At PR24, Ofwat set a separate business demand commitment alongside leakage and per capita consumption. Non-household consumption stopped being a footnote in the demand story and became something wholesalers are measured and incentivised on in their own right.
There is a structural problem with that, and it is worth naming plainly. The wholesaler carries the commitment. The retailer holds the customer.
Who owns the business customer, and who owns the target
Since April 2017, the business retail market in England has been open. Regional water companies remain the wholesalers, owning the pipes, mains and treatment works. Licensed retailers buy wholesale services and hold the billing relationship with businesses, charities and public sector customers. In Wales the same applies to organisations using more than 50 million litres a year. Scotland has run a comparable market since 2008.
So the organisation with the regulatory obligation to reduce non-household demand is generally not the organisation the business customer speaks to, receives bills from, or would think to call.
This is not a theoretical concern. Reviews of the market by Ofwat and by the Environment, Food and Rural Affairs Committee found it had not delivered on expectations for water efficiency improvements, with particularly low engagement from smaller companies. The Retailer Wholesaler Group’s own water efficiency roadmap put it more bluntly still, noting that each wholesaler is responsible for its own delivery plan and for involving retailers, and that collectively the plans fell short of the government’s 9% target reduction for non-household consumption. Its own warning was that progress would otherwise be piecemeal and uncoordinated.
The scale of what is sitting there
Here is the figure that should concentrate minds. Waterwise reports that smart meters and in-property leak detectors are finding leaking toilets in around 5 to 8% of homes and around 25% of commercial properties.
A quarter. Not of toilets, of properties. In a commercial estate of any size, the base assumption should be that a leak is present rather than absent, and the surprise should be finding a site without one.
The per-toilet cost is not trivial either. Waterwise gives it as 215 to 400 litres of treated water a day, silently, whether the building is occupied or not.
Why non-household is genuinely harder than household
It would be easy to read the underperformance as a lack of will. It is mostly a lack of access.
A household visit needs one appointment with one person who lives there. A non-household visit needs a named contact who may be a tenant rather than an owner, permission to enter areas that may be secured or operational, an induction, and often an out-of-hours slot because the plant room is only quiet when the building is empty. Multi-site organisations add a further layer, because the person with the water bill and the person with the keys are rarely the same person.
None of that is unsolvable. It is field work, and field work is a capability rather than a policy position. It is also why non-household demand programmes tend to stall between the intention and the visit.
Where the non-household water actually goes
The waste is often in plain sight. It is easy to dismiss or ignore, but across the commercial sites our teams assess, the same items recur.
- Leaking WCs, present in around a quarter of commercial properties on the Waterwise figures, at 215 to 400 litres a day each. A site with forty toilets is unlikely to have none.
- Urinals with no controls, or with defective or poorly maintained controls, flushing continuously in an empty building for roughly two thirds of every week.
- Taps set well above the flow rate the task requires.
- Irrigation, wash-down and external supplies, particularly on sites with landscaping or vehicle fleets.
- Cooling, catering and process equipment commissioned years ago against a use case that has since changed.
The common thread is that none of it registers as a fault. Nothing is broken, no alarm sounds, and the bill absorbs it. That is precisely why it survives.
The bill is the worst available evidence
A non-household water bill gives a total and nothing else. It will not separate process water from washrooms, will not identify water running out of hours, and will not flag a leak on the private supply pipe, which sits on the customer side of the meter and is therefore the customer’s cost even though the volume appears in national leakage reporting.
Consumption data is a different matter, particularly where a logger or smart meter sits on the supply. Overnight consumption at a site that closes overnight is the single most useful figure available, because a building with nobody in it should be using close to nothing. Any meaningful movement is waste, and it can be identified from a desk before anybody travels.
That is the same principle we apply on the network through our Intelligence work. Find where to act first, then send people to the right place.
What good delivery looks like
For a wholesaler building a business demand programme, four things separate a plan from a result.
- Data-led targeting, so visits go to sites with a demonstrable anomaly rather than to whoever agrees first.
- A field capability that can get into operational buildings, out of hours, with the right accreditations and inductions already in place.
- Fixing on the day wherever possible. A survey that produces a recommendation report and no fitted product converts at a fraction of the rate.
- A per-site evidence trail supporting the saving claimed, because business demand is a reported performance commitment and the reporting will be examined.
For retailers, the same capability is what turns water efficiency from a line in a tender response into something you can actually offer a customer. Retailers compete on price and on additional services, and water efficiency is one of the few with a measurable payback for the customer.
How do I reduce water use at my site?
If you are the business rather than the water company, three checks will tell an estates or facilities team most of what it needs to know before anybody is appointed.
- Read the meter last thing at night and first thing in the morning on a day the site is closed. Movement is waste.
- Check every urinal, whether or not it has a control, and every WC for a continuous run.
- Compare consumption per employee, or per square metre, against comparable sites if a benchmark is available.
If that turns something up, the saving is usually straightforward. If it does not and the number still looks wrong, the problem is somewhere a survey will find and a spreadsheet will not. Our water efficiency audits work the same way on the household side.
Where this goes next
Business demand is the youngest of the three demand commitments and the least developed. That makes it the one with the most available ground, and the one where a wholesaler that builds real delivery capability will separate itself from a wholesaler that writes a plan.
Our Saving Water team carries out workplace water assessment work across the UK alongside the household efficiency programmes we have delivered for water companies since 2007. Same teams, same evidence standards, different front door.
If business demand is a commitment you are carrying, or an estate you are responsible for, get in touch.
Common Questions
- How do I reduce water use at my business? Start by finding out where it goes. Read the meter overnight when the site is closed, because any meaningful movement is waste. Check every urinal, whether or not it has a control, and every WC for a continuous run. Then compare consumption per employee or per square metre against similar sites. Those three checks identify most avoidable waste before any survey is commissioned.
- Who is responsible for business water saving, the wholesaler or the retailer? Both, in different ways. Ofwat set the business demand performance commitment on wholesalers at PR24, so the regulatory obligation sits with the regional water company. Retailers hold the billing relationship with the business customer and compete partly on additional services, of which water efficiency is one. Progress usually depends on the two working together.
- Is a leak on my supply pipe my responsibility? Generally yes. Losses on customer-owned supply pipes are counted within national leakage reporting, but the water is billed to whoever owns the pipe. That is why a leak on the customer side of the meter shows up as a bill rather than as a fault report.
- How common are leaking toilets in commercial buildings? More common than most people expect. Waterwise reports that smart meters and in-property leak detectors are finding leaking toilets in around 25% of commercial properties, against 5 to 8% of homes. Each one wastes between 215 and 400 litres a day.
Where the figures come from
- Separate PR24 performance commitments for leakage, per capita consumption and business demand. Ofwat, PR24 final determinations: Our approach
- Business retail market open since April 2017 in England. Wholesalers own the network, retailers hold the customer relationship. Welsh threshold of 50 million litres a year. Scottish market since 2008. Retailers compete on price and additional services including water efficiency. Ofwat, Business retail market
- Ofwat and Environment, Food and Rural Affairs Committee reviews found the market had not delivered on expectations for water efficiency improvements, with low engagement from small companies. House of Commons Library, Water: non-household retail competition
- Each wholesaler responsible for its own delivery plan and for involving retailers. Plans fell short of the government’s 9% target reduction for non-household consumption. Warning that progress would otherwise be piecemeal and uncoordinated. Retailer Wholesaler Group, Water Efficiency Roadmap
- Leaking toilets found in around 5 to 8% of homes and around 25% of commercial properties. Also confirms Ofwat widened the PR24 demand commitment to include non-household demand. Waterwise, UK Water Efficiency Strategy progress report
- 5 to 8% of toilets leaking at any one time, wasting 215 to 400 litres per toilet per day. Waterwise, The Waterwise Guide for Offices
- Supporting figures on public perception of water use and household leaks. Water UK, research on public awareness of water use
- Reported leakage includes supply pipe losses on customers’ pipes. Ofwat, Leakage
- Household efficiency programmes for water companies since 2007. WRAS approved product range. Aqualogic, Saving Water
