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Enforcement

The Inspectorate publishes the drinking water quality legal instruments on its website under company improvement programmes. Security (SEMD and NIS) legal instruments are considered sensitive and therefore are not published in the public domain. A summary of the legal instruments issued in 2024 is below.

Type of legal instrumentNumberCompanies
Regulation 28(4) notice relating to risks identified in water safety plans10Dŵr Cymru Welsh Water (7), Hafren Dyfrdwy (3)

The individual legal instruments listed above have been discussed in detail, within the quarterly Chief Inspector’s reports published throughout 2024.

2024 saw the majority of work to secure legal instruments for the delivery of improvement programmes committed to by companies during PR24, reflected in the additional legal instruments summarised in the table below. These legal instruments enable the Inspectorate to monitor the progress of company plans to address drinking water quality, NIS or SEMD risks. In its PR24 determination, Ofwat have linked the price control deliverables for enhancement schemes to the Inspectorate’s issued legal instruments. The Inspectorate shall continue to work closely with Ofwat and keep them updated throughout the AMP.

Type of legal instrument

Number

Companies

Regulation 28(4) notice relating to risks identified in water safety plans

4

Dŵr Cymru Welsh Water (4)

Undertaking accepted under section 19(1) of the Water Industry Act 1991 for drinking water quality improvements

3

Dŵr Cymru Welsh Water (2), Hafren Dyfrdwy

Undertaking accepted under section 19(1) of the Water Industry Act 1991 for SEMD improvements

5

Dŵr Cymru Welsh Water

Regulation 17(1) notice for improvements under the Network and Information Systems Regulations 2018

2

Dŵr Cymru Welsh Water, Hafren Dyfrdwy

Formal acknowledgement of a set of actions (‘Acknowledged Actions’)

1

Dŵr Cymru Welsh Water

Transformation Programmes

A key activity of the Inspectorate’s Enforcement Team is the management of the transformation programmes. The Inspectorate may initiate a transformation programme where the risk position of a company becomes elevated or is frequently realised in a specific area of operation. For example, multiple, similar drinking water quality events caused by a lack of appropriate training. Once a company is notified that the Inspectorate intend to place them into transformation, they seek to work collaboratively to put together a measurable programme of improvements.
A transformation programme includes a set of bespoke legal instruments to address those areas of high risk. They are generally large in scope and require a long-term, concentrated effort to move the risk position. Following the initial tranche of legal instruments, follow up legal instruments may be served to address issues that fall out of the initial programme.

Transformation is not only about completing the work included in legally binding notices, but it is about a robust and consistent effort to reduce overall risk. A large factor in this can be the attitude of company personnel, particularly those in senior leadership roles, who ultimately determine the attitude of the company.
Dŵr Cymru entered transformation in June 2024 following an increasing risk profile as demonstrated by the company’s event and compliance reports and the subsequent assessment by the Inspectorate and the high number of recommendations these reports generated.

The transformation programme has been developed in collaboration with the company during 2024 and aims to improve performance in a number of key areas such as training, governance, procedures, and a hazard review of risks at water treatment works. Five transformation notices were served on the company at the end of 2024.
As part of routine work alongside the transformation programme, a new discolouration target for AMP8 was agreed with the company, however there remains to be any significant improvements in the company’s performance against this metric, to bring it to industry average. The new AMP8 target is a stretching target of a 50% reduction on the AMP7 target, with the aim that by the end of AMP9, the company will align with the rest of the industry.

The company has requested discussion and constructive feedback on milestone reports, recommendations and other aspects to deliver improvements which is positive and the company has stated an aim to be more open and collaborative as a whole, which of course is welcomed. The Inspectorate has started to see improvements in the submitted reports following these discussions, and encourage the company to continue in this fashion.
The Service Reservoir and Tank Inspection notice has been well managed, even with known access complications to some of the assets, the company addressed this within its planning and the company completed this notice on time, by March 2025.

The approach the company took to the transformation notices, in particular the Hazard Review notice was well-thought out, and the company appear to be placing the right level of personnel and support in the management of the notices to ensure its success.

The company is keen to have discussions and feedback regarding recommendations, milestone reports and other assessments by the Inspectorate. However, there remains some defensive or sensitive reactions during these meetings. Whilst a defensive posture is very natural, the Inspectorate’s goal is to aid the company in their understanding of our expectations and to move the company into a position where its risk profile decreases.
The company has shown eagerness to complete the transformation programme as expeditiously as possible. However, it must remember that some culture shifts take longer to embed, and whilst the Inspectorate commend the enthusiasm, the company must accept that these programmes take several years.

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