A more integrated approach is needed with upstream source control to supplement the current drive for end of pipe solutions in sewage management, says Peter Matthews of The Worshipful Company of Water Conservators.
Those of us who have been in the industry for a long time, see more interest in water management than at any time since 1989. This year has seen a stream (no pun intended!) of inquiries and investigations, starting with the House of Commons Environment Audit Committee Report on river quality.
Defra has also issued a series of consultations on aspects such as:
a proposed ban on single use plastics in wet wipes (see WIJ – March 2022 for my comment on that)
proposals for the future of storm overflows
reductions in water demand and phosphate in sewage effluent.
Following on from a general debate about river quality, the House of Lords is carrying out an inquiry into Ofwat’s powers, with a specific focus on storm overflows, while the Office of Environment Protection is investigating how regulations introduced by Defra, the EA, and Ofwat have impacted storm overflows on rivers. Plus, of course, Ofwat published its draft PR24 methodology in July.
The Company* has made extensive responses, underpinned by Position Statements, on a number of themes.
We support the need for the evolution of water management to protect the environment and meet public expectations, whilst also responding to factors such as the pressures arising from climate change and a growing population. We are also mindful this is an additional cost to customers at a time of economic hardship. The Company recognises that some of the views expressed in the wider media might distort understanding of what needs to be done.
However, we have reservations about how proposals will be implemented. There is a need for a ‘road map’ to explain how current and future initiatives relate to each other. Currently, it is a collection of seemingly ad hoc proposals which need integration with other initiatives and policies.
For example, targets for phosphate in, and abstraction of, river waters are dealt with in the consultation on 25 Year Environment Plan Targets, while sewer blockages (a major cause of sewer overflows) are dealt with in the drive to reduce single use plastics. Sewer overflows are dealt with separately, but the consultation contains a significant narrative about swimming in inland waters which are influenced by many other factors.
We believe that the later Defra proposals need a more refined approach to set operational and investment targets, along with better cost benefit appraisal. The current proposed targets are simplistic, blunt instruments and there must be a more integrated local approach (such as at the river basin level) using national principles rather than national targets. Plus we need a greater understanding of practical issues around delivery.
Part of this should be a shift towards outcome-based environmental regulation. Rather than specifying the outputs that water companies must deliver, it should specify necessary outcomes. This would include all sectors contributing to the problems (agriculture, industry, developers) who would work with the water sector to find best-value solutions, stimulate innovation and increase nature-based solutions.
These issues can’t be looked at in isolation. The interplay between economic and environmental regulation and Government policy should be assessed at the very least. The key challenge facing Ofwat and the whole sector is delivering improvements in environmental quality and resilience to drought and flood without creating an unaffordable bill burden. Current approaches will not achieve this.
Colin Drummond, Master of The Water Conservators, believes regulators and water and sewerage companies are reaching the limit of what they can do on their own, based on the government’s developing aspirations.
He says: “The utilities have much to do to reach their targets, but a lot also depends on society’s behaviour (e.g., what is flushed down toilets) and on what people want from our rivers and lakes in terms of recreation. There should be a national government-led approach. We can no longer rely solely on environmental regulators, Ofwat and the Price Review process.”
The government should also review its proposed Environment Act targets, which would work against the outcome-based approach. For example, the proposed target for phosphorus reduction focuses only on ‘treated wastewater’, ignoring the impact of agriculture, industry and CSO overflows.
Current targets will drive expenditure and focus by water companies as an ‘end of pipe’ issue rather than examine the root cause, at great cost and with limited benefit to river health. Instead, wording that emphasises ‘Good Ecological Status’ in rivers would drive all sectors to deliver the desired outcome.
The second part of this article goes into more detail. Some of our ideas may be too late for PR24 but they may be of some value in AMP8, and there is time to consider them for PR29. Five years is a long time and much can happen in that period.
See our December issue for part two of this discussion on the future of UK water management.
*The Worshipful Company of Water Conservators is the City of London Livery Company focused on the long-term health of our water resources and the broader environment. Members include active and retired professionals from water, environmental and related industries, academics and regulators, along with others with an interest in water and the environment.
