Ms Emma Kennedy:

I will address a few of the outstanding points, including the one on 57% versus 37%. On radio yesterday, Mr. Grant conceded that the 37% figure did not include a single drop of customer-side leakage. Customer-side leakage cannot possibly be 5%. The results of the first fix scheme show us that. Members can read the results for themselves. Customer-side leakage is one of three areas and it is impossible that it only accounts for 5%. It is almost certainly at least 19%. That is where the 57% figure originates. According to Irish Water's data, leakage in the UK is 20% on average, so comparing that with our 57% is like comparing apples and pears. UK leakage is reported on a total basis and includes losses from customers' supply pipes. To compare total losses in the UK to partial losses in Dublin is inappropriate and misleading.

A question was asked about headroom. At the time of the 2015 Project Need report on Irish Water's data, headroom was placed at above 15%. Anyone can read that data, which I can break down for people. The analysis of the Shannon project points to a future peak of 12%. On the radio yesterday and as reported today, the figures were given as 12% and 13% for peaking and headroom, respectively. Those numbers are wrong. In the analysis, they are 15% and 20%. I quickly checked on my calculator, as the other figures were clearly wrong. The 12% and 13% are a calculation of total distribution input, but that is not how Irish Water calculates headroom and peaking or how it is done internationally. Net worth leakage has to be deducted. As such, the figures are actually 15% and 20% of accounted for water. Irish Water's analysis factors in the fact that 35% must be made available every single day of the year over and above average demand. That is the headroom. Our analysis adopts the same requirement.

An Bord Pleanála is constantly referred to as an option for an independent review. It is our understanding that our case cannot be considered by An Bord Pleanála. The board has a limited remit over what matters it can consider - planning and environmental issues and regional development. No part of our case relates to any of those responsibilities. For it to get a fair hearing, An Bord Pleanála would not be valid.

Regarding water ingress, the implication is that there are only outages when there is insufficient water. We know that that is not the case. As shown during Storm Emma, outages are caused by pipes breaking. Water ingress is not limited to a situation in which there is not enough water to enter a property. Outages happen because cast iron pipes burst and they are 140 years old when their life expectancy is 80 to 100 years. Perhaps there are exceptions in some parts of Ireland, but this is the main cause of Dublin's outages and the water ingress.