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RWG Good Practice Guidance & Adoption

The Retailer Wholesaler Group (RWG) is a trading party group made up of retailers, wholesalers, the non-household market operator (MOSL), the Consumer Council for Water (CCW) and Ofwat. Their aim is to tackle the big non-household market operational issues, make changes and share good practice to improve overall customer service in the market.

We are a member of this group and are continuously working to align with the guides where we can and support the plans to formalise these guides into the codes. Please visit www.mosl.co.uk for access to the relevant guides and their addendums.

Below is our adoption status per guide – as part of this we have highlighted particular instances in which we have not yet adopted parts of the individual guidance or where we attempt to go further than the guidance.

Data Logging

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Data Logging Our Alignment - Partial
Wholesaler Responsibility  
The Wholesaler will accept Data Logging requests direct via an application form published on its website. Requests via a market bilateral form will not be accepted. Third parties will not be asked to submit applications via a Retailer. Partial - we do also allow submissions directly via email and accept these from third parties. We are in the process of updating our website and a form (not mandatory) will be provided. The publication of this form will then move us to full alignment shortly.
The Wholesaler will publish its Data Logging Application Form and Terms and Conditions (Policy) on its website together with an e-mail address for dealing with queries. Partial - as above.
The Wholesaler will provide a substantive response to data logging requests within five (5) business days of a completed application and will not unreasonably withhold or delay consent to a proposed installation. Aligned
The Wholesaler may charge the Applicant to cover the costs of surveying the meter or installing a pulse unit and/or splitter. Costs will be published in the Wholesaler's Non- Primary Charges. Aligned
Where the installation of the splitter is carried out by the Wholesaler this will be completed within 22 business days from the request or quote being accepted. Aligned - we endeavour to complete these within 10BD's for standard requests.
The Wholesaler may install data logging equipment for operational monitoring purposes. This can be either a permanent or temporary logger. Where a Wholesaler is unable to allow a data logger to be fitted due to the presence of an operational (leakage) logger they will either provide a splitter or make flow data available, in accordance with their Terms and Conditions (Policy). Aligned
The Wholesaler reserves the right to disconnect data logging equipment, even if a splitter is fitted, where it is found to be interfering with the reading of meters or affecting the performance of Wholesaler ancillary equipment (e.g. radio devices or operational loggers). The Wholesaler will provide evidence of the issue caused and will, where possible, try and resolve this with the owner/installer of the data logger. If the issue cannot be resolved the Wholesaler will provide 22 business days notification in advance of disconnection, where the owner of the equipment is known. In certain operational circumstances e.g. a leaking meter it may not be possible to give advanced notice. Aligned - if the owner is not known (labelled) and/or we have not been notified of the installation we will continue with the disconnection.
Where the Wholesaler identifies high / unusual consumption or leaks on an operational logger fitted to a customer meter, they will endeavour to notify Retailers and/or carry out other leakage investigation work. Aligned
The Wholesaler is responsible for the maintenance of its data logging equipment, ensuring that it is clearly labelled with a contact name and telephone number. Aligned
Provision of data from Wholesaler loggers  
The Wholesaler will make data available to the Applicant from their permanent operational (leakage) loggers. Data will be provided at a minimum of Day + 1 at 15 minute intervals. Aligned
The Wholesaler will investigate a flat-lining issue within 22 business days of receiving a request. The applicant should notify the Wholesaler direct, in accordance with their Terms and Conditions (Policy) if they become aware of a data flat-line on a Wholesaler’s operational logger (where data is shared). Aligned
The Wholesaler may make a reasonable charge to cover the cost of providing data including access to on-line data portals; FTP/SFTP formatted data or one-off data requests. Costs will be published in the Wholesaler's Non-Primary charges. Aligned
A signed letter of authority (LOA) from the customer is required, where the applicant is not the current retailer. The LOA must cover the period of data sharing. Aligned
Data Flatlining / Reporting damaged meters  

Where it is confirmed that the meter is damaged the Wholesaler should be notified as follows:

The Retailer will submit a B/01 (process B5 Retailer Initiated) market form

The Third Party will notify the Wholesaler direct in accordance with their Terms and Conditions (Policy). A job report and photos should be provided. The Wholesaler will then notify the Retailer via the B/01 (B5 Wholesaler Initiated) process.

 Aligned

If data logging equipment cannot be fitted due to a leaking meter, damaged chamber or buried meter, the Wholesaler should be notified as follows:

The Retailer will submit a B/01 (process B5 Retailer initiated) market form.

The Third Party will notify the Wholesaler direct in accordance with their Terms and Conditions (Policy). The Wholesaler will then notify the Retailer of this via the B/01 (B5 Wholesaler initiated) process.

 Aligned
Meter Exchanges  
The Wholesaler will reconnect any data logger (or similar device) following a meter exchange within 22 business days of the exchange, provided the meter is compatible. The wiring up of loggers is not standard and the Wholesaler may not have experience of the equipment to be re-attached. The Wholesaler will notify the owner of the logger if they are unable to reconnect it. Aligned - we are unlikely to reconnect any loggers after an exchange so will notify owners in instances that contact details for the owner of the equipment are attached.
Non-loggable meters  
Where a meter is > 15years old and is not compatible for logging purposes, the Wholesaler will not charge for the meter exchange. Retailer must submit B/01 form (Process B7). Third party should email us the request and we will notify the retailer by raising the form. Aligned
Where a meter is < 15years old and is not loggable (eg as a result of a damaged pulse connection point) a charge will be made for the meter to be exchanged (unless the meter is due for periodic/proactive exchange within 6 months). The Wholesaler will notify the applicant as follows;

The Retailer will be asked to submit a B/01 (process B7 Retailer Initiated) market form so that a quote can be provided for the meter exchange, in accordance with the Wholesaler's Non-Primary Charges

The Third Party will be provided with a quote in accordance with the Wholesaler's Non-Primary charges. The Wholesaler will then notify the Retailer of this via the B/01 (B7 Wholesaler Initiated) process.

 Aligned

Brown or discoloured water

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Leakage Allowance Our Alignment - Full
Type of Allowance  
Type of allowance awarded for leak on customers pipework

Not applicable. We do not offer an allowance for water unless a wholesaler issue.*

Please see Thames, Anglian or Southern for information on their adoption for sewerage allowances.

Please note we are obliged to provide an allowance following a first time meter installation.
If requested by the Retailer, the Wholesaler will provide substantive historical information on allowances awarded to the Customer for the past 3 years. Aligned
Identifying the leak  
If a leak has been identified as on wholesaler apparatus report to wholesaler Aligned - please report here. 
Time to repair the leak  
The leak must be repaired within 30 days of the Customer or Retailer becoming aware of the leak on the supply pipe. A waste notice may be issued to the Customer under Section 75 of the Water Industry Act 1991 and this will inform the Customer of the leak and their responsibility to undertake a repair within 14 days. If the leak is not repaired within this timeline, the Wholesaler reserves the right to carry out the repair using its statutory powers and recharge the Customer accordingly. Alternatively the supply may be turned off to prevent waste of water, damage or contamination in accordance with Section 75(9) of the Water Industry Act 1991. Aligned
What period will the allowance be granted for?  
If the leak occurred on the Wholesalers apparatus and it was the Wholesalers responsibility to undertake the repair an allowance will be applied for all additional charges raised, covering the whole period of the leak and be applied on each occasion a leak occurs on the Wholesalers assets. Aligned
How many allowances can be requested?  
If the leak occurred on the communication pipe or other wholesaler apparatus the allowance will be considered for the whole period of the leak with no limits to occasions or charges. If the leak is on the communication pipe and the Wholesaler is repairing the leak, the Retailer will not be penalised for any delays by the Wholesaler in undertaking the repair. Aligned
Calculating the allowance  
The wholesaler will accept both customer and retailer meter reads when considering an allowance request. Aligned
ADC x Leak period Aligned

Complaints

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Complaints Our Alignment - Full
Wholesaler Responsibility  
Will review the information provided by the Retailer and ensure that any additional requests are shared back to the Retailer as soon as possible. Aligned
Commit to the timelines as dictated in the codes, aspiring to respond to retailers within five (5) working days to allow the Retailer to respond to the customer within ten (10) working days Aligned
If a complaint is completely an operational issue the Wholesaler can choose to deal with it directly but must inform the Retailer within a maximum of 2 business days to allow the appropriate forms to be raised in line with market codes. Aligned
Mixed Responsibility  
If appropriate, retailers and wholesalers should be willing to engage in tri-partite conversations to seek appropriate resolutions within a timely manner. Aligned
Memorandum of Understanding (MoU) Aligned
This document should be used in conjunction with the memorandum of understanding and it’s recommended that all parties are committed to the MoU Aligned - we are currently signed up to the MOU

Meter Reading Services & Standards

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Meter Reading Services & Standards Our Alignment - Full
Wholesaler Responsibility  
Where premarket opening long unread meters exist, Wholesalers have a responsibility to work with Retailers to resolve these issues. Aligned
Wholesalers shall make it clear on their website whether they offer a meter reading service to NHH Retailers. It is advisable to publish terms and conditions on websites to improve transparency and ease procurement of services for Retailers. Aligned
Wholesalers who choose to offer meter reading services to Retailers should ensure the service they provide allows Retailer to perform to the standards set out in the Market Codes (e.g. minimum read frequency requirements). Aligned - our details are available on our webpages and within the RWG Retailer Information Document.

Meter reading service provider should be prepared to offer ad-hoc meter readings for a variety of different reasons. - Transfer readings – these should be managed in line with the Market Code requirements (two Business Days either side of transfer date) to allow Retailers to meet their obligations.

Where transfer readings are taken on behalf of a Retailer, timely feedback of read data where attainable is required to allow the Retailer to submit into CMOS within 2 Business Days of the read being taken. - General ad-hoc – Retailers or their customers may request an off cycle reading for various reasons such as to calculate an allowance, monitor usage more closely or validate reports of damage.

Meter reading service providers should consider offering appointments where possible so Retailers can provide their customers with clear expectations. - Types of reading – transfer readings or general ad-hoc readings can be either wireless (where applicable) or manual, to provide a greater level of assurance meter reading service providers should allow Retailers to specify the read type.

 Aligned
Regardless of how data is shared with Retailers, meter reading service providers should ensure data includes the below as a minimum:
  • SPID/DPID
  • Premises address
  • MSN
  • Reading or skip
  • Date & time of reading/skip
  • Type of reading (manual or wireless)
 Aligned

Unplanned Activities

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Unplanned Events & Incidents Our Alignment - Full
Event Tiers  
Tier 1, 2 and 3 events (and conditions) Aligned
Methods of Communication  
General Aligned
Retailer Specific Aligned

Planned Activities

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Planned Activities           

 Our Alignment - Partial
Wholesaler to NHH Customers  
The use of web and social media for all planned activities (D1, D2 & D3) Partial - use of social media dependent on the nature and impact of the planned works. We publish D1 and D2 on our retailer webpages and details can also be found using our “search our area” function. D3 works are not published.
The use of portal/push notifications for all planned activities / Customer Maildrops (D1, D2 & D3) Partial – we do not use push notifications to customers directly as we do not store their details. We will issue letter drops for D1 and D2 activity however, for D3 activity we do not do this for all incidents. This is dependent on the scenario - if needed we will speak to the customer directly as part of our work to enable the works either by visit (and leave a card) or attempt to call them.
Wholesaler ‘Pop Up’ campaigns and Public Consultations for all D1 events Partial - works dependant. We undertake drop-in sessions if works are likely to have a high level of interest/impact - these sessions are notified to customers as part of our initial letters and mail drops for this activity. We also make ourselves available to parish and councillor meetings.
Customer Consultation (D1 and potentially for sensitive customers during D2 and D3) Aligned - as part of our D1 activity we visit each NHH property when delivering letters with 22BDs notice to give a brief outline of works and to identify any particular needs. We also offer free temporary supplies if water is business critical and will explain that access will not be restricted if customer visits are required, such as shops and surgeries. Hospitals, prisons, care homes and schools are always consulted as part of D1 works to ensure best time and special arrangements are put in place.
Wholesaler to Retailers  
The use of alerts (push) to retailers for D1, D2 and D3. Partial - D1 information is published on our retailer website but not currently pushed to retailers. We believe our actions above regarding direct customer contact should ensure minimal impact as a result of this. D2 and D3 notifications are emailed to retailers.
The use of web and social media for all planned activities (D1, D2 & D3) Partial - D3 information is not currently published to our web and social media pages, however, works and incidents are available on our ‘”search our area” section.
Wholesaler public consultations Not aligned - we do not involve retailers in all consultations. We believe our actions above regarding direct customer contact should ensure minimal impact as a result of this however, we will speak to retailers if we believe this is required or is requested.

Planned Activities

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Disconnection for Non-Payment Our Alignment - Partial
Planning to Disconnect  
Retailer or AE contacts the wholesaler via email listing the SPID’s, customer name and address that may be disconnected. The Retailer or AE will only raise form I/01 if a property actually gets disconnected. Partial - we do not require prior notification for this activity, we are happy for the AE or retailer to proceed and notify us only if a disconnection is made.
Carrying out a disconnection  
Remain on site for up to 20mins to enable the customer to make payment.  Not aligned - we will attend to turn off supply as instructed. We prefer this activity is undertaken by an AE and look to make no further amendments to this.
If the disconnection can be carried out, then isolate the water supply using a lock off/blanking device Partial – temporary disconnections are made by closing the outside stop valve. This is in line with our requirements of an AE. AE addendum located here.

Return to Sewer Allowance

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Return to Sewer Allowance  Our Alignment - N/A
Return to Sewer Allowance N/A – Water Only

Incentive Schemes

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Incentive Schemes  
Gap site Will be reviewed 2021/22.
Vacant site We are beginning our own internal vacant initiatives and currently do not believe the vacant site incentive is the correct mechanism for this at this time.
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