"As a defender of the rights and interests of citizens, I make a recommendation - the price of the water supply service provided by VK Smolyan, VK Ruse, VK Yambol, VK Stara Zagora, VK Pleven, VK Varna, VK Montana, VK Veliko Tarnovo, VK Silistra, VK Vratsa, Waterworks Targovishte, Waterworks Plovdiv and Waterworks Gabrovo should not be promoted".

This opinion was sent by the ombudsman Diana Kovacheva to the Commission for Energy and Water Regulation (KEVR) on the occasion of the public discussion on the amendment of the approved prices of water supply services for 2023. 

Prof. Kovacheva was categorical that the increase in prices is in violation of the principles by which KEVR should be guided by law, namely - ensuring conditions for providing universal access to water and sanitation services, protecting the interests of consumers, the economic justification of prices of water and taking into account the needs of users who, due to geographical, terrain or other reasons, are in a disadvantaged position.

They propose an increase of over 50 cents per cubic meter of water in Ruse

According to her, it is becoming more and more impossible for citizens to repay the increasing water bills in the conditions of crises (economic, political, financial, post-covid) and with huge inflation - the annual inflation for October 2022 compared to October 2021 is 17.6% .

"Unfortunately, KEVR did not take into account the arguments expressed by the ombudsman and increased the prices of the services of nineteen water and sanitation operators.

The average increase in the complex water supply service for 2022 compared to 2021 is 36%," the ombudsman emphasizes.

Diana Kovacheva

Diana Kovacheva was born in Sofia in 1975. She graduated in law from Sofia University "St. Kliment draws attention to the fact that for 13 of the 19 regions of the country, whose water supply operators have approved business plans for the regulatory period 2022 - 2026, the prices of plumbing services in 2023 are increasing.

It indicates that in the Smolyan region, where the price of the water supply service is currently in fourth place in the country, the largest increase (24%) is planned compared to the established prices for 2022. Thus, from January 1 next year, the residents of Smolyan and the region will be forced to pay as much as 68% more expensive water supply service compared to the beginning of 2022.

"The citizens of Omurtag have repeatedly protested the extremely heavy water supply regime introduced for years.

Next year, they will have to pay 3% more expensive water than the established price for 2022 and 4% more expensive service compared to the price for 2021, although the problems with the quality of service are not being resolved." emphasizes Prof. Kovacheva.

She draws attention to the fact that the implementation of the quality indicators "total water losses in the water supply systems" are not taken into account by the Regulator when changing the price of the water supply service for 2023. 

"I appreciate that KEVR's actions are in accordance with the legal regulations, but over the years I have repeatedly emphasized that water losses in the water supply network are one of the main reasons for the transition to the water regime in hundreds of settlements in the country," the public defender points out.

Prof. Kovacheva also adds that from the KEVR's Comparative Analysis of the Water Supply Sector for 2021, according to which for 16 of the 19 water supply operators with approved business plans for the current regulatory period, the KEVR's assessment of the "total water losses" indicator is a "total default". 

"In the regions of Montana, Yambol, Razgrad, Targovishte, Varna, Pleven and Vratsa, total water losses exceed 60%.

Consumers have suffered.

Their demand is justified - that the price be reduced when water supply operators allow high water losses", Kovacheva is categorical.

She also emphasized the fact that in April 2021, KEVR adopted Guidelines for the regulatory period 2022-2026, according to which the quality indicator - "total water losses in the water supply system" was determined by the Commission as an indicator for efficiency, but it will apply to the change in the prices of the water supply service after the third year of the regulatory period and only in the first year of the next one. 

"Until then, however, citizens will pay a price for a service that does not correspond to its quality of provision, which is not fair," argued the ombudsman.

In her opinion, Kovacheva also draws attention to the social affordability of the price of water for 2023 and points out that KEVR has not published the data used for its calculation - average monthly monetary income per person in the household by region for 2021 from the study "Monitoring of household budgets'. 

"From the Report of the working group it is clear that these data were provided by the National Statistical Institute (NSI) with the condition that when they are published, the values ​​of the maximum error for each area will be indicated.

This is imperative, given the fact that these data are unreliable," adds the public defender.

It also emphasizes that when determining social affordability, which plays a major role in guaranteeing the ability of citizens to repay their water obligations, proven reliable data must be used.

"Very close to social affordability are the prices of water supply services for 2023 of: "Water Supply-Danube" EOOD (price including VAT - BGN 5,191, with social affordability including VAT - BGN 5,384), "Water Supply" OOD, Silistra (price with VAT – BGN 5,284, with social affordability with VAT – BGN 5,545), “ViK” JSC, city of Lovech (price with VAT – 4,002 BGN, with social affordability with VAT – BGN 4,232), writes the ombudsman with the conclusion that the price of the water supply service for these companies can actually exceed the threshold of social tolerance, which is unacceptable.

The ombudsman also sent KEVR a negative opinion on the price proposal of Kardzhali Waterworks, according to which consumers will be forced in 2023 to pay a 45% more expensive waterworks service compared to the price for 2021, applied in 2022 as well, i.e. is.

from BGN 2,648 (including VAT) to BGN 3,847 (including VAT).

The proposed approval price for 2026 is as much as 86% higher than last year.

- from BGN 2,648 (including VAT) to BGN 4,927 (including VAT).  

"The business plan and price proposal of "ViK" OOD, Kardzhali for the regulatory period 2022-2026 are considered by KEVR in the last month of the first year of the specified period.

Thus, on December 6, 2022, KEVR held a public hearing to approve the prices of water and sanitation services for the Kardzhali region for 2023, 2024, 2025 and 2026, amend and approve the price for 2023. This is a precedent in the practice of KEVR.

In practice, the regulatory period for the Kardzhali Waterworks, instead of 5, includes 4 years, which is contrary to the regulations," the ombudsman points out.

Prof. Kovacheva once again emphasizes that the significant increase in the price of water in Kardzhali and the region over the years is unacceptable in view of the unsatisfactory quality of the service provided.

Diana Kovacheva