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Appendix 4 Enhancement Business Cases and Cost Adjustment Claims

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Appendix 4 Enhancement Business Cases and Cost Adjustment Claims Appendix 4 Enhancement business cases and cost adjustment claims 1 Overview This summary sets out the enhancement expenditure in our plan and provides the detailed business cases to demonstrate the need for action and the solutions we have identified. In Section 4.1 we have presented evidence for all material enhancements outside of the four areas where we believe cost adjustments are required. It includes the following business case summaries: 4.1.1 Security enhancements 4.1.2 Catchment management 4.1.3 New development 4.1.4 Water NEP and other enhancements 4.1.5 Wastewater NEP 4.1.6 Wastewater developer services and growth 4.1.7 Welsh language services Section 4.2 and 4.3 contain the cost adjustment pro formas and detailed business cases respectivel y for the four cost adjustment claims. The four areas – Reservoir safety, Supply resilience, reducing lead and enhancing biodiversity and well-being. 4.2 proforma summaries for all cost adjustment claims 4.3 Approach to cost adjustment claims 4.3.1 Supply resilience 4.3.2 Reservoir safety 4.3.3 Reducing lead 4.3.4 Enhancing biodiversity and well-being Our May submission also included two econometric modelling claims – for water and wastewater services respectively. This was based on the identified risk that our specific circumstances are such that econometric models may not be able to accurately predict required efficient expenditure. We remain of the view that the size, rurality and lack of historic data means that it will be very difficult to effectively model the expenditure requirement for Hafren Dyfrdwy (HDD) using high level industry econometric models. However, given that we are not yet aware of how Ofwat plans to calculate HDD’s expenditure requirements, we have chosen not to restate these modelling claims at this stage. Instead we have focused on making cost adjustment cases for particularly sensitive blocks of expenditure that we consider will not be adequately allowed for. Document Title [controlled | protect | internal | public] Contents 4.1 Wholesale enhancement investment 4 4.1.1 Security business case ................................................................................................................................................ 8 4.1.2 Catchment management business case ................................................................................................................15 4.1.3 Developer services business case ...........................................................................................................................20 4.1.4 Ancillary water service business case ....................................................................................................................22 4.1.5 Wastewater environmental programme business case .....................................................................................26 4.1.6 Wastewater developer services and growth business case ..............................................................................44 4.1.7 Welsh language services business case .................................................................................................................47 4.2 Cost Adjustment claims 60 4.2.1 Methodology followed to identify and evidence cost adjustment claims ......................................................60 4.2.2 Cost adjustment claim summary forms.................................................................................................................63 4.3 Full business cases for the four cost claims 71 4.3.1 Reservoir safety cost assessment claim ................................................................................................................71 4.3.2 Reducing Lead in Wales cost assessment claim...................................................................................................91 4.3.3 Supply Resilience cost assessment claim ........................................................................................................... 136 4.3.4 Biodiversity and wellbeing cost assessment claim ........................................................................................... 162 Document Title [controlled | protect | internal | public] 4.1 Wholesale enhancement investment Interaction between enhancement expenditure and cost adjustment claims In line with Information Notice 18/11, we’ve identified all material programme items of our enhancement expenditure and have: explained why the expenditure is classified as enhancement and not as base, including identifying the drivers of the expenditure and the benefits; and provided evidence to support the need for the expenditure and how customers are protected. As explained above, evidence to support cost efficiency is described in appendix 5. Our enhancement cases include a wide range of inputs and data sources including: interpretation of current and future legislative and regulatory requirements as well as customer expectations; reference to associated current and historic performance baselines; overview of intervention options developed and estimation approaches used; assessment of benefits delivered from different intervention options; and sensitivity of investment to customer protection mechanisms. Our general approach to developing business cases for enhancement not subject to adjustment claims is set out in the table below. In summary we have explained why the expenditure is classified as enhancement and not as base, including identifying the drivers of the expenditure and the benefits; and provided evidence to support the need for the expenditure and how customers are protected. Efficiency of the costs are covered in appendix 5 – Efficient costs. Ofwat cost Relevance of cost adjustment Key themes considered in each enhancement business case adjustment criteria to a making a robust criteria enhancement business case Why do we consider this investment to be enhancement (i.e. Need for Specific relevance – A fundamental driven by statutory increase, clear customer support or investment component of any business case change in external conditions acting upon us)? What is the current level of service and how will it change? Does the proposed intervention deliver what customers / the statutory obligations want/require? Is the programme optimal? Is it cost beneficial (discretionary Best option for Specific relevance – A fundamental investment) or cost effective (statutory investment)? customers component of any business case What is the opportunity for a range of potential interventions within the programme? What is the scope for wider benefits that will result? What is the basis for estimating the identified expenditure? Specific relevance – A fundamental As per the cost efficiency chapter – What confidence do we Robustness and component of any business case. have that estimation methods are accurate and efficient efficiency of However, generally justified at a relative to external benchmarks? costs company level in appendix 5 – Securing cost efficiency. How have we used wider information to understand additional opportunities for further efficiency? How is the expenditure covered by proposed Performance Customer Specific relevance – A fundamental Commitments and Outcome Delivery Incentives (as set out in protection component of any business case the relevant chapters)? 4 What wider statutory / regulatory mechanisms will hold us to account for non/ under or late delivery? Wider relevance – Best considered As per affordability and risk/reward chapters – Is the business Affordability at a business plan rather than plan affordable? individual business case level. Wider relevance – Best considered Board assurance As per board assurance statement – Has the expenditure at a business plan rather than within the business plan been subjected to appropriate individual business case level. governance? Not relevant– Business cases do not make any assumptions as to Need for cost how Ofwat will independently NA adjustment assess the need for the identified expenditure. Not relevant– Business cases consider the basis for all relevant Management enhancement expenditure rather NA control than identifying reasons for variance relative to a generic benchmark. Read more Chapter 2: Customer Insights; Describes the research we’ve carried out to understand the expectations and views of our customers. Chapter 10: Securing confidence and assurance; Sets out wider governance of our plan. Appendices 2 and 3: Rationale for PCs and Bespoke PC definitions; Provides contextual information on the drivers of expenditure, customer and stakeholder views and performance commitments. Appendix 5: Efficient costs; Provides evidence to support accuracy and efficiency of business plan expenditure. 5 Wholesale Water enhancement expenditure overview Activity Enhancement Related Base Totex Estimate Cost Table WS2 lines Performance commitment coverage Wider customer included in plan included in of implicit Adjustment covered protection plan* allowance claim mechanism Water supply interruptions Supply resilience 1.150 10.121 11.271 2.571 8.700 Capex: 14 WRMP process Water quality complaints (Base Mains bursts expenditure Unplanned Outage WS1, line 13) Risk of severe restrictions in a drought Water supply interruptions Reservoir safety 4.350 3.150 7.500 0.420 7.080 Capex: 14, 24 Legislation Risk of severe restrictions in a drought (Base expenditure WS1, line 12) Number of lead pipes removed Lead 2.930 0 2.930 0 2.930 Capex: 6 DWI undertakings Water quality compliance (CRI) or
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