also consider 14 issues raised and evidence provided by Ofwat and third parties. 15 (see the Guide, paragraph 3.14.) 31. We will adopt a fair and proportionate approach to assessing the issues raised with us. For example, for a particular issue, we could decide to increase or reduce Disputing Companies’ funding and we will consider whether changes in approach should be applied consistently across Disputing Companies, noting that consistent implementation of certain changes could have results that are unfavourable to some or all of the Disputing Companies.
We will also consider aspects of the determinations which Ofwat has raised with us as potentially favourable to the Disputing Companies and we will have regard to the wider context of Ofwat’s decisions. 32. We propose to use the same regulatory building blocks as Ofwat used in its determinations. However, we do not exclude the possibility of revisions to Ofwat’s approaches and methodologies, including consideration of whether approaches may be modified, simplified, or any aspects of the price controls removed or supplemented. We are mindful of the extensive consultation that Ofwat carried out on aspects of its approaches and will consider this context in deciding whether to make changes. 33.
Using the considerations set out in the Guide 16 and our overriding objective, we propose to deprioritise a number of issues, and thus not conduct further work on them. We outline these in the sections below. 34. We do not intend to focus on issues raised with us where: (a) the issue has an insignificant impact on customer bills or other outcomes. 17 A factor in this is where the value of the issue would be 0.5% or less of the relevant PR24 total expenditure ( totex ) allowance permitted to a Disputing Company in Ofwat’s determination ( de minimis ).
18 In doing so, we are mindful of the information asymmetry between us and the Disputing Companies and the incentive for Disputing Companies to selectively raise issues for redetermination; 14 Guide ( CMA205) , December 2024, paragraph 3.14. 15 The third party submissions we have received so far have primarily addressed issues which have already been raised by the main parties. We note that CCW has raised issues regarding increasing affordability support and requested changes be made to Ofwat’s C-MeX measures (which measure customer experience). 16 Guide ( CMA205) , December 2024, paragraph 3.14. 17 Guide ( CMA205) , December 2024, paragraph 3.14(d).
18 Where the costs relate to only water or wastewater, as in the case of enhancement, we have used water or wastewater total totex allowance as the denominator; where the costs relate to water and wastewater, for example business rates, we have used water plus wastewater total totex allowance as the denominator. 10