News

19 October 2023

Ombudsman Diana Kovacheva sent an opinion to the Chairman of the Energy and Water Regulatory Commission (EWRC) Ass. Prof. Ivan Ivanov regarding the public debate on the draft amendment to the Guidelines on the pricing of water supply and sewerage services by the method of 'price cap' for the 2022-2026 regulatory period.

Prof. Kovacheva is adamant that when determining the social affordability for the relevant year, only reliable data of the National Statistical Institute (NSI) for the respective year should be used.

“During the public discussion of the Guidelines on the pricing of water supply and sewerage services using the 'price cap' method for the 2022-2026 regulatory period, in April 2021, I emphasised that the problem with the high maximum error in the 'Household budget monitoring' survey should be addressed, and urged the EWRC to take the necessary measures”, the Ombudsman writes. 

Diana Kovacheva refers to the NSI letter outgoing No. 07-04-1172#2/09.10.2023, addressed to the EWRC and the Ombudsman, which notes that the NSI defines as reluctance by the regulator to take into account their comments and opinions on changes in the relevant legal documents as a source of information on household incomes when determining the social affordability of the cost of water supply and sewerage services.

 “The proposed texts on points 52.2.2, 52.3.2, 52.4.2: In the event that no data is provided on the average monthly disposable income of a person from a household by area in the “Monitoring of household budgets” survey, the Commission uses data on the social affordability of water supply service prices from the approved business plans for 2024, 2025 and 2026 respectively, should be dropped,” Prof. Kovacheva points out.

She emphasizes that the calculation of the social affordability therefore starts on the basis of the average monthly disposable income per household from the NSI statistical survey for 2020. She adds that based on the publicly available information provided by the NSI on 2020, the data on 23 regions has a maximum stochastic error of more than 10%. These are the regions of Vidin, Vratsa, Lovetch, Montana, Gabrovo, Razgrad, Ruse, Silistra, Varna, Dobrich, Targovishte, Shumen, Sliven, Stara Zagora, Yambol, Blagoevgrad, Kyustendil, Kardzhali, Pazardzhik, Smolyan, Haskovo, Plovdiv and Pernik.

She also points out that the determination of the average monthly household income in the region concerned is a statistical activity which, under the Statistics Act, is carried out by the NSI, therefore the regulator should only use data provided by the National Statistical Institute.

The Ombudsman adds that the text on point 52.2.2 is not in accordance with the updated data on the total average household income from the "Monitoring household budgets" survey for each region from 2017 to 2022, conducted on 9 October 2023, with maximum stochastic error being added.

She also draws attention to the fact that the NSI has published data on 2022, from which it is clear that the maximum stochastic error in 18 regions is over 10%, which, according to the NSI, makes the data unreliable. These are the regions of Montana, Veliko Tarnovo, Ruse, Gabrovo, Pazardzhik, Stara Zagora, Lovech, Targovishte, Razgrad, Silistra, Vratsa, Yambol, Smolyan, Dobrich, Kardzali, Kyustendil, Pernik, Shumen.