General

We welcome the thorough inquiry by the House of Lords Science and Technology Committee and support most of the recommendations. The report rightly places responsibilities on all parties involved in the water sector, including Government, the water industry and stakeholders. It recognises the need for a multi-faceted approach including water supply enhancement, where appropriate, and increased attention to demand management through, for example, building regulations, metering and water efficiency.

Detailed responses to each of the recommendations laid out in the report are presented below. In each case the response references to the numbered paragraph in Chapter 8 of the main report.

In the text below reference to the House of Lords Science and Technology Committee is made in the abbreviated form as HoL.

Background

The HoL has identified what Water UK agrees is a central challenge for the sector to ensure sustainable water management in the future. This is the challenge of achieving a more integrated approach, in the context of a sector where, as the HoL notes, roles and responsibilities are presently dispersed, where some responsibilities remain unclear and where there may be some tension between the objectives of various stakeholders.

For instance, in the area of diffuse pollution—a major factor affecting the quality of raw water resources—roles and responsibilities are very unclear, both in terms of who regulates and who delivers. Similarly on the question of affordability and the protection of low-income customers, there remains a lack of clarity, less still agreement, as to where the responsibility lies.

Water UK has long called for more "joined up regulation" and more recently has emphasised the need for "greater co-ordination and consistency" between stakeholders.[9]

It is a theme that was also highlighted by the Baker review into Ofwat's 2004/5 price review process. Water UK believes that this must be addressed as a priority ahead of the next 2009/10 price review. In this context, our particular concern is that uncertainty about what is required of companies does not raise the cost of finance or compromise the delivery of effective water resource programmes.

Water UK believes that roles, responsibilities and actions must in future be integrated around the common theme of sustainability. On this point, the HoL notes that whilst "delivering sustainable water systems is a goal to which all those concerned subscribe", "at present neither the water industry nor the regulators have an agreed methodology to include sustainability within the processes of water management." Water UK, which has pioneered the development of sustainable development indicators for the water sector, looks forward to working with other stakeholders to develop clarity within this area, and we have welcomed Ofwat's consultation on how to interpret its duty to sustainable development.

We would look to the MOUs to be developed by regulators under the Water Act to provide some clarity about how regulators will work consistently together in future under this Sustainable Development banner. However, this inevitably will be at high level.

In a practical sense we believe that there needs to be more working in partnership on long-term planning. We also believe that agreement on the methods for assessing the costs and benefits of alternative resource options will help to foster more consensuses over choices.

In addition, Water UK believes there is a clear and crucial role for Defra, in consultation with stakeholders, to resolve questions about roles and responsibilities, perhaps through an updated version of its strategic document Directing the Flow. Likewise, we would like to see the development of a shared vision for the industry, building, inter alia, on work being done by the EA (on its long term sector plan for the industry), Ofwat's Water Industry Forward Look (an exercise in long term scenario modelling), Water UK's own internal long-term industry outlook, currently in progress, CCWater's ongoing work to understand consumer expectations and our own members' business plans and in particular their water resources plans.

The Regulatory and Legislative Framework

Successes of the Regulatory Framework (re DWI) 8.3

Research carried out for CCWater concluded that consumers are consistent in attaching great importance to safe, clean drinking water—a high quality product that is good for health. Water UK supports the view that there should be a strong and independent drinking water quality regulator, to ensure consumers' confidence in drinking water is maintained. We believe the single focus on drinking water quality through a dedicated regulator has been instrumental in driving the significant improvements achieved by the industry since 1990. Looking forward, the DWI has a key role to play in the 5-year Periodic Review process, working with Ofwat and the companies, to ensure that capital and operational investment to improve drinking water quality is assessed on a fair and consistent basis with other investment drivers. We are concerned how this would be maintained should the DWI become subsumed within a larger regulatory body with other and multiple priorities.

Problems with the regulatory framework

The Periodic Review Process 8.4-8.5

The HoL has highlighted perceived problems with the regulatory framework, and in particular the 5 yearly price review cycle. Water UK has recently responded to Ofwat's detailed consultation on this issue. Our view is that the problem is not so much the 5 yearly cycle as the lack of a long-term framework within which this sits. We do not believe that switching to a timetable which more closely aligns to the WFD would automatically be advantageous. The WFD is just one potential cost driver which the industry faces—there are many other cost and revenue pressures that Ofwat needs to take into account in setting prices and it is not clear that the process should be more closely aligned to the WFD than to other items. Our full thoughts on these topics are contained in our response to Ofwat's consultation.

We believe that with a better shared understanding of—and commitment to—the long-term plans of companies and of regulators (for instance in the context of environmental improvements), the 5 yearly process would then become much more what it is designed to be: a staging post for adapting plans in the light of changed circumstances. We believe this would deliver better long term outcomes for consumers, the environment and for the supply chain.

It is important that this is a shared understanding and that the regulatory framework also adapts to give more weight to longer term output aspirations for instance in terms of ongoing capital maintenance requirements or investments in large very long term investments such as new reservoirs or long term metering strategies.

This is important to ensure the cost of investment is minimised over the long term and that security of supply to future generations is properly planned for. It will enable companies to adopt a more continuous approach to investment, with benefits to the supply chain in terms of predictability of workload.[10] It will involve more willingness by regulators and companies to factor in the adoption of more sustainable strategies that might be more uncertain in effect and take longer to deliver, but could be much cheaper, and that strategies are "future proofed", for instance against major uncertainties such as climate change.

Resource Development 8.6-8.7

Water UK agrees that, even with a step change in demand management, new resources will be needed in some areas. This is why companies include proposals for new resources in their 25-year water resource plans. It would be helpful if Ofwat could provide clearer guidance on how major resource developments spanning more than one price renew period are funded.

There is a need also to address the problems posed by the planning arrangements, which significantly extend the lead times of such major projects.

Ofwat and the EA also need to engage with the industry and government on how changes in customer expectations over time (e.g. less willingness to tolerate occasional restrictions on water use) will alter the need for new resources and how such resources are planned and funded.

Water Efficiency 8.8-8.9

Water UK agrees that water efficiency has a central role to play in balancing supply and demand and that Ofwat should provide greater funding to companies for water efficiency initiatives. However, we should recognise the practical difficulties for Ofwat around identifying the outputs from water efficiency activities and we need to work together to improve the evidence base in this area.

Infrastructure Maintenance and Renewal 8.10

As the HoL notes, the sector's approach to maintenance investment has considerably improved over the last 5 years, with the development of the Common Framework for Capital Maintenance which has introduced a more rigorous and forward looking approach to assessing capital maintenance requirements. Companies had long believed that insufficient funding had been allocated to maintenance—largely a result of prices also having to accommodate investment to achieve legal requirements on the UK to meet new environmental standards.

At the last periodic review the new approach meant that at the last review a higher level of funding for maintenance to maintain customer service was agreed. Nonetheless many companies felt that this still fell short of the long term sustainable level. For PR09 companies are currently developing their approaches in order to demonstrate this more robustly to the regulators. This is a crucial area of expenditure for ensuring the quality and reliability of supply to consumers, where in our view Ofwat must focus on the soundness of the arguments presented in the round, taking account, in a transparent and predictable way, of a range of evidence.

Research and Development 8.11

The HoL has raised concerns about the level of R&D in the industry. We agree that Ofwat and the EA should consider the impacts of their regulatory approaches for the incentives companies receive to invest in R&D. We believe that whilst the regulatory framework encourages companies to seek out more efficient ways of delivering its operations and investments, it does not encourage companies to invest beyond what it is funded for or to choose more "sustainable" solutions. We agree that there is a tendency to focus on R&D in solutions that can give short term savings, in a 5 year payback. There are various options for encouraging R&D, including the suggestions made by the HoL. These need to be looked at alongside the question of how to encourage longer term planning by the industry. Rewards for R&D will need to be consistent with the risk that companies take on in pursuing R&D.

Water Bills and Affordability 8.12-8.13

Water UK agrees with the HoL statement that there are two serious issues facing the industry around unpaid bills and affordability of water bills for some low income groups.

With the withdrawal of the right to disconnect in 1990, water companies' only sanction to recover charges is through the Court Service, with the result that the industry is now their largest user. However not all customers who can afford to pay respond to a Court Order, and will make conscious choices to spend their money elsewhere. There is therefore an argument for a range of solutions tailored to the customer i.e. help with water affordability for those genuinely struggling or unable to pay; Court action for those non-payers where it is effective, e.g. homeowners and those in stable employment and a system similar to that in Australia outlined in the report for those where affordability is not the issue and where the Court process will not work.

We have discussed the Australian example of trickle follow devices with the water company mentioned in the report, Yarra Valley Water (YVW). We were concerned that there would need to be safeguards to ensure the approach is not taken with those who genuinely cannot afford their water bill. Companies would therefore need to differentiate between those customers who can afford their water bill and those who cannot.

Water UK agrees with the HoL that this option could provide a viable solution to those non-payers who can afford to pay and where Court action would be ineffective. Such a solution would require a change of legislation in the UK and, we believe, the development of a similar Hardship Programme to that in Victoria in agreement with the industry regulator, CCWater and Defra.

Water UK agrees with the HoL report on the issues of water affordability. Defra's "Cross-Government Review of Water Affordability" indicates that 7.8% of households spent more than 3% of disposable income on water and sewerage charges in 2004/05. This was expected to increase to 10.7% by 2009/10.

Two previous Select Committees have raised the issue of water affordability and recommended that the Government should help those suffering from serious difficulty in paying their water bills through the benefits and tax credits system. We agree and the Government has already acted in Northern Ireland, where water charges will be introduced for the first time in 2007, with a special Affordability Tariff. For those on low incomes no one will pay more than 3% of income. The Consumer Council in Northern Ireland expects about 200,000 households to benefit automatically from this tariff.

Whilst there is no guarantee that this 'benefit' will continue beyond the next 3 years, as the HoL points out, there is a comparable benefit nearer home—the annual Winter Fuel Payment. Water UK agrees with the HoL and CCWater that a targeted water benefit could provide significant help for significantly less than the Winter Fuel Payment.

Competition 8.14

Water UK agrees that competition, if efficient, could be beneficial in bringing a better allocation of water resources, and not just as suggested by CCWater with increased trading. More innovation in making water resources more available, generally, could be one of the benefits of competition

Water UK is however concerned by the HoL's lack of recognition competition, like metering, has a cost. Increasing costs by introducing universal metering to permit extension of competition to domestic customers raises the question of whether the benefits of competition are worth its cost. We would have preferred the HoL to recommend an evaluation of competition before it is extended by default to domestic customers.

The HoL is right to guard against cherry-picking and we are very pleased it raises the matter. But the HoL has not fully grasped the provisions put in place by Water Act 2003. Licensing of new entrants is not what protects against cherry-picking—it is the pricing regime put in place in Water Act 2003. It would have been useful if the HoL considered how the very low margin for new entrants, which results from a pricing regime designed to prevent cherry-picking, can nevertheless not be seen as a barrier to entry. Water competition may not be primarily about price cuts.

Water UK feel that the HoL are ill-advised in endorsing Ofwat's criticisms of water companies for making the pace of negotiations too slow. We believe Ofwat could have anticipated difficulties by facilitating the negotiation of standard contract clauses, which would have moved the negotiation process forward.

The Way Forward 8.15-8.16

Water UK disagrees with the HoL's proposal for the setting up of regional boards to prepare long-term integrated water management plans. This would conflict with the statutory consultation process for water resources plans established in the Water Act 2003, which already deal effectively with the concerns raised by the HoL. The appropriate parties are already engaged in the water resource planning process and have clearly defined roles. There is a serious danger that an extra level of bureaucracy would make the process less effective rather than more.

Demand for Water

Demographic and Social Factors 8.17

We agree that water efficiency needs to be taken much more seriously by all parties. Improving efficiency is the responsibility of all and we need to work together to take this to the next level. Imposing targets specifically on companies is likely to have limited effectiveness since many factors affecting water use are behavioural and not within water companies' control. What is needed is a collaborative approach with appropriate and sufficient funding in place.

Housing and Planning 8.18-8.23

We agree that water companies should be consulted in development planning at a strategic level. However, we do not agree with those who oppose housing expansion in the South East on the grounds that it will provoke a "water crisis". The availability of water and wastewater services need not hold up economic development as long as development and water resource plans are made side by side.

Water Supply

Climate Change 8.24

We agree that, in the past, insufficient priority has been given to climate change in water resources planning. However, we are already working with the EA and Ofwat to ensure that the next round of plans is based on common assumptions and scenarios and that climate change is fully factored into those plans in a consensual way as a result.

New resources

Reservoirs 8.25-8.26

Water UK agrees that some new reservoirs will be necessary to ensure the supply demand balance is maintained in the future. This is why companies serving customers in the South East identified a number of schemes to build new reservoirs or expand existing ones in their 25-year water resources plans prepared in 2004. We also agree that companies should not put "all their eggs in one basket" and that a range of resources should be developed alongside demand side measures. We also think that environmental and social costs and benefits should be fully factored into the assessment of long-term water resource options.

In addition, if climate change leads to wetter winters and drier summers, we may need more winter storage reservoirs to ensure sufficient supplies are available for the summer months. Subsidies for private (non-water company) winter storage reservoirs to supply customers' own needs (e.g. farmers) would help.

Desalination 8.27

We recognise that desalination is a relatively expensive option and also has environmental impacts in terms of intensive energy use. This is why desalination is not a first or preferred option. However, given future predicted demand, limited supplies from other sources and the potential impacts of climate change, it is one option that needs to be considered against others when water resource plans are developed. We would therefore welcome moves to improve the efficiency of this technology.

Leakage Reduction 8.28-8.29

The existing leakage targets and the Economic Level of Leakage approach are based on the principles developed from the 2002 Tripartite Report produced by Ofwat, the Environment Agency and Defra. These principles already embody components of a sustainable approach to leakage, as they balance a number of environmental and economic considerations. Nevertheless Water UK agrees with Ofwat that it is now appropriate to review the Tripartite principles and will be working with Ofwat, Defra, the EA and CCWater to understand how we can incorporate sustainability issues further, including better account of environmental and social costs within the assessment. This could become the "sustainable level of leakage" suggested by the HoL.

However, even a sustainable level of leakage may go up as well as down. Social factors such as noise, disruption and traffic congestion from the necessary street works to replace or repair water mains may increase the social costs of reducing leakage. The Traffic Management Act and its associated regulations will increase the cost of working in the highway for all utilities. This will directly increase the costs of leakage repairs and under the current methodology raise the economic or sustainable level of leakage.

Whilst developments in technologies for leakage detection will continue, they are likely to lead to incremental reductions in leakage. Significantly lower targets will require more proactive mains replacement, which will require funding through customer charges. Whilst customers may believe leakage levels should be lower their willingness to pay for lower leakage levels has yet to be determined.

We do not feel regional boards are an appropriate way forward or the way to determine leakage targets. Since Ofwat has overall responsibility for determining the price limits and agreeing company business plans, Ofwat should retain responsibility for determining targets based on an agreed sustainable approach.

Water UK accepts that when customers are being encouraged to save water and water use restrictions are in place, it is important for companies to show a lead and make additional efforts to reduce, albeit on a temporary basis, leakage losses below the agreed target levels.

Water Transfer 8.30

We agree that a national water grid is currently not feasible on both economic and environmental grounds, and other options to deliver the supply-demand balance are more cost-effective. However, water companies have a responsibility to constantly review the cost-effectiveness of a range of different options and we will help them to include the possibility of a national water grid in these assessments.

There is already a 'regional water grid' in the southeast. However, we do expect companies in the region to work with the EA and Ofwat to assess whether there is potential to improve connectivity further as part of their water resource plans.

Water re-use

Large-scale Re-use of Treated Wastewater 8.31

The report "recommends that the Government, the Environment Agency and Ofwat encourage and support schemes for the planned indirect re-use of treated wastewater by water companies, especially in the driest areas". It is also notes that "there is scope for greater industrial use of wastewater that has been treated to sub-potable standard, and we recommend that the Government explore means by which such schemes could also be encouraged". Large-scale water re-use schemes are not generally cost-effective at the current time. However, we would expect companies, particularly those in the driest areas of the country, to review the feasibility of such schemes as part of their water resource planning.

The first recommendation is made for areas where treated effluent is discharged to sea or coastal and transitional waters. The report also recognises that in the UK effluent recycling and re-use is normal practice. Water UK supports the principle of sustainable water re-use and schemes for planned re-use of treated wastewater. However such developments must be considered in a holistic way and as part of a long term water resource strategy that minimises adverse impact on climatic change. There must be a strong government leadership to managing issues related to public perception.

With ongoing public concerns about pollutants such as endocrine disrupters such schemes are likely to require high energy intensive solutions that treat the effluent to drinking water standards. The sustainability credentials of such schemes must be rigorously assessed against other water resource development options.

The EU Urban Wastewater Treatment Directive encourages development of standards and framework for Re-use. However, to date, in spite of calls by the stakeholders including Eureau, the Association of European Water and Wastewater service providers, neither the EC nor UK has made any progress.

Local Treatment and Re-use of Wastewater 8.32

We agree that there is potential for grey water recycling at a local level and we would welcome further research and investment in this area. We note the caution of the HoL with regard to public perceptions and agree that caution is necessary, particularly where such water is intended for internal domestic use.

Water UK aggress that re-use is a positive means to reduce demand for potable water, particularly during drought periods.

Promotion of local wastewater treatment is welcomed provided it does not create health and environmental contamination risks. Lessons from incidents, pollution and contamination caused by local treatment such as septic tanks and cesspools must be learnt. Local treatment of wastewater can reduce demand on centralised treatment works but may require more skilled resources and management. In addition the emergence of strict effluent and sewage sludge quality standards will mean that technologies needed for local treatment will have to improve considerably, or better source control of pollution be implemented.

Water UK supports the call for universal statutory standards for sub-potable water intended for re-use. Work by WHO and organisations such as Eureau could be a good basis for development. Provisions in the UWWTD could also be used as a hook to collaborate with the European Commission and the EU.

Rainwater Harvesting 8.33

We agree that there is more potential for rainwater harvesting systems, particularly in new developments where there is the opportunity to introduce such systems more cost-effectively at the design stage. However, health and safety concerns need to be borne in mind and such systems are currently most appropriate for external uses of water only.

Water Efficiency

Promotion of Water Efficiency 8.34-8.35

Water companies have a statutory duty to promote water efficiency which they take seriously. All companies promote the efficient use of water in various ways and are committed to continuing to do so. This includes free auditing of and advice for large customers (e.g. commercial and industrial and information and water saving devices for household customers). Water UK on behalf of the industry is also actively participating in the Government-led Water Saving Group, which is examining the barriers to water efficiency and how efficiency can be taken to the next level.

We believe that there may be scope for a government-backed water saving body to push water efficiency higher up the agenda. However, we would caution that such a body should not duplicate the excellent efforts and progress being made by waterwise, an independent NGO set up and partly funded by the water industry.

Domestic water efficiency

Public Awareness 8.36-8.37

We agree that talking to children and engaging with them on a range of water management and efficiency issues is important to the water industry and to future sustainability in general. The current drought in the South East has raised the profile of water and the need to use this precious resource wisely.

The industry is already active in this area. We have funded and implemented a website (www.waterintheschool.co.uk). This includes National Curriculum compatible materials such as guidance for teachers, activity and fact sheets, animations and downloadable software to help in assessing the school's water management performance.

Companies also provide water efficiency devices and equipment (such as water butts), talks about water management and conservation and visits to water and wastewater treatment works

There are many pressures on the content of the National Curriculum but we would welcome the inclusion of water efficiency and water management generally.

Metering 8.38-8.42

Water UK supports the sentiment behind all the recommendations of the HoL concerning metering. We believe that implementation work needs to be taken forward for all of them, to put them in practice where possible and identify modifications where necessary. Some change may be necessary in practice to give substance to the spirit of the recommendation.

As with issues on water efficiency, Water UK supports fully the emphasis on education and the need to raise customers' awareness. In particular, the recommendations on smart water bills and smart meters are well worth pursuing. Water companies should be free to design specific smart water bills that raise customer awareness in the way most suited to their local conditions.

We particularly welcome the recommendation that smart meters should be introduced progressively as conventional meters need replacing.

We agree with the principle that rising block tariffs could encourage water efficiency while allowing the satisfaction of basic essential water needs at low cost. However, essential water needs vary with household size and other characteristics. Establishing household size is an expensive and intrusive data management activity, which is also prone to fraud and errors. The alternative to adapting a rising block tariffs to household characteristics is to fixing an identical rising block tariffs for all households, irrespective of their sizes. But that may increase affordability problems for poor large households. We think that further work needs to be done before a consensus can be developed on how a rising block tariff could be implemented. Meanwhile, it should not become compulsory.

The HoL reports a consensus on the water saving that metering can generate; this consensus applies to the savings that can arise when customers are universally and compulsorily metered. The current policy of optional metering does not produce such savings.

Water UK welcomes the HoL recommendations that water companies that wish to increase metering should be able to do so by obtaining easier access to the water scarcity status. We agree that this can be achieved without primary legislation but through a revision of the Water Industry (Prescribed Conditions) Regulations 1999. Such revision should clearly specify the objective achievable conditions that need to be satisfied for a water company to qualify for water scarcity status. This will increase regulatory transparency and encourage companies to apply when appropriate.

Water Efficient Fittings and Appliances 8.43-8.46

We agree that there is scope to improve the water efficiency of fittings and appliances. We are working with the Water Saving Group to further this through amendments to the Buildings Regulations and a labelling scheme. We think it is important that designers, suppliers and retailers are also involved in this process and we will continue to work to ensure that all parties take forward this agenda as fully and as quickly as possible.

We also agree that financial incentives can play a vital role in incentivising consumers and others to become more water efficient and we look to Government to work collectively to ensure such incentives are put in place.

Building Regulations 8.47

We are keen that any revisions to the Building Regulations should be as ambitious as possible in water efficiency terms and we are working through the Water Saving Group to achieve this.

We do not believe that there is an argument for regional variation in this area. Different regions can experience water availability problems at different times and it is also important that the market receives a strong and consistent signal about the future direction of building standards.

Code for Sustainable Homes 8.48-8.49

We agree with all the recommendations of the HoL in respect of the Code for Sustainable Homes. In addition, we recommend that the Code is extended to all buildings (not just homes) and to existing (not just new) buildings as soon as possible.

Industrial and agricultural water efficiency

Industry 8.50

Whilst companies already provide a great deal of advice and information to industrial water users, we agree that more can always be done. We think that further discussion about how compulsory water audits are paid for is required but would observe that, in our experience, such audits and the investments in efficiency which they generate, generally tend to pay for themselves within a short space of time.

Agriculture 8.51

We agree that the list of products covered by the Enhanced Capital Allowance scheme could be extended to include agricultural equipment and potentially other items.

Water and the Environment

Water Framework Directive 8.52-8.53

We support the call for clarification of "good ecological status"; however the call should be directed at the European Commission, albeit with the EA and Defra contributions. We will ask for broader stakeholder involvement and data input than is currently the case.

Water UK would like to see measures stepped up to control both urban and agriculture diffuse pollutions. We support the recommendation that the Water Industry must not be seen as a soft target for tackling diffuse pollution. Our customers should not pay for the cleaning up pollution caused by other sectors including farming and transport. The government should put in place cost recovery mechanisms to enable sectors that clean up pollution caused by others to recover their costs.

The quality of drinking water abstraction sources must be protected as a matter of priority. Relevant measures must be included in the Significant Water Management Measures and costs included in the ongoing national costing exercise.

Priority substances directive 8.54

A de minimis provision in the directive for priority hazardous substances in particular would provide a pragmatic way to manage cessation of those substances. Water UK therefore supports the need for a de minimis provision in the directive. However such a provision should not be used as an excuse for sectors to continue to discharge these substances into water company sewers.

The major gap in the EC proposals to date is the lack of comprehensive emission control measures that is now left for members to put in place. This means the UK Government needs to ensure that it has developed the right range of measures to control these substances at source. There are a number of SMEs in the urban environment, government departments and local governments that may not be aware of the impact of this daughter directive on them. Water UK is committed to rigorous enforcement of the Polluter Pays principle in implementing the directive on priority substances.

Water UK is keen for the water industry to recover its costs fully from the polluting sectors. We recommend that the Government puts in place the appropriate cost recovery mechanisms for industries to recover their costs.

Sustainable drainage systems 8.55-8.57

The water industry through Water UK is a member of the National SUDS Working Group, which includes membership of Defra, DCLG (previously ODPM), Welsh Assembly, Ofwat, Environment Agency, Home Builders Federation, English Nature, Local Government Association and other stakeholders.

The Working Group established the Interim Code of Practice on SUDS in 2004. It includes an indication of what type of SUDS local authorities, highway authorities and sewerage undertakers would adopt. To clarify this further and to assist developers the industry prepared a separate note on general conditions for SUDS features that may be adopted and operated by sewerage undertakers.

Water UK agrees that Government needs to take a lead and address the current financial, legislative and regulatory issues that preclude wider take up utilisation of sustainable drainage systems. In particular, for sewerage undertakers, these include:

(1)  the right of connection to the public sewerage system;

(2)  the lack of a right by sewerage undertakers to discharge surface water to private watercourses;

(3)  disposal of controlled waste from SUDS;

(4)  health and safety issues associated with bodies of open water in residential areas

Water UK agrees that we should maximise the use of the range of available water resources. This includes investigating the cost effectiveness of storm water and/or recycled water for irrigation purposes to conserve valuable treated water supplies for the benefit of both customers and the environment.

Water UK supports an integrated approach to urban drainage which should include sustainable drainage systems.

Water resources 8.58-8.60

Water UK supports the call for OSIRC, NERC and CEH to carry out additional research with regard to fresh water ecology.

Water UK supports the recommendation for the Agency to consider water quality implication of each CAMS plans and links with the WFD.

Water UK also supports the conclusion combining protection of the environment and security of supply. Water UK is very concerned that there is no recognition anywhere in the section that "developing a new source" has a cost which local customers have to pay. The question is not just whether water is available but at what cost.

14 September 2006

10   We support the research project currently being commissioned by UKWIR to investigate problems with the regulatory cycle and possible solutions. Back