In the second part of his comment on water quality management,
Peter Matthews of The Worshipful Company of Water Conservators, discusses strategic issues and practical examples of change which can bring immediate benefits.
In the September issue of WIJ, we made extensive responses to government consultations underpinned by Position Statements, and set out some general principles:
- A more ‘connected approach’ is needed for initiatives, including a ‘road map’ and overarching strategy
- To meet many of the aspirations for a better water environment, it can’t all be left to the water companies. They must provide excellence in operational delivery but changing societal practices is not their sole responsibility. There must be a greater role for Citizen Science coupled with Citizen Delivery.
To meet aspiration, practical experience needs to be blended with academic insight and innovation. An understanding of societal psychology is also required (anything to do with sewage is dominated by the ‘faecal aversion barrier’, an essential part of public health hygiene).
Relatively straightforward practical policy changes could include:
- Removing the automatic right to connect to the public sewer network
- Making water companies a statutory consultee in planning processes
- Tighter product regulation and customer information on packaging to reduce sewer blockages and reduce water consumption
- New developments should have a legal requirement to deliver SUDS (with exemptions in prescribed conditions)
- Improve the processes for dealing with disruption to roads and access when water infrastructure is being put in place or repaired.
As mentioned in September’s article, a broader approach generates innovative thinking. For example, the Consultation on Environmental Targets proposes that phosphorus loadings from treated wastewater are reduced by 80% by 2037 (against a 2020 baseline).
Defra wants water companies to explore innovative, nature-based, and catchment-based approaches. The Consultation also set demanding targets for agriculture.
But as an example of the ‘jigsaw approach’, the government issued further instructions on 20 July 2022 requiring treatment of sewage discharges in nutrient neutrality areas to be upgraded to the highest technically achievable limits by 2030. The statutory duty to do this will be incorporated into forthcoming Levelling Up and Regeneration legislation.
Nutrient neutrality is already causing debate about delayed housing development; and fuller sewage treatment is promoted as a major solution. These are still end of pipe solutions.
We have suggested that reducing phosphate in diets could be one way to help achieve targets. Half is added artificially and the NHS already issues advice on reduction for patients with renal problems.
The government also wants to reduce water demand long term (see the consultation on Environmental Targets), but consumers will have to play a role in dealing with water leaks. The complexity of delivering this is already defined in Ofwat’s consumption targets (but not yet Defra’s) and leakage management has gone well beyond the old ‘watershed’ of economic levels.
A return to river quality objectives is needed to achieve local delivery using a set of national principles. We need an overarching National River Strategy based on existing Basin and Catchment Plans, which should include quality criteria for recognisable uses, with public consultations on uses within defined stretches of rivers.
This could then be combined into a quality specification for each stretch to decide:
- discharge consents (including separated surface waters)
- river flow regimes, using models such as SIMCAT, under the future Regulations of the Environment Act.
Getting this right will be essential for a robust regulatory framework, including Ofwat’s role.
Including nutrient neutrality could create a very different programme for overall phosphate reduction. By linking to 25-year Environment Plan targets and other environmental initiatives, integrated decisions can be made to best manage the phosphate cycle, whilst recognising that phosphate is an increasingly scarce resource.
We believe the designation of bathing waters should be part of this strategy, but also part of a wider consultation. Expectations may be raised which can’t be delivered in practice and won’t be the best course of action within the context of storm overflows – a major, but not sole, factor in healthy bathing waters.
We back a review of national committees, even a revival of Royal Commissions. The impact of demographic change on the environment should also be revisited as it overshadows issues addressed in the consultations.
The Environment Act provides an excellent framework, but the Environment Plan has lost its focus. An overarching water strategy is needed urgently which sits within, or informs, the Plan, so that water targets fit together better.
