Memorandum submitted by ACRE (Ofwat 06)
OFWAT'S PRICE REVIEW 2009
ACRE leads the Rural Community Action Network
(RCAN) comprising 38 Rural Community Councils (RCCs) and 8 regional
bodies that together provide comprehensive support to communities
and community groups across rural England.
Management of community owned assets is a core business
for ACRE and its network members. ACRE supports and trains the
specialist rural community building advisers located with its
local members, cascading dedicated advice and technical support
to grass roots organisations. ACRE provides support individually
and collectively at regional level and represents the interests
of community buildings at national level.
There are 8900 village halls and similar community
buildings in rural England managed by volunteer committees. Community
buildings provide a centre for delivery of services and activities
contributing to the well being of the community.
1. CONDUCT OF
THE REVIEW
This submission relates to the conduct of the
review and in particular Ofwat's and United Utilities proposed
definition of the customer groups that they will be considering
under a review of charging structures.
We are concerned to note that they will only be considering
three types of building category:
— Faith buildings—registered
under the Places of Worship Registration Act 1855.
— Community amateur sports clubs (CASCs)—registered
under Schedule 18 to the Finance Act.
— Scout and Guide Association buildings.
These categories will exclude all other community
buildings in rural, urban and suburban areas whether traditional
village halls, WI halls, church halls, memorial halls or community
centres.
United Utilities reasoning explained in their
letter[23]
aligns the decision with the "zero rateable value set by
the Valuation Office" assuming that community halls are not
eligible for rate relief. In fact, the local Government Finance
Act 1988 (sections 43, 45 and 47) provides for 80% mandatory rate
relief and 20% discretionary relief at the discretion of the local
rating authority. This is applicable to all premises (not just
CASCs and Scout and Guide Association buildings) that have charitable
purposes whether or not they are registered charities. Faith buildings
are exempt from rates under the Local Government Finance Act 1988
paragraph 11, Schedule 5. It is also worth noting that church
halls will not be classified as faith buildings unless they are
used in connection with a place of religious worship and many
are not.
We do not believe that Defra, as the Department
responsible for rural affairs and that resides over the water
industry as well as holding the Secretariat for the Rural Community
Buildings Network, would want an anomaly in the rules for water
charging.
2. IMPACT OF
CHARGING STRUCTURE
United Utilities also claim that the groups
they have selected are deemed the worst financially affected.
ACRE's briefing[24]
requested evidence from halls that were affected and an extract
is detailed below. The increase in charges is proportionate to
those experienced by Scout Groups, CASCs and Churches.
|
| Building | Previous annualcharges
| New annualcharges |
Percentageincrease |
|
| Hough Village Hall, Cheshire | £53.65
| £2580.00 by 2011 |
4009% |
| Alvanley Village Hall, Cheshire | £67.71
| £458.72 in 2008rising to £1,233by 2010
| Initially 675%rising to 1813%
|
| Kelsall Community Centre, Cheshire | £400.00
| £1,600 | 400%
|
|
3. SOLUTIONS
Defra is aware of the current funding climate for capital
works on community buildings. Whilst volunteer committees striving
to maintain and manage their buildings are aware of the possibilities
of ensuring that their drainage water does not run into the main
drainage system the actual costs of works to provide soak-a-ways
are prohibitive.
In the longer term ACRE considers a social tariff for community
and voluntary groups to be appropriate. We would draw attention
to the previous Severn Trent Water Scheme of Charges, Section
9, Sub-section 10 which charged community premises "as if
their site area was in the band of 100-199 square metres"
(ie Band 3) not according to their site area. There was a
condition that there were no commercial aspects of the operation
of the premises eg a permanent bar. The Scheme of Charges was
previously approved by Ofwat and we believe a similar tariff could
be introduced by all water companies following detailed consultation
with the possible user groups of this tariff. This would follow
the Guidance[25] intended
by the Secretary of State.
ACRE
February 2009
23
Letter of 16 February 2009 United Utilities to ACRE & Community
Matters. Back
24
ACRE Briefing to Village Hall Advisers August 2008. Back
25
Guidance on Charges Scheme Provisions for Non-Household Customers-Water
Industry Act 1999. Back
| 
