Okay. Good morning, everyone. My name is Chris Laybutt, Investor Relations and Clean Energy Strategy Director here at United Utilities. And I'd like to welcome you all to our capital markets event today. As always, please note the cautionary statement at the start of the presentation on your screens now. And, to get us started, I think, as you all know, we've published our PR24 business plan this morning, which you can find on our website, alongside an RNS and a neat summary of the documents in terms of a summary document. The format of today's event will be a brief presentation by our CEO, Louise Beardmore, and CFO, Phil Aspin. And then we'll follow that with some Q&A at the end of the session.
So about 20 minutes for a presentation, followed by Q&A. The, the Q&A will be conducted live, so if you'd like to ask a question, please use the Raise Hand function, and, and turn your camera on, so we can, so we can see you as well. Okay, terrific. With that, I'll hand over to, to Lou and Phil.
Thanks, Chris, and good morning, everybody, and thank you for joining us today to discuss our PR24 business submission that, as Chris said, we submitted to Ofwat this morning. It's a really exciting plan. It's the biggest investment in our region's water and wastewater infrastructure in over 100 years, and we're delivering what matters for customers, for communities, and for the environment. We're safeguarding supplies and protecting and enhancing our rivers, improving drinking water quality, and reducing flooding. We've got really strong customer support and advocacy for the plan that will transform services for customers and provide significant growth opportunities, too. There's a long way to go before the final determination, but we've got the flexibility with the financial strength in our balance sheet to enable the growth that we're setting out today. And what's more, we're not waiting.
We've already started with delivery, giving us the confidence that we can deliver on the ambitions that we're setting out, and we're backing ourselves, backing ourselves to deliver the outperformance that everybody and we want to see. I spoke to our results presentation back in May, and I set out how we were approaching and progressing our plans for PR24. We've been out, and we've been listening to customers and communities right across our region. We've got five fantastic and very diverse counties in the North West, and what is clear is that they all have very different challenges and needs. By taking this approach to our engagement, we've been able to build and adapt our plans to deliver targeted county-based plans that deliver what matters most to them.
This five counties engagement model has not just actively informed the development, engagement, and support for our plan, it's also at the heart of how we intend to deliver the step change that we all want to see. We need to improve services for customers and the environment, and that's why we're proposing a hugely ambitious plan, GBP 13.7 billion worth of investment, and a plan that is gonna see us deliver the largest level of infrastructure investment into water services here in the North West for over 100 years, and an environmental plan that is seven times greater than our AMP7 plan today. Our engagement has been really, really robust. We've spoken with 95,000 customers, and not just today's customers, but future bill payers, too, securing really strong advocacy, with 74% of support for the plan.
We've also conducted 79 research projects, driving innovation and opportunity, and as well as delivering improved services, we're able to deliver real growth opportunities for the North West, too. A chance to drive inward investment and ignite a regional economy, as our plan will support 30,000 jobs, with 7,000 of them being new ones. Now, before we delve further into the detail of our plan, I wanted to highlight how we're currently performing. We've got a really strong track record in delivering on our promises, which gives us real confidence that we can deliver what we've set out in our business plan. We believe in doing business the right way, behaving responsibly, and focusing on the things that matter. Our fully funded pension scheme, low level of gearing, and coupled with sector leading credit ratings, demonstrate our long-term thinking and our focus on financial resilience.
We lead the way on affordability schemes for customers, and we always have done, ensuring a wide range of scheme and support for many customers right across the North West. We've got a strong track record of delivering service, performance, commitments, and ESG practices, and we've consistently achieved around 80% of our ODIs so far during AMP7, with the last year being our best ever performance, delivering 83% of our performance commitments, the highest in the sector. From an environmental perspective, we've got a strong track record, having been awarded the highest four-star rating in the EA's annual assessment in five of the last eight years, and we continue to lead the sector on reducing pollution. But we're not waiting for AMP8, because we've already started.
Our accelerated GBP 1.2 billion investment has allowed us to make an early start on tackling combined sewer overflows with a team at 500 strong by the end of the year, innovating and delivering already... enabling us to today propose the UK's biggest CSO spill reduction program, reducing storm overflow activations by 60% by 2030, against the 2020, 2021 baseline. We've worked really hard, hard to deliver all the elements that are needed to deliver an exceptional plan. We've worked closely with all our regulators to ensure we're delivering a comprehensive plan, a plan that delivers against all of our statutory obligations, and at the same time, a plan that delivers the things that customers want to see. So what are we proposing?
Well, we'll be completing programs that will see us improve the quality of water that is provided to over 1.4 million homes and businesses here in the North West. We're gonna be investing in our Victorian aqueducts to ensure we protect supplies in our key cities of Manchester and Liverpool, safeguarding supplies for 2 million homes and businesses all working here. And now, more than ever, as we respond to the challenges of climate change and population growth, we need to focus on resilience, doubling our efforts on leakage. This plan sees us replace over 950 kilometers of water mains, install over 900,000 smart meters, so that we can help domestic and business customers reduce consumption and drive lower bills. And at the same time, our combined programs on water supply and demand will see us half the chances of future hosepipe bans.
We are clear, we're clear that we need to respond quickly and effectively to reduce the level of storm overflow activations. In the North West, we experience greater levels of rain, coupled with one of the highest combined sewer infrastructure systems in the country, requiring us to go further and faster than most to make the step change that everyone, including us, we all want to see. That's why we're proposing the biggest CSO spill reduction program across the country, and at the same time, enhancing and protecting over 500 kilometers of rivers and bathing waters. We're also driving hard to reduce internal sewer flooding, and our programs targeting a 32% reduction. What's important is that we want to deliver our combined programs in a responsible and a sustainable way. Net zero remains a priority.
We've produced an ambitious strategy, striving for a science-based pathway to net zero in 2050. Our plan to manage and reduce greenhouse gases is our most advanced and comprehensive yet. We'll be working to reduce operational emissions by around 43% in AMP8, mitigating the growth pressure of an increased program. We're committing to providing the best value for money for our customers, too. Our customers rightly want us to spend money wisely and efficiently, so that we can make sure that we keep bills affordable. Bills are expected to increase by around GBP 22 on average every year of AMP8, before inflation. We're also enhancing our affordability support, proposing a material increase during AMP8, with a support package totaling GBP 525 million.
As well as 30,000 jobs supported by the plan, our GBP 13.7 billion proposed TOTEX is expected to deliver more than GBP 35 billion worth of associated economic value for the North West, a huge and much-needed opportunity for this region. This is the largest plan that we will have ever delivered, with the increase substantially all being on our environmental program, driven by changes in legislation. We're stretching ourselves to innovate and optimizing our plan, enabling 14% of efficiencies to be realized through the plan's delivery. The step change in environmental investment means that we expect to see strong RCV growth, the strongest that United Utilities will ever have delivered, with 52% nominal or 37% real across AMP8. I want to take a minute to unpack bills and the impact a little bit further.
Bill affordability is a top priority for our customers, and it's a priority for us, too. Our proposed business plan requires real-term bill increases, an increase of around GBP 22 real on average each year, or 25% over the AMP. Our plan has not utilized any excess fast money to support financability, as this would add unnecessary cost pressure to customer bills at a time when they can least afford it. Now, more than ever, it is critical that we're helping those that may be struggling, and we are determined that no one will be left behind.
We will be doubling our affordability support with a comprehensive package worth GBP 525 million, and that is gonna enable us to support 590,000 customers, or more than one in six, which, more importantly, will also see, make sure that there is no increase in the levels of water poverty despite the increase in the water bill. We are clear that customers don't and won't pay twice. Investment is all linked to new statutory requirements and services. I'd like to hand you over to Phil so we can talk through some of the detail on TOTEX, on growth, and on financing of our plan.
Thanks, Lou, and good morning, everyone. First, let's start with TOTEX. Back in May, we outlined a significant step change in the environmental enhancement in our WINEP submission, which has increased from around GBP 1 billion in each of AMP6 and AMP7 to around GBP 6 billion for AMP8. This slide shows how that combines with other elements of the plan to build the overall TOTEX picture.... In addition to the WINEP expenditure, our TOTEX plan of GBP 13.7 billion pulls together other enhancements in our base TOTEX spend in the water, wastewater, and retail operations. At the heart of our plan is ensuring statutory compliance, with 93% of enhancement driven by statutory requirements. Our plan is both ambitious and stretching. In building our plan, we took a long-term adaptive planning approach, ensuring a low or no regret solution pathway to the requirements.
This was further supported by an independent scrutiny panel to challenge the need, scale, and phasing. We've made use of innovation and optimized solutions, such as value engineering, where we've challenged asset standards and driven lean designs to achieve targeted outcomes at an efficient cost. We've robustly challenged internal costs and engaged with markets to drive further cost savings. All of this means our base TOTEX proposals are within our assessment of efficient model costs, and the efficiency of our plan is supported by benchmarking analysis and third-party assurance. Submission of our plan today is an important milestone in the price review process. This will frame ongoing discussions as we continue to work with regulators and government on opportunities for long-term adaptive pathways to optimize and phase delivery. The aim here is to maximize environmental outcomes while minimizing abortive spend and community disruption.
Now, as already mentioned, this is the largest plan we've ever submitted, driving a step change in environmental outcomes, which will see our RCV increase from GBP 14.8 billion at March 2025 to GBP 22.4 billion at March 2030. This results in record levels of growth, with our PR24 submission seeing RCV growing at a rate of around 9% per annum and over 50% across the AMP. Turning next to investor returns, we know that Ofwat will be updating their WACC assumption for the draft determinations next summer, and given the potential for further changes in the market environment between now and then, we see little merit in taking an alternative approach to applying Ofwat's early view WACC in our base submission.
However, to support Ofwat in their deliberations when updating the WACC, we have set out our view on why we think the early view WACC may not be high enough to attract the capital that is required for the industry in AMP8. You will also see from the table that we asked Frontier Economics to provide an independent assessment, which is available as part of our submission. In engaging with customers in relation to our plan, we achieved 74% acceptability. Recognizing with any increase in the WACC would lead to higher customer bills, we have also tested with customers the acceptability of a higher WACC based on the Frontier Economics 3.9% set out above.
This did not lower the level of support for the plan, which retains 74% customer acceptability, and importantly, we also retained further headroom in the level of customer affordability support that we can make available in a higher bill scenario. In addition to the WACC, there are incentives for high quality and ambitious plans, the quality and ambition assessment, with a standard plan benefiting from a 10 basis point uplift to the cost of equity, while an outstanding plan is worth 30 basis points. Now, Lou and I are really clear. Our plan is both high quality and ambitious, and we believe it's an outstanding plan. We also set out on this slide our P10 and P90 AMP8 ROE range. As you can see, we're proposing incentives broadly in line with the Ofwat proposed range, with notable differences being TotEx and financing.
TOTEX reflects a negative skew due to the ambitious and stretching TOTEX plan that we've submitted, while financing has a negative skew due to a combination of factors, being a significant need for capital, the mismatch of new and embedded debt in the WACC, and the potential recessionary outlook. Now, having talked through the assumptions underpinning the plan submission, we thought it would be helpful to look at a gearing bridge. We approach the plan from a robust position, with one of the lowest gearing levels in the sector at just 58% today. This uniquely positions us to tackle the challenge of delivering and funding our investment program in AMP8 and beyond. What is clear is that we have options and flexibility around funding this capital requirement.
In order to align with the Ofwat methodology, our PR24 submission assumes that the program is funded with equity and debt, with equity sized so that we maintain our current A3, A- credit ratings. Recognizing that Ofwat will be updating our WACC assumption for the draft determinations next summer, we have adopted Ofwat's early view cost of capital in the business plan submission. On this regulatory basis, our PR24 submission assumes notional equity of GBP 1.35 billion out of a total capital requirement of around GBP 5.2 billion. This gives rise to an average gearing across the AMP of 63%. So now to build on that last slide, we thought it would be helpful to provide an alternative lens from which to view our business plan submission, resulting in an alternative gearing bridge.
If the investment program is funded entirely with cash and senior debt, we would expect gearing to average around 65% across the AMP. This is based on our full GBP 13.7 billion TotEx plan, coupled with Ofwat's early view of WACC. This also assumes a continuation of our current dividend policy and no outperformance or rewards. By way of illustration, if the WACC was circa 60 basis points higher, in line with the Frontier Economics 3.9% WACC, we would see gearing levels average around 1.5% lower. If adaptive planning decisions led to a GBP 1 billion deferral of TotEx into AMP9, then that would result in a further 1% reduction on average. The combination of both would see group gearing averaging 63% over the AMP and remaining within our target range of 55%-65%.
So to wrap up, I think it's really important to recognize that we're still at an early stage of what is a relatively long process. And as I've just shown you, what is clear is that we have options and flexibility around funding the capital requirement. So thank you, and I'll now pass back to Lou.
... Thanks, Phil. Turning now to customer ODIs. We've got a strong track record of delivering on common ODIs, and we're proposing to continue to push the frontier on key metrics such as pollution. And we have ambitious plans to drive improved services, and as I've already said, we're backing ourselves to deliver. There have been some changes to the ODI framework for PR24, the most notable shift being the move from common and bespoke ODIs. And you can see from this slide that the weighting has very much shifted towards common ODIs for AMP8, and we're positioned really well. Last year, we delivered the highest percentage of ODI, our ODI outcomes in the sector at 83%.
We have active plans for all ODI measures, with each measure being owned and driven by a member of the executive team, and we've been shadow reporting and optimizing our delivery for the last 12 months. We want to hit the ground running and feel that we're really well-placed against the new common ODI framework. We're submitting a plan, a plan that is financiable, affordable, and most importantly, it's deliverable. Three key lenses of which Ofwat we use to assess our plan. As Phil has said, we've got a strong balance sheet today, with 58% gearing and a credit rating of A3, A-, and looking forward, we have flexibility in financing, with a 65% average gearing over the AMP, based on Ofwat's early view WACC and the current scope, without any recourse to equity. The plan is also affordable.
We're maintaining our industry-leading approach to affordability, with GBP 525 million worth of funding, allowing us to help one in six customers in the region to be supported. Based on the plan's initiatives and support, this would mean there is no increase to water poverty over the AMP. The affordability support is provided by a team who have just been rated as number one WASC for customer service in the latest and independent Institute of Customer Service survey that assesses all brands across the UK. Most importantly, this is a plan that's deliverable, and we've already started delivering. The GBP 1.2 billion worth of early investment has enabled us to start delivery against our storm overflow reduction program already.
We've invested in and are up and running with our in-house CSO, rainwater management and modeling team, and we've increased our delivery partners from 5 to over 50 to underpin our delivery as we move into AMP8. Hopefully, it's been useful to understand the key elements of the plan and the impact on financials, but I thought it would also be helpful to summarize the next steps in the process. This is obviously a submission as opposed to a determination, and as in previous AMPs, there will be a continued discussion and dialogue with all regulators and stakeholders in the weeks and months ahead, as plans are digested and evaluated ahead of the final determination being announced. We understand the importance of the dividend for investors. We know you value our progressive inflation-linked dividend, and we will announce our policy after the final determination in 2025.
Recognizing there's a huge amount to absorb and a lot of detail that we've shared this morning, we've pulled together some of the key facts and the things that we think will be most relevant in your assessment of the plan that we've put forward. We're also gonna be adding an investor summary onto our website this afternoon, and hopefully, that will also help you to evaluate the plan that we've put forward. Before we move to questions, I want to take a minute to summarize why I believe that this is an outstanding plan. I'm not gonna read everything off this slide, but the regional approach that we have taken to building our plan is unique. It delivers the services customers and regulators want, and at the same time, brings real and tangible economic growth to jobs here in the North West.
We've got strong customer support, real and significant solutions to help with affordability, and we've got the financing headroom that means that we have got options. This plan delivers strong year-on-year growth for investors in a way that AMP6 and AMP7 never did, with RCV growing at 52% nominal over AMP8 or an 8.7% CAGR. And at the same time as building the plan, I've been building capability. I have taken the best of the old team and recruited some fantastic new talent, building capability and capacity right through the business at all levels. And it doesn't stop there. We're organizing ourselves into our regional delivery squads, so we're ready to deliver our county-based plans at pace and with purpose. What's important, and I've said it before, we've already started. We're not waiting until AMP8.
The Accelerated Infrastructure Delivery project we secured early in the year has enabled us to get to work on the UK's biggest storm overflow reduction program, working at pace, innovating, and driving to deliver the step change that we all want to see. And lastly, and most importantly, we're committed. We're committed as a team to make a difference, and we're backing ourselves to deliver this plan because it matters. It really matters to customers, to regulators, to shareholders, and it really matters to us, and we're determined to deliver the step change that we all want to see.... So thank you. Thank you for your time this morning. I know it's precious, but Phil and I would really welcome your questions and the chance to discuss the elements of the plan that we've presented this morning. Thank you.
Terrific. Thank you very much, Lou. Thanks, Phil. So, yeah, our first question comes from Martin Young at Investec. He's had his hand up for about an hour, so a lot of enthusiasm there. Over to you, Martin.
Yeah, good morning, to everybody. I guess we're going to be a little bit time limited, so I will limit it to two questions. The first relates to equity. I appreciate what Phil was saying about it being somewhat sort of early in the process, but I did notice from one of the filings that you say that, UUG is expected to be well-placed to fulfill such equity calls from UUW, and is likely to consider one or more of the following sources of capital: an injection of group cash, issuance of debt higher up the group capital structure, or UUG equity issuance, and that it would be for the board of the, the group company to determine the most appropriate way of making equity injections into, to the regulated, business.
Given that you've outlined those three potential routes, and you might tell me there are more, is there a sort of rank order or preference amongst those that we can have a think about at this stage? And then, secondly, on the WACC, you and at least the other business plans that I've seen have presented the plan on the basis of the early view of WACC from Ofwat. Severn Trent's done a mark to market, Pennon has done a mark to market, albeit with a new view on the debt split in AMP8. You've presented the Frontier report, so different ways of looking at it, but everybody kind of suggesting that there should be, yeah, perhaps a little bit more.
How do you feel the industry comes together to present a common view here? And what, if any, mood music have you picked up from Ofwat on the subject of WACC?
Okay. Morning, Martin. Thank you for your questions. Phil, do you want to pick those?
Yeah. Okay. Well, I guess starting with your first question, Martin, on the equity, I think you know, what you read out is pretty much a textbook answer, as you might expect, going into a business plan submission. I think what's important today is to recognize that that is a regulatory submission for water and not the overall group position, and what we've illustrated is the group position. And so it's very clear that there's no need to raise equity, equity in terms of the group position. We've got a very, very robust balance sheet with 58% geared at the whole co level, and probably important to draw out, but our credit ratings are already one notch higher than many of our peer group companies.
Within that position, you know, we've retained outperformance at UUG from the sort of water business in the past. We have a cash buffer at that level of around GBP 600 million, so that's about 4% of RCV today. We don't have any drag from whole co debt from the other activities. As you're all very aware, we also have a very, very robust pension scheme position. You know, we're fully funded on that pension buy-out basis. We've actually completed a sort of pension risk transfer, with two-thirds of the pension risk fully insured now. So effectively, there's lots of sort of positives. That means there's no drag on the group position, effectively.
And as I illustrated in the two slides, I've given you the bookends of the scenarios from a group perspective with gearing, and you can see that, you know, we're looking at 63% on average across the AMP period. So that's the first question. I suppose the second question on WACC and the mark to market, you know, we've included the Frontier WACC assessment. That was at a point in time in April. I think one of the clear dynamics at the moment is the market continues to evolve, and I think, you know, it's gonna be another sort of nine months or so before Ofwat is setting a WACC for the draft determination. And, you know, a lot can change in nine months, as we've seen in the last year or so.
So I think it's really important to see how that process plays through. Of course, what we have done is provide the Frontier Economics report, and we provided a lot of evidence to Ofwat of the sort of things we expect them to consider as part of that process.
Okay. Thank you.
Terrific. Thank you very much, Mr. Young. Over to Pavan Mahbubani at J.P. Morgan. Pavan, go ahead.
Thanks, team, for your presentation and for taking my questions. I'll stick to two as well, please. Can you provide some color around the adaptive planning scenario that you highlighted in your slides and some context around that? Are there some projects that you think Ofwat is going to remove from your plan, or things that you don't see as necessarily being statutory obligations? I mean, just to get some color around what's in there and why you flagged it would be helpful, please. And my second question around feedback from your customers, and I guess more widely, feedback in the north and northwest. Have you spoken to any policymakers on your proposal ahead of publishing your plan, and can you share any feedback that they have on that as well, please? Thank you.
Great. Good morning, Pav. I'll pick up both of those questions. So in relation to scope deferral, the reason that we've highlighted that. Perhaps just to give you some color as to some of the things that sit in there. So, for example, there's GBP 200 million in the plan for HS2. None of us know as we sit here today, what's going to happen in relation to HS2. But it's a really great example of some of the things that we're including in the plan that actually, as a result of policy changes more broadly, may look slightly different. We've also got investment in there for nutrient neutrality, carbon and net zero ambitions, and there's also a really great case study on Davyhulme that I would really sort of encourage you to have a look at.
Davyhulme is a real great example, if you like, of what we mean by adaptive planning. So essentially, we could do things in AMP eight and then move some of the scope to AMP nine when other environmental drivers come along. And the benefit of doing that, Pav, is twofold. One is it actually reduces any abortive spend that may be realized as a result of then having to do additional projects in AMP nine, but it also limits customer disruption as well. So when we talk about adaptive planning, that's what we mean. We're trying to make sure that we invest once and we get the greatest level of return for customers. So hopefully, that's just provided a little bit of color as to some of those items around scope.
Your question around support in relation to the plan, I think, you know, we've said we've got 74% customer advocacy for the plan and 95,000 customers we've engaged with. But what I think is really unique about this plan, is the approach that we've taken to the 5 counties, has allowed us to build a plan for Cumbria, a plan for Merseyside, et cetera. And each of those plans contains very, very different elements, because each of those communities and environments is different. The other real benefit is it allowed us to engage with MPs, local authorities, and politicians.
And alongside our plan, we've got great support that's gone into the plan itself from Andy Burnham and the combined authority of Manchester and Steve Rotheram over in Liverpool, who are real advocates of the plan and what we're proposing to do, 'cause they can see the benefit that that's gonna have in terms of regional infrastructure, but also in terms of jobs. So that county-based approach, that we think is unique, is a real game changer in helping us really articulate the benefit and gain support for what we're putting forward this morning.
Thank you.
Next up, we have Mr. Nash from Barclays. Dom, please go ahead.
Hi, can you, can you hear me okay?
We can, Dominic.
We can, Dom.
Oh, great.
We can't see you. We'd love to see your face.
All right, I'll see what I can do just for this. Okay.
Go, go ahead. Go ahead.
Right. Okay. Two questions for me, please. Firstly, the difference between enhancement and baseline spend. There we go. Okay, the base complete now. Ofwat's basically saying that consumers shouldn't be paying for the sins of the past. And your baseline expenditure historically should be sort of meeting the targets at the time with an underlying efficiency number. How do you think they're gonna look at your business plan here? And is there a risk that they will shovel some of your enhancement TOTEX into a baseline number, which means it's basically being paid for by shareholders rather than consumers, and how comfortable are you that catching up is within this plan? And secondly, can I just come back to the gearing levels.
Can you just confirm again, when you quote gearing level, that will be a group debt to RAB, or will that be at the water level to RAB? I presume that you'll be running the water debt at the sort of statutory 55% going forward, but you might well be quoting a group debt, or will you be coming up with two sets of numbers? Thank you.
Thanks, Dominic, and it's lovely to see you this morning. We will, I'll probably take the first one, and I'll ask, I'll ask Phil to lead on the second. In relation to the plan, we've been working really hard to make sure that the plan that we put in is an efficient plan and is very much within Ofwat's econometric models for where they, you know, are going to be running the models in relation to their view of efficiency. So I think that's the first, first really important point. And secondly, I think we said earlier in the presentation, we've assumed a 13% efficiency, and that's coming through various different initiatives and activities that are already up and running.
You know, much greater focus on driving towards, you know, value engineering and making sure that we're delivering scope and doing that efficiently. We're also working really hard in relation to supply chain management and greater levels of automation. So we have a number of initiatives that are running through our plan to ensure that when Ofwat assess our cost base, they review it as being efficient. Your point about our customers paying twice, I think is a really important one, and we're really clear that what we've put forward all links to the new environmental legislation that was passed. This is not customers being asked to pay twice. This is as a result of us needing to increase and invest in infrastructure to cope with that hydraulic incapacity that we see here in the North West, and alignment against those new standards.
We're very clear, and always have been, that this isn't asking customers to pay twice. I think that as we go out and we communicate the plan and communicate the bill impacts more broadly, it's a really important point for us all to all to focus on. Phil?
Morning, Dominic. On the gearing levels, firstly, the slides should hopefully be clear, but it is a group debt to RCV. I know, sometimes it's not always transparent, but we're always very clear on what we're talking about, so it should be clear that it's group debt to RCV gearing for the slides. In the context of the statutory 55% at water, that's the notional company for the Ofwat assumptions. Obviously, our plan submits a notional and actual position for UU Water, and we're running gearing there, more like 63% effectively. So, that's the difference in terms of the numbers.
The sort of key point here is the point I made earlier, which is that there's GBP 600 million or so of cash at the group level outside the water company. So the group gearing is actually lower than the water company gearing in the position today.
... Does that, sorry, just to follow up on that, does that not mean that there's a tax drag issue, in that the regulator allows your cash tax to pass through? If you've got higher leverage than the 55%, you'll end up paying less tax.
We'll be paying very little tax, given the scale and size of our capital program in the next AMP, Dominic, in the context of all the capital allowances. So, it's a bit more of a moot point, really.
Okay, great. Thank you.
Thanks, Dominic.
Terrific. Thank you, Dom. James, I think you've had your hand up for an eon, and you keep getting bumped out of the queue. So, James Brand, over to you, sir.
Oh, hi, good morning. I'll stick with the kind of two questions as well. So firstly, there seems to be a perception out there that common ODIs are a lot harder to outperform on than bespoke. And obviously that's, you know, we're moving to a regulatory review, where there's gonna be a lot more commons. And I see you still have a ±2% targeted range on ODIs. So just wondering whether you agree with that general sentiment, that it's harder to outperform on the common ones, and how you're placed? And then secondly, I personally think your Frontier Economics cost of equity proposal is pretty close to reality or maybe even a little bit low.
Do you think the Ofwat's coming around at all to the arguments that many people have made, that the proposed return on equity is too low?
Thanks, James. So I suppose in terms of picking up on the first point around common ODIs, I think, you know, and we all saw it last week, didn't we? When Ofwat put the data out in terms of the APR tables. There is a big difference across the sector in terms of the performance. You know, we perform well on common ODIs. I think one of the key things that, you know, is always an issue when you look at any sort of ODI set, is the impact of variables such as weather and those types of factors, but we perform well. We perform well on that common set and always have done.
I think what is also important is that we have got a series of activities that are run in terms of that shadow reporting. So looking at that common set with an executive owner for each of those ODIs, so that we can make sure that we hit the ground running when we start the AMP, and we've already started shadow reporting, so we can understand our performance against them. I think there is obviously lots of conversations happening right across the sector in terms of the reward and penalty balance, and I'm sure that will continue to continue to play through. But as you saw last week, there's only three companies that are actually performing. We're one of them, and we're doing well.
In relation to cost of equity, I think, you know, we have seen some movement in terms of language around cost of equity, particularly in terms of the updating the position. I think, you know, Ofwat have sort of started to talk about that a little bit themselves in relation to some of their communications with shareholders and analysts. But I'll let Phil pick up on that more broadly.
Yeah, I mean, the points you make, James, are the points that investors make to us regularly. I think we felt it was important to provide that independent assessment of WACC, for Ofwat to get a sort of broader perspective of the views that are out there. And we know that investors are also very engaged in talking to Ofwat on this subject as well. So you know, we-- from our perspective, you know, we believe Ofwat clearly understands, we recognize the issues, and, you know, we also recognize the importance of the decision that they will have to make when they come to set the draft determination WACC, come next summer. But I think, we've done all we can to sort of help them understand where the market is at this point in time.
Great. Thank you very much.
Thanks, James.
Okay, terrific. Next up, we have Bartek from SocGen. Bartek, go ahead.
Hello, and good morning. Two questions from my side. Firstly, if we can compare the TOTEX number for AMP8 with the TOTEX number for AMP7 on the same basis, i.e., real terms of 2020 to 2023 prices, what's the increase in AMP8 TOTEX? And secondly, you've been talking about investments, but I also wonder how did you approach OpEx modeling for AMP8, and especially those cost components which had overshoot over AMP7, particularly electricity prices. And I just wonder how Ofwat is going to approach, for instance, the power costs in AMP8, and whether there could be quite a significant discrepancy versus what you are presenting in your plan versus what Ofwat may think about power costs in AMP8. Thank you.
Thanks, Bartek. Do you want to pick those up, Phil?
Yeah. So, Bartek, slide sort of 8, what we talked through in the presentation includes the numbers you're looking for in terms of the TOTEX position. Those are all in FY 2023 prices, so they're all comparable in terms of the numbers and the scale and sizing. So that deals with the first question. In terms of the OpEx modeling, you're right, it is incredibly important, not least because on things like power, we were extremely well hedged ahead of the Ukraine challenges, and so we benefited from that hedging in terms of our base costs. And so we've been really, really clear in our submission around how that will flow through moving forward.
you know, 'cause that's very different to other organizations who may not have been as well hedged, and therefore would have higher costs, but you'd expect to step down. So all of that is very clearly articulated in our plan. As I say, we've put forward our view around the efficient model cost and how we compare to that, and, and sort of, you know, I think that's all pretty well contained in chapter eight.
If I may move to specifics. For instance, for power costs, what do you assume for AMP8? Do you take historical costs? Do you take forward costs? Do you take some estimates for power costs? I mean, they are right now around 20% of your cost base, so I think this is critical to understand.
... Yeah, so it is a critical point because of the, and it's a critical point because of the baseline from which you measure that is really important as well, as I say. So, we've used forward costs in terms of our assumption of the market rates and how that compares, and it's really important to sort of position that against the right start point, because, as I say, you know, power costs today are less than they were 12 months ago, but our costs were obviously insulated 12 months ago because we were very, very highly hedged. So that's a really key point, and that's sort of teased out in the submission.
Okay. Thank you.
Thank you.
Okay. Over to Ahmed, please, go ahead.
Yes, hi. Thank you. Thank you for taking my questions. Two from my side. I just was gonna ask you more about a little bit more about the deliverability of the plan, in the sense that it's a huge step up in the expenditure, and not, it's just not you, the whole industry is trying to scale up at the same time. I wanted to sort of, sort of get your thoughts on how you thought about actually the sort of the execution, deliverability, supply, supply side challenges and actually cost inflation that might come through with this. So that's number one. I think you said earlier, you know, we will announce the dividend policy, sorry, in 25. But I'm just wondering whether there's anything we should read across from the base dividend assumptions in the business plan for the actual dividend policy. Thank you.
Thank you, Ahmed. I'll, I'll pick up the first one, and I'll ask Phil to pick up on, on dividend. Deliverability is key. You know, it's gonna be one of the key tests that Ofwat are gonna apply to our plan, but it's where we've been really focusing our attention. So the fact that we were able to secure that accelerated infrastructure program in relation to CSOs has allowed us to get to work already on a third of the CSO program. So this isn't like we're, we're suddenly doing a huge ramp up. We've already started, essentially, that, that increase and that, and that incline in relation to, to delivering the additional TotEx.
As I said, I've also strengthened the team, so I've brought in a number of new talent and new capability, particularly in the space of commercial engineering and capital delivery. And then, when I talk about the county delivery, it's really important because at the heart of this is gonna be going in and out of local authorities and getting planning permissions. By organizing ourselves into that county-based model, I've also put stakeholder managers in there. So we're already talking to those local authorities now, about what planning applications they're gonna be having, when they can expect them. We're starting to do that consultation now, and I think that's really, really important because we, as we know, a lot of these programs can sometimes falter because of the sort of time that it takes to go through the relevant planning processes.
And then, when you also look at the way that we are organizing our capital delivery, both in terms of the design but also the execution, we're very clear in terms of how we're essentially aligning what we've called different runways and pathways. So we're clear about the size and the scope of the project, which supply chain partner we're going to be working with. And again, all of that has already happened. So essentially, you know, the fact that we've had that accelerated infrastructure investment has meant we're already doing this now. I'll hand you over to Phil in relation to dividend.
Thank you. So you're quite right, Ahmed. The UUG dividend policy is very independent of the water business plan submission. So I think that's the first point. It's really important to recognize that we've submitted today our PR24 regulatory submission for the water company, and that's very different to the group position. Just picking up on the water company dividend policy though, and expanding a little bit further, the dividend policy we've adopted is 1% less than the cost of equity. So it's not 3%, it's 1% less than the cost of equity. And as James Brand sort of helpfully reminded us all, you know, that cost of equity is likely to increase quite markedly. So that does provide further sort of upside in terms of the water dividend policy.
In addition, effectively, the plan doesn't assume any RoRE outperformance. It doesn't assume any quality and ambition assessment reward that we expect to pick up in the process. And that's why, sort of, when I've sort of done the modeling and we've sort of shown you the bridging, we've shown you the sort of group position on a net debt to sort of RCV basis, and you can see therefore, the sort of security of a dividend position articulated through that group bridge effectively. So, that's how I'm sort of seeing the position.
Thank you.
Okay. Thank you, Ahmed. Dom, Dom Nash, we, a follow-up question. Please go ahead.
Hi there. Yes, actually, it is a follow-up question on Ahmed's response there. I've got two questions actually, but the first one on the follow-up. You say that you haven't put any RoRE outperformance into your business plan today, but how have you treated financing outperformance, when what cost of debt versus your actual cost of debt expectations? I mean, I presume that that is caught up in your financing, sort of, debt to positions. And secondly, something that kind of interests me, you see you got 900,000 smart meters coming your way? What's the consumer acceptability of having smart meters installed in water, and when do you think you'll be in a position to start coming up with some innovative tariffs? Thank you.
Thanks, Dom. Do you wanna pick the first-
Yeah.
Next one?
Just quickly on the first one. So our business plan, you know, does reflect the actual cost of debt in the UU Water position against the WACC allowance, so that's in the baseline. And then the RoRE position moves on from there, and, you know, as I said in the sort of presentation, we see the RoRE position. There's a few things in the financing that we expect will put sort of also be picked up as we look at the draft determination WACC. So things like the split of debt between new and embedded, for example, Dom, I think the 17% assumption, clearly these business plans and ours in particular is significantly larger, so therefore, there is new debt coming into the plan above that sort of level.
All of that we would expect to play through in any reevaluation of the WACC next summer.
... In relation to smart meters, Dom, there's two elements of that. One is, essentially, we are proposing that we replace all commercial premises who currently have, you know, pretty basic dumb meters with smart meters. We see that as being key. A third of the consumption, real opportunity there in terms of driving efficiency, but also making sure that we're managing voids and water usage, particularly in that non-household market, where they have a higher propensity to churn and move around. So that's key. And in relation to domestic customers, one of the things that we have been doing that's worked really, really well, and it's one of the examples that sits in the business plan, is essentially something called our Lowest Bill Guarantee, where we've been essentially shadow metering.
So going down the street, as part of the work that we're doing on rehab and lead, a combined activity, so we can install meters and then essentially work with customers to convert them onto, to a lower bill. Because you're absolutely right, the smart metering capability then starts to enable much greater levels of tariff innovation, particularly in things like rising block tariffs, as a way of incentivizing lower water consumption. So one of the things that the Lowest Bill Guarantee has really helped us with is to remove that sort of fear and anxiety people initially have to meters. So it's those two combined things that we think are really critical, both in terms of enabling lower bills, but also helping us manage leakage and per capita consumption, both key elements of the plan.
Thank you.
Thank you.
Okay. I think that draws our Q&A session to a close. Lou, Phil, back to you.
Listen, I'd just like to say thank you so much. I know it's a busy morning as you're trying to evaluate everybody's plans, so thank you so much for joining us. I'd just like to reiterate, you know, my thanks to the team for pulling what is a fantastic plan together. There's been so much hard work that's been put into this plan. And more importantly, we're delivering the things that really, really matter to customers, to regulators, and I think to you as shareholders, too. Real significant growth, the likes of which we've never delivered before, and we're really, really hungry and keen to deliver against it. So thank you. Thank you for your time this morning, and no doubt we will engage further on the various different meetings and roadshows we've got planned. Thank you.
Thank you, everyone.