(b) we expect the issue to be addressed in a reasonable period through alternative means, for example through a process that Ofwat already has in place or is developing ( alternative route ); (c) the issue reflects a well-established regulatory practice and we have not received compelling evidence to suggest we should revisit this in the context of this redetermination process.
Consideration of more fundamental changes to the regulatory framework are best addressed through industry-wide policy work, outside of these redeterminations ( well-established practice ); or (d) the issue would require a disproportionate amount of work to resolve in the context of this redetermination process when set against the potential impact ( disproportionate) . 35. This document sets out our current thinking about issues that are deprioritised on these bases. We will keep this under review, having regard to submissions and developments throughout the redeterminations. 36.
To the extent that errors have been made in Ofwat’s PR24 FD that are agreed by Ofwat and the Disputing Company and are straightforward for us to correct eg when updating modelling or calculations necessary to reach our redeterminations, we will correct them. This might result in increases or decreases in revenue allowed to Disputing Companies. 37. To the extent that any claims have been made by Disputing Companies which were not raised during the more than four-year Ofwat PR24 process, we will need to understand why this is the case, including whether such claims may be speculative or opportunistic.
We are also mindful that there are risks of determining new issues without the time to consult extensively as Ofwat was able to during the PR24 process. Where we are persuaded that there is a good reason for a claim not having been raised during the PR24 process, and it is not deprioritised in accordance with the filters set out above (paragraph 34), we propose to assess it as part of the redeterminations. 38. In making our redeterminations, we are mindful of the already substantial bill increases that customers are facing to pay for legally required drinking and wastewater quality, environmental and climate change resilience improvements.
Ofwat’s PR24 FD states that nearly 90% of investment, which is four times higher than at PR19, reflects legal requirements. 19 Throughout our assessment we will consider the potential impact of any changes to the Disputing Companies’ allowed revenue on bills, in particular by promoting efficiency and avoiding customers 19 Ofwat (2025) PR24 final determinations: sector summary , page 9. 11