 

5.41 

0.21 

1.86 

0.00 

0.00 

0.00 

-2.55 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

14 July 2023 
PAGE 190 OF 211 

 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
Additional Regulatory Information 

This section contains additional regulatory information required by RAG 3.14. 

However, some tables have not been included from this report either because their size or because of the technical nature of their 

content. These tables, which are listed below, can be found on our website, alongside this report.  

4B 

4L 

Analysis of debt 

Enhancement expenditure – water resources and water network+ 

4M 

Enhancement expenditure – wastewater network+ and bioresources 

4Q 

4R 

Developer services – Non-financial information 

Properties, customers and population – non-financial information 

4S-U  Green Recovery tables – not applicable to NWL 

5A 

5B 

6A 

6B 

6C 

6D 

6E 

6F 

7A 

7B 

7C 

7D 

7E 

7F 

8A 

8B 

8C 

8D 

Water resources – asset and volumes data 

Water resources - operating cost analysis 

Raw water transport, raw water storage, and water treatment data 

Treated water distribution – assets and operations 

Water network+ – mains, communication pipes and other data 

Demand management – metering and leakage activities  

Leakage activity detailed analysis 

WRMP annual reporting on delivery - non-leakage activities 

Wastewater network+ – functional expenditure 

Wastewater network+ – large sewage treatment works 

Wastewater network+ – sewer and volume data 

Wastewater network+ – sewage treatment works data 

Wastewater network+ – energy consumption and other data 

Wastewater network+ - WINEP phosphorus removal scheme costs and cost drivers 

Bioresources – sludge data 

Bioresources – operating expenditure analysis 

Bioresources – energy and liquors analysis 

Bioresources – sludge treatment and disposal data 

10A-E  Green Recovery tables – not applicable to NWL 

11A 

Operational greenhouse gas emissions reporting 

14 July 2023 
PAGE 191 OF 211 

 
 
 
 
 
 
4A  WATER BULK SUPPLY INFORMATION for the 12 months ended 31 March 2023 

Volume   
Ml   

Operating 
costs 
£m 

Revenue 
£m 

Bulk supply exports 
(NESBWE1) Affinity Water (Three Valleys) 
(NESBWE2) Anglian Water (Fairstead) 
(NESBWE3) Anglian Water (Fuller Street) 
(NESBWE4) Anglian Water (Hogwells) 
(NESBWE5) Anglian Water (Layer) 
(NESBWE6) Anglian Water (Maldon) 
(NESBWE9) United Utilities Water 
(NESBWE11) Anglian Water (Stour - Tiptree) 
(NESBWE12) Leep Utilities - Barking 
(NESBWE13) Anglian Water (Woods Meadow Oulton) 
(NESBWE14) Thames Water 
(NESBWE15) Albion Water (Five Oaks) 
(NESBWE17) Anglian Water (2 Sisters Buxted Chickens) 
(NESBWE18) IWNL - Throckley 
(NESBWE19) IWNL (Malyon's Lane) 
(NESBWE25) IWNL - River View - Maldon Road 
(NESBWE24) LEEP - Conrad Road Witham 
(NESBWE21) Marsh Road, Burnham 
(NESBWE20) IWNL (Limebrook Way) 
(NESBWE21) IWNL (Naisberry Farm) 
(NESBWE22) IWNL (Lambton Park) 
(NESBWE23) IWNL - Chester Road, Pennywell 
(NESBWE26) IWNL (Seaton Vale) 
(NESBEW28) IWNL (West Benton) 
(NESBEW30) IWNL (Cell A) 
Total bulk supply exports 

Bulk supply imports 
(NESBWI2) Anglian Water (Cressing) 
(NESBWE14) Thames Water 
(NESVW13) - UUW 
(NESBWI3) Anglian Water (Hartismere) 

5.8   
11.4   
7.7   
3.8   
38.5   
100.4   
234.2   
917.9   
312.4   
56.7   
-   
48.7   
92.1   
28.4   
33.6   
1.7   
-   
7.8   
49.1   
2.6   
4.0   
3.6   
4.8   
5.2   
6.9   
1,977.3   

393.7   
30,370.0   
0.4   
-   
30,764.1   

- 
- 
- 
- 
- 
0.1 
0.2 
0.7 
0.2 
0.1 
- 
- 
0.1 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
1.4 

0.4 
2.3 
- 
- 
2.7 

- 
- 
- 
- 
0.1 
0.2 
0.2 
1.1 
0.4 
0.1 
1.5 
0.1 
0.1 
- 
0.1 
- 
- 
- 
0.1 
- 
- 
- 
- 
- 
- 
4.0 

- 
- 
- 
- 
- 

14 July 2023 
PAGE 192 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4C  IMPACT OF PRICE CONTROL PERFORMANCE TO DATE ON RCV for the 12 months ended 31 March 2023 

12 months ended 31 March 2023 

Price control period to date 

Water 
resources   

Water 
network+   

Wastewater 

network+    Bioresources 

Water 
resources   

Water 
network+   

Wastewater 

network+    Bioresources 

Totex (net of business rates, abstraction licence fees and grants and contributions) 

£'m  

£'m  

£'m  

£'m  

£'m  

£'m  

£'m  

Final determination allowed totex (net of business rates, abstraction licence fees, grants and 
contributions and other items not subject to cost sharing) 
Actual totex (excluding business rates, abstraction licence fees, grants and contributions and other 
items not subject to cost sharing) 
Transition expenditure 
Disallowable costs 
Total actual totex  (net of business rates, abstraction licence fees and grants and contributions) 
Variance  
Variance due to timing of expenditure 
Variance due to efficiency 
Customer cost sharing rate - outperformance 
Customer cost sharing rate - underperformance 
Customer share of totex overspend 
Customer share of totex underspend 

Company share of totex overspend 

Company share of totex underspend 

Totex - business rates and abstraction licence fees 
Final determination allowed totex - business rates and abstraction licence fees 
Actual totex - business rates and abstraction licence fees 
Variance  - business rates and abstraction licence fees 
Customer cost sharing rate  - business rates 
Customer cost sharing rate  - abstraction licence fees 
Customer share of totex over/underspend  - business rates and abstraction licence fees 
Company share of totex over/underspend  - business rates and abstraction licence fees 
Totex not subject to cost sharing 
Final determination allowed totex -  not subject to cost sharing 
Actual totex - not subject to cost sharing 
Variance - 100% company allocation 

Total customer share of totex over/under spend  

25.2  

284.7  

220.0  

18.1  

74.9  

804.7  

551.6  

55.2  
-  
-  
55.2  
30.0  
(19.4)  
49.4  
55.00%  
45.00%  
22.2  
-  

27.2  

-  

51.4  
43.8  
(7.6)  
82.95%  
82.67%  
(6.3)  
(1.3)  

5.7  
5.6  
(0.1)  

15.9  

297.0  
-  
0.6  
296.4  
11.7  
(1.7)  
13.4  
55.00%  
45.00%  
6.0  
-  

7.3  

-  

30.0  
27.3  
(2.7)  
90.14%  
75.00%  
(2.4)  
(0.3)  

3.8  
10.6  
6.8  

3.6  

206.3  
-  
-  
206.3  
(13.7)  
6.3  
(20.0)  
55.00%  
45.00%  
-  
(11.0)  

2.8  
-  
-  
2.8  
(15.3)  
8.7  
(24.0)  
0.00%  
0.00%  
-  
-  

130.5  
-  
0.2  
130.3  
55.4  
-  
55.4  
55.00%  
45.00%  
24.9  
-  

-  

-  

30.5  

(9.0)  

(24.1)  

-  

7.8  
7.7  
(0.1)  
90.00%  
75.00%  
(0.1)  
-  

-  
1.5  
1.5  

(11.1)  

1.6  
1.6  
-  
90.00%  
75.00%  
-  
-  

-  
-  
-  

-  

144.1  
139.2  
(4.9)  
82.61%  
82.67%  
(4.0)  
(0.9)  

16.3  
23.4  
7.1  

20.9  

777.1  
-  
4.7  
772.4  
(32.3)  
(48.1)  
15.8  
55.00%  
45.00%  
7.1  
-  

8.7  

-  

84.2  
81.3  
(2.9)  
90.87%  
75.00%  
(2.6)  
(0.3)  

12.2  
31.4  
19.2  

4.5  

561.1  
-  
2.8  
558.3  
6.7  
-  
6.7  
55.00%  
45.00%  
3.0  
-  

3.7  

-  

22.0  
19.4  
(2.6)  
90.00%  
75.00%  
(2.3)  
(0.3)  

0.7  
2.5  
1.8  

0.7  

£'m 

51.0 

9.0 
- 
0.2 
8.8 
(42.2) 
- 
(42.2) 
0.00% 
0.00% 
- 
- 

- 

(42.2) 

4.5 
4.0 
(0.5) 
90.00% 
75.00% 
(0.4) 
(0.1) 

- 
- 
- 

(0.5) 

14 July 2023 
PAGE 193 OF 211 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
 
 
   
   
   
 
   
   
   
 
 
   
   
   
 
 
 
 
   
   
   
 
 
   
   
   
 
 
 
 
 
   
   
   
 
 
   
   
   
RCV 
Total customer share of totex over/under spend  
PAYG rate 

RCV element of cumulative totex over/underspend 
Adjustment for ODI outperformance payment or underperformance payment  
Green recovery 
RCV determined at FD at 31 March 
Projected 'shadow' RCV 

12 months ended 31 March 2023 

Price control period to date 

Water 
resources   

Water 
network+   

Wastewater 

network+    Bioresources 

Water 
resources   

Water 
network+   

Wastewater 

network+    Bioresources 

15.9  
91.44%  

3.6  
54.47%  

1.4  

1.6  

(11.1)  
37.71%  

(6.9)  

-  
40.72%  

20.9  
90.10%  

-  

2.1  
-  
-  
340.4  
342.5  

4.5  
54.62%  

2.0  
-  
-  
2,259.0  
2,261.0  

0.7  
43.15%  

0.4  
-  
-    
2,328.8  
2,329.2  

(0.5) 
40.87% 

(0.3) 
- 

169.2 
168.9 

14 July 2023 
PAGE 194 OF 211 

 
 
 
  
 
 
 
 
 
 
   
 
 
   
   
   
 
 
 
 
 
 
 
   
 
 
   
   
   
 
 
 
 
 
   
   
   
 
 
 
   
   
   
 
 
 
   
   
   
 
 
 
   
   
   
 
Wholesale Totex Comparison to FD Allowance 

Totex (net of business rates, abstraction licence fees and grants and contributions) 

Actual totex in 2022/23 across all price controls was £12.7m higher than the FD allowance, after excluding disallowed costs.  This 

has been allocated as £6.1m underspend due to timing of expenditure and £18.8m overspend relating to ‘efficiency’. 

The cumulative position for the first three years of the price control period is a total underspend of £12.4m, of which an underspend 

of £48.1m has been allocated to timing and an overspend of £35.7m to ‘efficiency’. 

The methodology adopted for allocation of variances between timing and efficiency is as follows: 

• 

• 

All operating expenditure variances are allocated to efficiency as they relate to in-period spend; 

If cumulative capital investment for a price control is above FD and forecast to remain above, then it is allocated to ‘efficiency’.  

This is the case for the Water resources price control; 

• 

If cumulative capital investment for a price control is below FD and forecast to remain below, then it is allocated to ‘efficiency’.  

This is the case for the Wastewater network plus and Bioresources price controls; 

• 

If cumulative capital investment for a price control is below FD but forecast to be above over the full AMP, then the variance is 

allocated to timing.  This is the case for Water network plus. 

Operating costs for the three years to date have been higher than FD on all price controls except Bioresources.  This has been 

primarily due to the significant increase in power prices from 2021.  

Capital expenditure has been lower than FD in the first three years, although it will increase significantly in the final two years of 

AMP7.  The underspend due to timing is principally due to slower progress on enhancement projects, as reported in 4L and 4M of 

our APR, which can be found on our website. 

Our progress on delivering our enhancement programme is explained in detail under ‘Outcome 6: We are resilient and provide clean 

drinking water and effective sewerage services; now, and for future generations’ on page 53 of this report. 

Totex - business rates and abstraction licence fees 

Actual totex in 2021/22 was £10.4m lower than the FD allowance. This primarily relates to lower abstraction charges following the 

end of a temporary two-year increase to recover costs relating to Kielder.  

The  original  Ofwat  determination  set  consistent  cost  sharing  rates  for  abstraction  and  rates  variances.  However,  our  CMA 

redetermination amended the sharing rates for different elements of these costs. In order for the sharing rate calculation to work 

correctly, a hybrid sharing rate has been used and reported in the row for ‘Customer cost sharing rate – business rates’ in line with 

Ofwat guidance. The individual rates are shown below: 

14 July 2023 
PAGE 195 OF 211 

 
 
 
 
 
 
12 months ended 31 March 2023 

Price control period to date 

Water 
resources 

82.67% 

Water 
network 
plus 
75.00% 

Wastewater 
network 
plus 
75.00% 

Bio-
resources 

Water 
resources 

75.00% 

82.67% 

Water 
network 
plus 
75.00% 

Wastewater 
network 
plus 
75.00% 

Bio-
resources 

75.00% 

90.00% 

90.00% 

90.00% 

90.00% 

90.00% 

90.00% 

90.00% 

90.00% 

82.95% 

90.14% 

90.00% 

90.00% 

82.61% 

90.87% 

90.00% 

90.00% 

Customer cost sharing 
rate - abstraction 
Customer cost sharing 
rate - business rates 
Customer cost sharing 
rate - weighted ave 

Shadow RCV 

Actual RCV at 31 March 2022, as published by Ofwat, was £5,097.4m. 

The projected ‘shadow’ RCV, adjusted for the customer share of cost variances was £5,101.6m, the small increase reflecting the 

customer share of overspends due to increased energy costs. 

Disallowable costs  

Costs classified as disallowable are:  

• 

• 

Section 74 fines and fixed penalty notices; and 

compensation claims. 

Recharges in respect of ‘principal use’ of assets  

These relate to assets which are shared across more than one business unit, which mainly relate to IT systems and office buildings. 

The capital is allocated to Water Network+ as the ‘principal user’ and an appropriate proportion recharged to the other business 

units, including retail. The values are reported on table 2A.

14 July 2023 
PAGE 196 OF 211 

 
 
 
 
 
 
 
4D  TOTEX ANALYSIS: WATER RESOURCES AND WATER NETWORK+ for the 12 months ended 31 March 2023 

Water resources 

Raw water 

transport   

Raw water 

storage   

Water treatment   

Network+ 

Operating expenditure 
Base operating expenditure 
Enhancement operating expenditure 
Developer services operating expenditure 
Total operating expenditure excluding third party services 
Third party services 
Total operating expenditure 

Grants and contributions - operating expenditure 

Capital expenditure 
Base capital expenditure 
Enhancement capital expenditure 
Developer services capital expenditure 
Total gross capital expenditure (excluding third party) 
Third party services 
Total gross capital expenditure 

Grants and contributions - capital expenditure 

Net totex 

Cash expenditure 
Pension deficit recovery payments 
Other cash items 
Totex including cash items 

Atypical expenditure 
Pension past service credit (non-cash) 
Total atypical expenditure 

£'m  

73.6  
1.2  
-  
74.8  
5.6  
80.4  

-  

21.8  
2.4  
-  
24.2  
-  
24.2  

-  

104.6  

0.6  
-  
105.2  

(0.3)  
(0.3)  

£'m  

6.8  
-  
-  
6.8  
1.4  
8.2  

-  

0.1  
1.2  
-  
1.3  
-  
1.3  

-  

9.5  

0.1  
-  
9.6  

-  
-  

£'m  

2.3  
-  
-  
2.3  
-  
2.3  

-  

-  
-  
-  
-  
-  
-  

-  

2.3  

-  
-  
2.3  

-  
-  

Treated water 
distribution  
£'m  

Total 

£'m 

110.8  
0.5  
-  
111.3  
2.0  
113.3  

-  

64.0  
17.4  
20.5  
101.9  
-  
101.9  

(13.1)  

256.9 
2.1 
- 
259.0 
9.5 
268.5 

- 

139.1 
24.4 
20.5 
184.0 
- 
184.0 

(13.1) 

£'m  

63.4  
0.4  
-  
63.8  
0.5  
64.3  

-  

53.2  
3.4  
-  
56.6  
-  
56.6  

-  

120.9  

202.1  

439.4 

3.6  
-  
124.5  

(2.0)  
(2.0)  

9.2  
-  
211.3  

(4.9)  
(4.9)  

13.5 
- 
452.9 

(7.2) 
(7.2) 

14 July 2023 
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4E  TOTEX ANALYSIS: WASTEWATER NETWORK+ AND BIORESOURCES for the 12 months ended 31 March 2023 

Network+  
Sewage collection 

Network+  
Sewage treatment 

Bioresources 

Surface water 
drainage 
£'m  

Foul 
£'m  

Highway 
drainage 
£'m  

Sewage treatment 
and disposal 
£'m  

Imported sludge 
liquor treatment 
£'m  

Sludge 
transport 
£'m  

  Sludge treatment 
£'m  

Sludge 
disposal 
£'m  

Operating expenditure 
Base operating expenditure 
Enhancement operating expenditure 
Developer services operating expenditure 
Total operating expenditure excluding third party services 
Third party services 
Total operating expenditure 

Grants and contributions - operating expenditure 

Capital expenditure 
Base capital expenditure 
Enhancement capital expenditure 
Developer services capital expenditure 
Total gross capital expenditure (excluding third party) 
Third party services 
Total gross capital expenditure 

Grants and contributions - capital expenditure 

14.3  
-  
0.2  
14.5  
-  
14.5  

-  

11.6  
0.5  
0.4  
12.5  
-  
12.5  

(0.6)  

20.6  
-  
-  
20.6  
0.1  
20.7  

-  

19.3  
0.8  
0.7  
20.8  
-  
20.8  

(0.9)  

11.0  
-  
-  
11.0  
-  
11.0  

-  

10.2  
0.4  
0.4  
11.0  
-  
11.0  

(0.5)  

64.9  
0.2  
-  
65.1  
-  
65.1  

-  

25.6  
29.1  
-  
54.7  
-  
54.7  

-  

7.1  
-  
-  
7.1  
-  
7.1  

-  

-  
-  
-  
-  
-  
-  

-  

Net totex 

26.4  

40.6  

21.5  

119.8  

7.1  

Cash expenditure 
Pension deficit recovery payments 
Other cash items 
Totex including cash items 

Atypical expenditure 
Pension past service credit (non-cash) 
Total atypical expenditure 

2.9  
-  
29.3  

(0.4)  
(0.4)  

0.2  
-  
40.8  

(0.7)  
(0.7)  

-  
-  
21.5  

(0.4)  
(0.4)  

3.0  
-  
122.8  

(2.0)  
(2.0)  

-  
-  
7.1  

-  
-  

5.5  
-  
-  
5.5  
-  
5.5  

-  

0.5  
-  
-  
0.5  
-  
0.5  

-  

6.0  

-  
-  
6.0  

-  
-  

(5.8)  
-  
-  
(5.8)  
-  
(5.8)  

-  

3.0  
-  
-  
3.0  
-  
3.0  

-  

1.1  
-  
-  
1.1  
-  
1.1  

-  

-  
-  
-  
-  
-  
-  

-  

Total 
£'m 

118.7 
0.2 
0.2 
119.1 
0.1 
119.2 

- 

70.2 
30.8 
1.5 
102.5 
- 
102.5 

(2.0) 

(2.8)  

1.1  

219.7 

0.3  
-  
(2.5)  

(0.2)  
(0.2)  

-  
-  
1.1  

-  
-  

6.4 
- 
226.1 

(3.7) 
(3.7) 

14 July 2023 
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4F & 4G 

MAJOR PROJECT EXPENDITURE FOR WHOLESALE WATER AND WASTEWATER 

NWL does not have any Major Projects as defined by RAG4.11.

14 July 2023 
PAGE 199 OF 211 

 
 
 
 
 
4H  FINANCIAL METRICS for the 12 months ended 31 March 2023 

Units 

  Current year  AMP to date 

- 
- 
- 
- 
6.1% 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 
- 
- 

Financial indicators 
Net debt 
Regulatory equity 
Regulatory gearing 
Post tax return on regulatory equity 
RORE (return on regulatory equity) 
Dividend yield 
Retail profit margin - Household 
Retail profit margin - Non household 
Credit rating - Fitch 

Credit rating - Moody's 
Credit rating - Standard and Poor's 
Return on RCV 
Dividend cover 
Funds from operations (FFO) 
Interest cover (cash) 
Adjusted interest cover (cash) 
FFO/Net debt 
Effective tax rate 
RCF 
RCF/Net debt 

£m  
£m  
%  
%  
%  
%  
%  
%  
Text  

3,483.8 
1,613.6 
68.3% 
-3.4% 
10.0% 
6.9% 
0.7% 
0.0% 
n/a 
Baa1 
Text  
(Stable) 
Text   BBB (Stable) 
4.1% 
(0.4) 
207.4 
3.1 
0.6 
0.1 
(8.4%) 
96.6 
- 

%  
dec  
£m  
dec  
dec  
dec  
%  
£m  
dec  

Borrowings 
Proportion of borrowings which are fixed rate 
Proportion of borrowings which are floating rate 
Proportion of borrowings which are index linked 
Proportion of borrowings due within 1 year or less 
Proportion of borrowings due in more than 1 year but no more than 2 years 
Proportion of borrowings due in more than 2 years but but no more than 5 years 
Proportion of borrowings due in more than 5 years but no more than 20 years 
Proportion of borrowings due in more than 20 years 

%  
%  
%  
%  
%  
%  
%  
%  

61.5% 
0.6% 
37.9% 
1.7% 
0.8% 
16.4% 
70.7% 
10.4% 

An explanation of RORE performance compared to the allowance in the FD is provided in the commentary to table 1F. 

14 July 2023 
PAGE 200 OF 211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
4I  FINANCIAL DERIVATIVES for the 12 months ended 31 March 2023 

Interest rate 
(weighted average for 12 
months to 31 March 
2021) 

Payable   Receivable 
% 

%   

2.36%  
0.00%  
0.00%  
0.00%  
12.82%  
0.00%  
0.00%  

0.49% 
0.00% 
0.00% 
0.00% 
2.17% 
0.00% 
0.00% 

Nominal value by maturity (net) at 31 March 

0 to 1 
years   
£'m   

1 to 2 
years   
£'m   

2 to 5 
years  
£'m  

Over 5 
years  
£m  

  Total value at 31 March   
Mark to 
Market   
£'m   

Nominal 
value (net)   
£'m   

Total 
accretion 
at 31 
March 

£'m  

-  
-  
-  
-  
-  
-  
-  
-  

-  
-  

0.3  

0.3  

-  
-  
-  
-  
-  
-  
-  
-  

3.2  
3.2  

-  

150.0  
-  
-  
-  
150.0  
-  
-  
300.0  

0.9  
0.9  

-  

-  
-  
-  
-  
100.0  
-  
-  
100.0  

-  
-  

-  

150.0  
-  
-  
-  
250.0  
-  
-  
400.0  

4.1  
4.1  

0.3  

(8.7)  
-  
-  
-  
96.3  
-  
-  
87.6  

(0.3)  
(0.3)  

(0.2)  

-  
-  
-  
-  
87.2  
-  
-  
87.2  

-  
-  

-  

3.2  

300.9  

100.0  

404.4  

87.1  

87.2  

Interest rate swap (sterling) 
Floating to fixed rate 
Floating from fixed rate 
Floating to index linked 
Floating from index linked 
Fixed to index-linked 
Fixed from index-linked 
Index-linked to index-linked 
Total 

Forward currency contracts 
Forward currency contracts USD 
Total 

Other financial derivatives 

Total financial derivatives 

14 July 2023 
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For the floating to fixed rate swaps, the interest rate receivable has been calculated using the forward SONIA curve as the applicable 

market rates on the last day of 2022/23 for the discounted maturity cash flows of the derivative(s). 

For  the  fixed  to  index-linked  swaps,  the  interest  rate  payable  has  been  calculated  using  a  reference  RPI  of  13.51%,  being  the 

published RPI for March 2023. Both swaps reported in this line are set at RPI minus the margin as a fixed percentage on the swaps. 

Other financial derivatives are power forward contracts. 

For the mark-to-market valuations, liability (out  of the money) positions are reported as positive values and asset (in the money) 

positions are reported as negative values, in accordance with RAG4.11. The total balance, £87.1m liability, is consistent with the 

Financial instruments balance in table 1C Statement of Financial Position. 

14 July 2023 
PAGE 202 OF 211 

 
 
 
 
 
4J  BASE EXPENDITURE ANALYSIS: WATER RESOURCES AND WATER NETWORK+ for the 12 months ended 31 March 2023 

Water network+ 

Raw water 
distribution   

Raw water 

storage    Water treatment   

£'m  

£'m  

Water resources 
£'m  

Operating expenditure 
Power 
Income treated as negative expenditure 
Bulk supply 
Renewals expensed in year (infrastructure) 
Renewals expensed in year (non-infrastructure) 
Other operating expenditure 
Local authority and Cumulo rates 

Service Charges 
Canal & River Trust abstraction charges/ discharge consents 

Environment Agency / NRW abstraction charges/ discharge 
consents 
Other abstraction charges/ discharge consents 

Other operating expenditure 
Costs associated with Traffic Management Act 
Costs associated with lane rental schemes 
Statutory water softening 

20.6  
(0.3)  
1.2  
0.6  
0.2  
7.5  
4.2  

0.5  

39.1  
-  

-  
-  
-  

3.1  
-  
-  
-  
-  
0.4  
3.3  

-  

-  
-  

-  
-  
-  

0.1  
-  
-  
-  
-  
2.2  
-  

-  

-  
-  

-  
-  
-  

Treated water 
distribution  
£'m  

Total 

£'m 

28.3  
-  
-  
0.4  
4.6  
57.4  
19.7  

-  

-  
-  

0.4  
-  
-  

58.7 
(0.3) 
1.2 
1.0 
6.0 
118.8 
31.2 

0.5 

39.4 
- 

0.4 
- 
- 

£'m  

6.6  
-  
-  
-  
1.2  
51.3  
4.0  

-  

0.3  
-  

-  
-  
-  

Total base operating expenditure 

73.6  

6.8  

2.3  

63.4  

110.8  

256.9 

Capital expenditure 
Maintaining the long term capability of the assets - infra 
Maintaining the long term capability of the assets - non-infra 
Total base capital expenditure 

Traffic Management Act 

8.7  
13.1  
21.8  

-  
0.1  
0.1  

Projects incurring costs associated with Traffic Management Act 
(nr) 

-  

-  

-  
-  
-  

-  

-  
53.2  
53.2  

29.3  
34.7  
64.0  

38.0 
101.1 
139.1 

-  

9,165.0  

9,165.0 

14 July 2023 
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4K  BASE EXPENDITURE ANALYSIS: WASTEWATER NETWORK+ AND BIORESOURCES for the 12 months ended 31 March 2023 

Operating expenditure 
Power 
Income treated as negative expenditure 
Bulk discharge 
Renewals expensed in year (infrastructure) 
Renewals expensed in year (non-infrastructure) 
Other operating expenditure 
Local authority and Cumulo rates 

Service Charges 
Canal & River Trust discharge consents 
Environment Agency / NRW discharge consents 
Other discharge charges / permits 

Other expenditure 
Costs associated with Traffic Management Act 
Costs associated with lane rental schemes 
Costs associated with Industrial Emissions Directive 

Wastewater network+  

Bioresources 

Surface 
water 
drainage   
£'m  

Highway 
drainage 
£'m 

Foul   
£'m  

Sewage 
treatment 
and 

Sludge 
liquor 

disposal   
£'m  

treatment   
£'m  

Sludge 
Transport   
£'m  

Sludge 
Treatment   
£'m  

Sludge 
Disposal   
£'m  

3.9  
-  
-  
0.5  
0.3  
7.8  
-  

-  
1.8  
-  

-  
-  
-  

6.4  
-  
-  
0.8  
0.5  
12.8  
0.1  

-  
-  
-  

-  
-  
-  

3.4 
- 
- 
0.4 
0.3 
6.9 
- 

- 
- 
- 

- 
- 
- 

24.5  
-  
-  
-  
1.6  
29.3  
7.6  

-  
1.9  
-  

-  
-  
-  

5.4  
-  
-  
-  
-  
1.7  
-  

-  
-  
-  

-  
-  
-  

1.6  
-  
-  
-  
-  
3.9  
-  

-  
-  
-  

-  
-  
-  

3.6  
(19.5)  
-  
-  
0.2  
8.3  
1.6  

-  
-  
-  

-  
-  
-  

-  
-  
-  
-  
-  
1.1  
-  

-  
-  
-  

-  
-  
-  

Total 
£'m 

48.8 
(19.5) 
- 
1.7 
2.9 
71.8 
9.3 

- 
3.7 
- 

- 
- 
- 

Total base operating expenditure 

14.3  

20.6  

11.0 

64.9  

7.1  

5.5  

(5.8)  

1.1  

118.7 

Capital expenditure 
Maintaining the long term capability of the assets - infra 
Maintaining the long term capability of the assets - non-infra 
Total base capital expenditure 

Operating expenditure (AMP 7 shadow reported values) 
Power 
Income treated as negative expenditure 

9.4  
2.2  
11.6  

3.9  
-  

15.7  
3.6  
19.3  

6.4  
-  

8.3 
1.9 
10.2 

3.4 
- 

0.1  
25.5  
25.6  

24.5  
-  

-  
-  
-  

5.4  
-  

-  
0.5  
0.5  

1.6  
-  

-  
3.0  
3.0  

3.6  
(19.5)  

Traffic Management Act 
Projects incurring costs associated with Traffic Management Act (nr) 

402.0  

-  

- 

-  

-  

-  

-  

-  
-  
-  

-  
-  

-  

33.5 
36.7 
70.2 

48.8 
(19.5) 

402.0 

14 July 2023 
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4N  DEVELOPER SERVICES EXPENDITURE: WATER RESOURCES AND WATER NETWORK+ for the 12 months ended 31 March 2023 

New connections 

Requisition mains 

Infrastructure network reinforcement 

s185 diversions 

Other price controlled activities  

Total developer services expenditure 

Water network+ 

Treated water distribution 

Capex   

Opex   

Totex 

£'m   

£'m   

£'m 

7.7  

5.1  

5.1  

1.7  

0.1  

19.7  

-  

-  

-  

-  

-  

-  

7.7 

5.1 

5.1 

1.7 

0.1 

19.7 

14 July 2023 
PAGE 205 OF 211 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4O  DEVELOPER SERVICES EXPENDITURE: WASTEWATER NETWORK+ AND BIORESOURCES for the 12 months ended 31 March 2023 

Wastewater network+  

Surface 
water 
drainage   

Highway 
drainage   

Sewage 
treatment 
and 

Sludge 
liquor 

disposal   

treatment   Total 

£'m   

£'m   

£'m   

£'m   

£'m 

Foul   

£'m   

Capex 

New connections 

Requisition sewers 

Infrastructure network reinforcement 

s185 diversions 

Other price controlled activities  

Total total developer services capex 

Opex 

New connections 

Requisition sewers 

Infrastructure network reinforcement 

s185 diversions 

Other price controlled activities  

Total developer services opex 

Totex 

-  

-  

-  

0.1  

0.2  

0.3  

-  

-  

-  

-  

-  

-  

-  

-  

-  

0.2  

0.4  

0.6  

-  

-  

-  

-  

-  

-  

-  

-  

-  

0.1  

0.2  

0.3  

-  

-  

-  

-  

-  

-  

Total developer services expenditure  

0.3  

0.6  

0.3  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

- 

- 

- 

0.4 

0.8 

1.2 

- 

- 

- 

- 

- 

- 

1.2 

14 July 2023 
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4P  EXPENDITURE ON NON-PRICE CONTROL DIVERSIONS for the 12 months ended 31 March 

2023 

Water 

resources   
£'m   

Water 
network+   
£'m   

Wastewater 

network+   
£'m   

Total 
£'m 

Capex 
Costs associated with NSWRA diversions 
Costs associated with other non-price control diversions 
Other developer services non-price control capex 
Developer services non-price control capex 

Opex 
Opex associated with NSWRA diversions 
Opex associated with other non-price control diversions 
Other developer services non-price control opex 
Developer services non-price control opex 

Totex 
Costs associated with NSWRA diversions 
Costs associated with other non-price control diversions 
Other developer services non-price control totex 
Developer services non-price control totex 

-  
-  
-  
-  

-  
-  
-  
-  

-  
-  
-  
-  

0.8  
-  
-  
0.8  

-  
-  
-  
-  

0.8  
-  
-  
0.8  

-  
-  
0.3  
0.3  

-  
-  
0.2  
0.2  

-  
-  
0.5  
0.5  

0.8 
- 
0.3 
1.1 

- 
- 
0.2 
0.2 

0.8 
- 
0.5 
1.3 

14 July 2023 
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4V MARK-TO-MARKET OF FINANCIAL DERIVATIVES ANALYSED BASED ON PAYMENT DATES for the 12 months ended 31 March 2023 

Derivatives - Analysed by earliest payment date 

  Derivatives - Analysed by expected maturity date 

  Net settled   

Gross 
Settled 
outflows   

Gross 
Settled 
inflows   

Total    Net settled   

Gross 
Settled 
outflows   

Gross 
Settled 
inflows   

£'m   

£'m   

£'m   

£'m   

£'m   

£'m   

£'m   

Between one and two years 

Between two and three years 

Between three and four years 

Between four and five years 

After five years 

Total 

-  

-  

(52.7)  

-  

(34.9)  

(87.6)  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

(52.7)  

-  

(52.7)  

-  

-  

(34.9)  

(34.9)  

(87.6)  

-  

(87.6)  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

-  

Total 

£'m 

- 

(52.7) 

- 

(34.9) 

- 

(87.6) 

14 July 2023 
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4W  DEFINED BENEFIT PENSION SCHEME – ADDITIONAL INFORMATION for the 12 months 

ended 31 March 2023 

Scheme details 

Scheme name 

Scheme status 

Scheme valuation under IAS/IFRS/FRS   

Scheme assets  

Scheme liabilities 

Scheme surplus / (deficit) Total 

Scheme surplus / (deficit) Appointed business 

Pension deficit recovery payments 

Assets 

Technical Provisions 

Scheme surplus / (deficit)  

Discount rate assumptions 

Recovery plan (where applicable) 
Recovery Plan Structure 

Scheme valuation under part 3 of Pensions Act 2004   

Scheme funding valuation date 

  31 December 2019 

Defined benefit pension schemes 

Northumbrian Water Pension Scheme       

£'m       

  NWPS 

  Closed to accrual of future defined benefits 

823.2 

805.3 

17.9 

17.6 

23.4 

1,066.7 

1,291.8 

(225.1) 

pre-retirement:  gilts +1.6%; 
post-retirement:  gilts +0.7% 

Recovery Plan signed on 24 March 2021. 

Schedule of contributions requires employers to 
pay the following deficit reduction contributions: 

•  £12.2m pa, with effect from 1 January 2020 

to 31 March 2020; 

•  £12.5m pa, with effect from 1 April 2020 to 

31 March 2021; 

•  £20.0m pa, with effect from 1 April 2021 to 

31 March 2022; 

•  £23.8m pa, with effect from 1 April 2022, 

increasing annually by RPI each 1 April 

Recovery plan end date  

Asset Backed Funding (ABF) arrangements 

Responsibility for ABF arrangements 

  31 August 2027 

  Not applicable 

  Not applicable 

14 July 2023 
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9A  INNOVATION COMPETITION  

Allowed 

Allocated innovation competition fund price control revenue 

Revenue collected for the purposes of the innovation competition 

Innovation fund income from customers  
Income from customers to fund innovation projects the company is leading on 
Income from customers as part of the inflation top-up mechanism 
Income from customers that is transferred to other companies as part of the innovation fund 

1 
£'m 

3.8 
5.3 
0.9 
0.6 
0.4 
0.7 

11.7 

2 
£'m 

- 
- 
- 
- 
- 
- 

- 

3 
£'m 

0.2 
0.1 
0.8 
0.3 
- 
0.1 

1.5 

4 
£'m 

0.2 
0.1 
0.8 
0.3 
- 
0.1 

1.5 

5 
£'m 

- 
- 
- 
- 
- 
- 

- 

Fairwater 
National Leakage Research Centre   
Stream phase 1 - Open data 
sharing platform 
Support For All 
SuPR Loofah (Sustainable 
Phosphorus Recovery) 
Water Quality As-A-Service 
Treatment-2-Tap 
Innovation project 14 

Total 

Administration 

Current 
year 
£'m 

2.6  

2.6  
11.8  
-  
3.5  

6 
£'m 

3.8 
5.3 
0.9 
0.6 
0.4 
0.7 

11.7 

£'m 

0.1  

7 
£'m 

0.2 
0.1 
0.8 
0.3 
- 
0.1 

1.5 

8 
£'m 

(3.6) 
(5.2) 
(0.1) 
(0.3) 
(0.4) 
(0.6) 

9 
£'m 

3.5 
5.2 
0.1 
0.3 
0.4 
0.7 

(10.2) 

10.2 

10 
£'m 

- 
- 
- 
- 
- 
- 

- 

14 July 2023 
PAGE 210 of 211 

 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
Innovation Competition 
As part of PR19 Ofwat established its Innovation Fund, the purpose of which is to grow the water sector’s capacity to innovate enabling it to better meet the evolving needs of 

customers, society and the environment. Our revenue allowance includes £2.6m per annum, which is recovered through customer charges, to contribute towards the Innovation Fund. 

Innovation fund income received from customers was £2.642m (21/22 £2.526m).   

There was also a payment to Ofwat of £0.106m for the innovation partner administration charge. 

£m 

Income from customers (price control) 

Innovation project cost contributions 

Administration partner costs 

Net 

20/21 

2.512 

0 

0 

2.512 

21/22 

2.526 

-0.128 

-0.116 

2.282 

22/23  Cumulative 

2.642 

-3.509 

-0.106 

-0.973 

7.680 

-3.637 

-0.222 

3.821 

The net receipt of £3.821m has been accrued in operating costs in the Statutory accounts but removed from the Regulatory accounts, in accordance with Ofwat guidance. 

NWL has received the funding in 2022/23 to lead on a number of projects: 

Water Breakthrough Challenge 1 - Fair Water. 

Water Breakthrough Challenge 2 : Catalyst - Support for All, SuPR Loofah, Water Quality as a Service (Treatment 2 Tap). 

Water Breakthrough Challenge 2 : Transform - National Leakage Research and Test Centre; Stream (open data sharing platform). 

The income and expenditure to date for each project is shown on the table above. 

14 July 2023 
PAGE 210 of 211