It appears that TW does not send identical ‘standard replies’ to a customer who has decided to withhold payment. This underlines the importance of making emails with complaints and notification of withholding payment as individual as possible. It is far more difficult to fob off individual complex emails with standard wording.
The content of a TW response seems to depend to some extent on the individual TW operative. However, there is a similarity in the points made on behalf of TW. Some of these are set out below, together with suggestions for taking issue with them when replying.
TW: (In effect) ‘You have reached the end of the road.’
TW says, e.g:
“As there isn’t anything further, I can assist with at this time, I’ll bring your case with me to a close today.”
“I’m confident we’ve done all we can to help resolve this matter. You’ve now exhausted our complaints procedure.”
Do not simply accept TW’s assessment that there is nothing further they can assist with or that they have done all they can to resolve the matter.
The body of the email, including the ‘facts’ TW rely on, should be further challenged and questioned. Indeed, their initial response may open up a whole new range of possible questions.
Long-term Investment and Improvement Plans
TW says eg:
Eliminating these discharges is not going to be quick, easy, or inexpensive and we welcome the continued support of our customers and regulators, who are as passionate about this topic as we are, as well as extensive collaboration with local communities and other stakeholders, to achieve the cleaner rivers we all want to see.
Our commitment on this long-standing issue is highlighted in our current draft business plan, where we outline our intent to achieve a maximum of 24 spills on average, per overflow per year by 2025, and 17 spills on average, per overflow per year by 2030, with the overall governmental target to meet of less than 10 discharges on average, per overflow per year by 2050, with a long term investment of £13.4 billion.
Our ambitious draft plans for our next investment period (2025 – 2030) include £885 million for reducing storm overflows, part of a £6.6 billion programme to improve the environment, and includes further major improvements towards our goal of eliminating untreated discharges.
In London, the completion of the £4.6 billion ‘supersewer’, the Thames Tideway Tunnel, will provide a massive reduction in the need for discharges to the tidal River Thames, which is due to go into commission later this year.
We might reply:
- Despite Thames Water’s draft business plan outlining ambitious goals for reducing sewage spills, investigative journalism by outlets such as [specific news outlet] has revealed systemic failures in Thames Water’s infrastructure and management practices. These reports cast doubt on the feasibility and effectiveness of proposed solutions, indicating a need for immediate action rather than relying solely on long-term targets ([cite specific investigative report]).
- Please explain why I should believe your assurances? Thames Water has been privately owned since 1989. It has failed to comply with its statutory duties for 35 years. Why should I believe that is now going to resolve the problems?
- It is reported that TW is in debt to a tune of £16 billion. How on earth can you pay for this?
Monitoring discharges
TW says:
While we continue to make above improvements, we think it is essential that we let local people know when these discharges start and stop. So, we have been issuing real-time notifications of discharges at all of our 468 permitted discharge points, since the beginning of this year. Our interactive map can be found here.
These notifications are helping people to decide whether or not to take part in recreational activities, such as swimming, in rivers. We need to be clear that there are also other potential hazards in rivers, including bacteria and parasites in the water, from livestock and other animals, along with pollution from farming, industry, and roads. This is why we support the government’s advice on open water swimming, which can be found here.
We might reply:
While the provision of real-time notifications of sewage discharges is commendable, recent incidents reported by [specific news outlet] have demonstrated the inadequacy of notification systems in protecting public safety. These incidents, including cases of water contamination and public health warnings, underscore the urgency of preventing sewage discharges rather than simply notifying the public after the fact ([cite specific news report]).
Shareholder Dividends
TW says, eg:
In October 2023 we decided to pay our immediate parent company, Thames Water Utilities Holdings Limited an internal dividend to service group debt obligations. We informed Ofwat about our decision and are currently working with Ofwat to provide further context and clarification around our board’s decision and its reasons. We take our licence obligations very seriously, including those relating to the declaration and payment of dividends.
I’d like to offer reassurance no distributions have been made to external shareholders of the group and they have not taken an external dividend for six years, since 2017, to prioritise investment in improving service for customers and to protect the environment. Our plans assume no external dividends to shareholders until at least 2030, to support our turnaround.
We might reply:
Recent disclosures by regulatory authorities such as the Financial Conduct Authority and investigative reports by [specific news outlet] have raised concerns about Thames Water’s prioritization of internal dividends over essential infrastructure upgrades. These reports highlight discrepancies in executive compensation packages and dividend distributions, suggesting a misalignment between corporate priorities and customer and environmental interests ([cite regulatory filings] and [specific investigative report]).
Or
Can you please explain to me why any shareholder will be interested in investing in TW if it isn’t with a view of getting income or capital gain out of it? If investors aren’t going to put in the money to pay off the debts and carry out the work required, then who is?
Executive reward packages
TW says, eg:
Our executive reward packages are benchmarked with those at other similar-sized organisations. We must pay competitive packages to attract and retain the best people. Bonuses are dependent on achieving specified performance improvements in key areas including leakage, pollutions and customer service.
We might reply:
Which organisations is it benchmarked against? The remuneration is about 10 times that received by the Prime Minister. It is about three times the remuneration paid to the CEO of Welsh Water, a publicly owned company. What efforts were made to recruit at a lower figure, taking into account the interests of customers? [Precise figures to be checked]
Bills and funding
TW says, eg:
In terms of how our operations and investment is funded, the water industry works in five-year regulatory periods, otherwise known as Asset Management Plan (AMP) periods. Every five years we agree our business plan with Ofwat, our economic regulator. This is based on extensive planning and customer research. As part of that process, we agree a set of performance commitments for the next five years, as well as Ofwat setting the prices we can charge our customers. The next Price Review with Ofwat is this year (2024) and will set price controls for water and sewerage companies for 2025 to 2030.
It’s important our bills are affordable but also allow us to meet our commitments. We achieve this balance by:
Continually evaluating what we need to do to improve our services to customers, and undertaking research to understand the future impact of things like climate change and population growth on our network.
Talking to our customers about what they value most from Thames Water and what they’re willing to pay for
Being challenged independently by representative bodies, such as our Customer Challenge Group (CCG)
We also keep our bills low through:
Operating our network as efficiently as possible to reduce unnecessary costs.
Borrowing money in competitive markets to minimise the cost of our debt.
Using the Government’s capital allowances scheme to keep our corporation tax bills lower than they’d otherwise be.
We might reply:
Details to follow soon.