APPENDIX 8
Memorandum submitted by Water UK (G11)
EXECUTIVE SUMMARY
We are pleased that Government brought together
within a new Department, DEFRA, environment and food and agriculture
interests so allowing an integrated approach to the environment
and land use issues. We support the DEFRA project.
We are also pleased that it has not been altered
by changes in Ministerial responsibilities this week; the Ministerial
team have been very positive and helpful since the establishment
of DEFRA. It needs time to deliver the benefits that an integrated
approach should bring to all stakeholders.
DEFRA has been in existence for a year and its
Vision, aim and objectives were finalised only about six months
ago. It is too early to reach firm conclusions on how focussed
DEFRA has been in pursuing its Vision. Suffice it to say that
fire-fighting ongoing issues in the aftermath of Foot and Mouth
and BSE/CJD and in response to the EU have tied up resources.
The need for safe and adequate supplies of drinking
water and for proper sanitation rank alongside the need for food.
We are disappointed that the Vision fails to give due weight to
the importance of water to the quality of life.
We agree that the means of achieving the Vision
is sustainable development with its four interlinked objectives:
— social progress which recognises
the needs of everyone;
— effective protection of the environment;
— prudent use of natural resources;
and
— maintenance of high and stable levels
of economic growth and employment.
The emphasis that DEFRA has given to climate
change is exemplary though the opportunity to involve the water
industry—a major energy user—more has not been exploited.
Co-ordination of the management of climate change as it occurs
also needs consideration.
DEFRA has made less headway in avoiding environmental
degradation and making efficient use of natural resources. Avoiding
the possible pollution consequences, especially from diffuse sources,
of food production needs action. Similarly a strategy is needed
that will ensure the availability of water resources and a viable
water industry structure for the long term.
The immediate task is for DEFRA to lead the
debate over the next periodic review of the prices that water
industry customers will have pay for capital assets and maintenance
programmes in the years 2005 to 2010. These are essential infrastructure
developments that are needed in accordance with the DEFRA Vision
to provide adequate supplies of high quality drinking water, to
provide reliable and good quality sewerage services and to enhance
environmental quality.
The willingness of DEFRA Ministers and officials
to discuss policy issues and attend meetings with other stakeholders
has been impressive. However, intra-governmental consultations
through the new structures seem to have been time-consuming making
external consultations later and more time-restricted than previously.
There is not yet a proper balance between the
various interests that DEFRA covers to allow sustainable development
to occur. Over the past year environmental protection and water
matters have taken the backseat.
In theory, DEFRA is able to offer an integrated
and sustainable approach to achieve its objectives, looking beyond
short-term single sector fixes to integrated multi-sectoral solutions.
There are a few welcome signs of this but progress is slow. This
may be due partly to a lack of resource and/or experience within
parts of DEFRA to secure a proper balance of interests.
An example of this is the Water Framework Directive
that affects all sectors of the community and requires an integrated
approach to protection of the water environment. A coherent mechanism
within DEFRA for progressing it with full involvement of all stakeholders
does not seem to exist.
The role of the Wildlife and Conservation Directorate
is unclear, especially in its relationships with English Nature
and the Environment Agency, the statutory bodies in this field.
Sufficient strategic guidance from DEFRA to these agencies is
missing.
DEFRA appears to have devolved much of the responsibility
for water protection to the Environment Agency but the division
of responsibility is unclear. DEFRA needs to establish and chair
a National Water Forum to develop common understanding and consensus
between all stakeholders on water-related issues, allowing clear
decisions on long term sustainable solutions to be made.
There also needs to be effective communication
between Departments across the UK so that consistent messages
are put across, especially in EU negotiations, and implementation
practices are adequately coordinated.
The objectives that DEFRA has set for itself
in respect of rural affairs are those of general applicability.
They include promoting biodiversity, improving enjoyment of the
countryside, ensuring the sustainable use and management of natural
resources and promoting thriving rural communities and economic
prosperity based on sustainable farming, water and other rural-based
industries. In these, DEFRA should set out the policy framework
and ensure appropriate and co-ordinated actions follow.
In summary, DEFRA has made a steady if slow
start. It will need to take care to avoid myopic vision on agriculture,
failing to join up water and other important strands that are
essential to achieving its Vision. It will need time to deliver
the benefits that an integrated approach to environmental, food
and agriculture and rural affairs should bring.
1. Introduction
1.1 Water UK represents the water industry
throughout the UK. Our members abstract water from groundwaters
and surface waters, treat it to the high standards expected for
drinking water and distribute it to domestic and business customers.
They collect the used waters from customers, treat them to high
standards and return the treated wastewaters back to the environment.
By-products of the treatment processes can and are used—gas
from wastewater treatment and sludge disposal as sources of renewable
energy and sewage sludge as a soil conditioner and natural fertiliser.
We therefore interact closely with rural communities, the farming
and food industries and others within the wide range of interests
served by DEFRA.
1.2 We therefore welcome this opportunity
to comment on the role and progress of DEFRA.
2. Progress in meeting the Vision
2.1 DEFRA has been in existence for a year
and its Vision, aim and objectives were finalised only about six
months ago. It is too early to reach firm conclusions on how successful
(or otherwise) it has been or will be in relation to these long-term
aspirations. Our impressions of the progress that DEFRA is making
are outlined in this submission.
2.2 We supported the formation of DEFRA
on the grounds that it should enable an integrated approach to
be taken to the management and use of land and the inter-related
other environmental resources. We welcomed the preparation of
the Vision as a guiding statement for DEFRA's longer-term objectives.
The Ministerial team at DEFRA and the advisers have been very
positive about the need for an integrated approach to environmental
policy.
2.3 DEFRA's Vision is broad, seeking to
safeguard and promote rural communities and of high quality public
services to them, looking for the food, fishing and farming industries
to work together to produce safe food without dependency on output-related
subsidies, striving for careful land management and the promotion
of biodiversity on land and in the seas, seeking animal welfare
and protection against animal disease. These are all laudable
aims.
Water for life
2.4 We are disappointed that the Vision
does not give due weight to the importance of water to the quality
of life and, specifically, to the contribution that the water
industry makes through provision of high quality drinking water
and provision of sewage services. Medical advice is that an adequate
intake of water is important for good health; the quality and
value of tap water should therefore stand alongside safe, nutritious
food as essential to the health of the whole nation.
Sustainable development
2.5 DEFRA does see the practice of sustainable
development with its four interlinked objectives:
— social progress which recognises
the needs of everyone;
— effective protection of the environment;
— prudent use of natural resources;
and
— maintenance of high and stable levels
of economic growth and employment;
as the means of achieving the Vision. We concur.
Climate change
2.6 In its Vision, DEFRA recognises the
importance of climate change and environmental degradation and
sees low carbon emissions and the efficient use of natural resources
as the heart of our way of life.
2.7 Much of the emphasis on climate change
is on measures that might help curb emissions of greenhouse gases.
This effort is exemplary and progress has been steadily made.
We would however query the approach taken to the water industry,
the third most energy intensive industry in the UK with over 13
per cent of turnover spent on energy. Since the basis for qualification
is an industry subject to integrated pollution prevention and
control, the water industry is not able to enter into negotiated
agreements whereby energy efficiency and other means of reducing
greenhouse gases would entitle it to a reduction in climate change
levy.
2.8 We would also query whether sufficient
attention is being given to the means for sequestering greenhouse
gases. Also, we doubt if sufficient is being done to improve coordination
across all sectors of the management of climate change that will
inevitably occur. For example, changing weather patterns might
entail different crops that lead to the need for variations in
pest controls and water protection measures.
Environmental protection
2.9 In terms of avoiding environmental degradation
and making efficient use of natural resources, DEFRA has made
little headway. For example, we do not believe that DEFRA has
a sufficiently coherent vision and strategy for water to underline
its importance in a successful society. There is need for a strategy
that will ensure the availability of water resources and a viable
water industry structure for the long term.
2.10 The Department's responsibilities in
relation to these issues cannot be delegated to others. Immediately
it must lead, not follow, the debate surrounding the next periodic
review of prices and the capital assets and maintenance programmes
in the years 2005 to 2010 that water customers will have to pay
for. It cannot, for example, rely on Ofwat to set a strategy and
also determine programmes and funding to deliver it, as has happened
in the past. Only government has the authority to set a course
that meets the needs of all stakeholders in the critical but controversial
area of environmental enhancement and to advise the water industry's
regulators accordingly.
2.11 We also need the benefits of customer-responsive
food production and rural employment without the disadvantages
of water pollution, an issue within the framework of the Vision
but on which progress is slow.
Stakeholder involvement
2.12 The pursuit of the Vision requires
full stakeholder involvement. We have been impressed by the willingness
of DEFRA Ministers and officials to discuss policy issues and
attend meetings with other stakeholders. DEFRA's own stakeholder
programme has also been successful from a standing start. That
said, we have the impression that intra-governmental consultations
are more complex and taking longer than hitherto, making external
consultations later and more time-restricted.
2.13 We wonder whether more could be done
to promote the Vision and DEFRA's aim and objectives to a wider
audience and therefore to encourage even more stakeholders to
participate in their development. For example making printed versions
of the DEFRA Annual report, a means for reporting achievements
over the year to all stakeholders including the general public,
more freely available could help.
Water UK conclusion
2.14 We conclude that these are early days.
There has been some progress in a few areas where DEFRA has moved
towards its Vision. There has been insufficient regard to the
importance of water and DEFRA strategies relevant to it are needed.
The immediate need is for DEFRA to lead the debate over the next
review of prices to pay for developments by the water industry
over 2005 to 2010 that are necessary to sustain its high quality
services to customers and to the environment.
3. Balancing farming, food, environmental
and conservation concerns
3.1 We have yet to see a proper balance
between the various interests that DEFRA covers and hence in its
delivery of the principles of sustainable development. This may
be in part due to the distraction of having to deal with crises
in the farming sector such as the aftermath of Foot and Mouth
disease. Over the past year environmental protection has taken
the backseat. Water, an essential component to a healthy lifestyle
and sustainable environment, has received scant attention.
3.2 Water UK has consistently drawn attention
to the fact that many current farming practices and the Common
Agricultural Policy have major implications for the water industry,
requiring it to remove pesticides before putting drinking water
into supply or to find alternative resources and to blend or abandon
water sources to comply with nitrate standards. These measures
are expensive and not sustainable. Avoiding pollution at source
is the sustainable solution and compatible with the DEFRA vision
of avoiding environmental degradation.
3.3 Conversely the product of sewage treatment,
sewage sludge, can make a real contribution to sustainable agriculture,
reducing the dependency on inorganic fertilisers and improving
soil condition, helping for example to improve soil structure
and to reduce erosion.
Water UK conclusion
3.4 We conclude that as a priority there
is a need for joined-up consideration of all the policy areas
for which DEFRA is responsible. We hope that progress will be
made in DEFRA's second year.
4. Infrastructure to deliver objectives
4.1 In theory, DEFRA is able to offer an
integrated and sustainable approach to achieve its objectives,
looking beyond short-term single sector fixes to integrated multi-sectoral
solutions. It could plan, with the help of key stakeholders such
as landowners, the farming and water industries, for solutions
that are sustainable over the long term.
4.2 DEFRA is not, of course, in complete
control of its workload and therefore may have to allocate staff
to tasks that may not be priorities towards achieving its Vision.
For example, it may need to devote resources to deal with infraction
proceedings in respect of European Directives. Conversely, making
an early and well researched input into the development of EU
and international initiatives can both reduce the likelihood of
implementation problems later and gain wider acceptance of DEFRA's
objectives and their means of achievement.
4.3 There are a few welcome signs of the
DEFRA being prepared to look for a more integrated approach, an
example being the consultation document "Sustainable Food
and Farming—working together" produced in March. However
progress has been slow. We wonder if this is due to a lack of
resource and/or experience within parts of DEFRA, especially within
the Environmental Protection Group, to secure a proper balance
of interests that would allow integration to take place.
Balancing the water agenda
4.4 For example, there does not appear to
be a coherent mechanism within DEFRA for progressing the concepts
of the Water Framework Directive that affect all stakeholders,
not just the water sector. The Directive requires an integrated
approach to protection of the water environment that focuses on
achieving acceptable and sustainable outcomes, and with full engagement
of stakeholders. This is consistent with the DEFRA Vision.
4.5 Amongst other things, the Water Framework
Directive provides the vehicle for dealing with diffuse pollution,
much of which originates from land use and agricultural-related
activities. This is a difficult issue to address, needing a string
of cross-sectoral measures, including support to farmers for environmental
practices such as the safe storage and handling of agrochemicals,
avoiding nitrate spikes from ploughing up pastureland and keeping
animals away from sensitive water resources to reduce the risk
from Cryptosporidium. However unless it is tackled—through
the collaboration of all stakeholders coordinated by DEFRA—water
and land use practices that are sustainable in the long term will
not be achieved. Whilst we recognise the political will and the
commitment of individual civil servants exists we are not convinced
this work is sufficiently resourced.
4.6 Water UK has called for Government to
set up and chair a National Water Forum that would develop common
understanding and consensus between all stakeholders—including
farming interests—on water-related issues, allowing clear
decisions on long term sustainable solutions.
4.7 In reality, DEFRA has devolved much
of the responsibility for water to the Environment Agency, with
drinking water quality delegated to the Drinking Water Inspectorate.
The division of responsibility between DEFRA and the Environment
Agency is not always clear and this is exacerbated by the Vision
statements of both organisations. These appear to be parallel
rather than the Environment Agency's Vision dovetailing into that
of DEFRA. DEFRA should clearly set the policy framework and elaborate
strategic guidance that its regulatory agencies should follow.
Coherence across the UK
4.8 It is important that DEFRA should not
operate in isolation from other Departments, including its sister
organisations in Scotland, Wales and Northern Ireland. There should
be effective communication between Departments so that consistent
messages are put across, especially in EU negotiations, and implementation
practices are adequately coordinated.
Water UK conclusion
4.9 We are not convinced that the DEFRA
infrastructure is sufficiently resourced to deliver a truly integrated
approach to achieving its Vision. The issue of diffuse pollution
will be a major test of its capability. DEFRA needs to set the
policy and give clear strategic guidance on water.
5. Role and Influence of Environment Protection
Group and Wildlife and Countryside Directorate
Environment Protection Group
5.1 We do not believe that the Environment
Protection Group has had a significant influence on DEFRA policy
since its transfer. Farming and land use issues have dominated
the agenda.
5.2 We hope that the Environment Protection
Group (EPG) will be able to make an impact in the future, particularly
in setting out strategies and guidance to achieve important elements
of the DEFRA Vision. For example, consistent with the objective
of making efficient use of environmental resources, there is a
need for DEFRA, through the EPG, to propose a long-term strategy
for water resources management. This should look both at reducing
demand and at developing new supplies, to cope with future uncertainty
in demand and supply, stemming for example from climate change.
Wildlife and Conservation Directorate
5.3 The role of the Wildlife and Conservation
Directorate is unclear, especially in its relationships with English
Nature and the Environment Agency, the statutory bodies in this
field. The fact that the main part of the Directorate is in Bristol
has not helped integration into DEFRA. The lack of clarity in
its role has limited the influence that it has or could have in
future.
5.4 The fact that the respective roles and
responsibilities of the two statutory agencies, especially in
relation to habitats protection, are also unclear has not helped.
In this, DEFRA has not issued sufficient strategic guidance to
the agencies, leaving considerable scope for separate interpretation
of their responsibilities. Hence the Environment Agency supports
specific designation of areas as sensitive on the basis of scientific
justification (an approach with which we agree) whereas English
Nature prefers a blanket approach.
5.5 These uncertainties make it difficult
to decide on which areas, habitats and species warrant priority
action and how, what and when action should be taken. A more coherent
strategy, defining DEFRA's role and perhaps bringing together
the conservation responsibilities of English Nature and the Environment
Agency into a single management agency, should be considered.
5.6 The water industry has made good progress
in collaboration with landowners and conservation groups in protecting
species and habitats. DEFRA needs to provide new guidance underlining
the beneficial connectivity of sustainable conditions, so that
for example the conservation or creation of wetlands not only
supports threatened wildlife, but also plays a major role in flood
management.
Water UK conclusions
5.7 Neither the Environment Protection Group
nor the Wildlife and Countryside Directorate has yet made its
mark on DEFRA, though both have the potential. Most urgent is
the need for the responsibilities of each, and the agencies that
operate in the same fields, to be better defined.
6. Objectives for the rural agenda
6.1 The objectives that DEFRA has set for
itself in respect of rural affairs are those enunciated in its
statement of general objectives. The most relevant of these, consistent
with the principles of sustainable development, are:
— promoting biodiversity;
— improving enjoyment of the countryside;
— ensuring the sustainable use and
management of natural resources;
— promoting thriving rural communities
and economic prosperity based on sustainable farming, water and
other rural-based industries.
Promoting biodiversity
6.2 We expect DEFRA to strongly promote
biodiversity and to encourage landowners and occupiers to make
an active contribution. As a major landowner, the water industry
already takes a leading role. It manages hundreds of Sites of
Special Scientific Interest. Many sites covered by the Habitats
Directive rely on its careful management of water abstractions
for public water supply and treated wastewater discharges. It
actively seeks to protect and promote UK biodiversity, for example
it is the national sponsor of the otter.
Improving enjoyment of the countryside
6.3 Through environmental protection, enforced
by the Environment Agency, and countryside stewardship schemes,
DEFRA has a wide range of measures available to safeguard environmental
quality and manage the physical environment. The adequacy of the
measures in combination may need review to check their efficacy
for achieving the DEFRA objective.
6.4 Often much enjoyment from the countryside
comes where a water feature is included. In this, the water industry
also plays an important role, ensuring that sewage is collected
and treated so that watercourses are protected and also allowing
public access to its reservoirs.
Ensuring the sustainable use and management of
natural resources
6.5 We would hope that DEFRA will take a
positive approach to the management of water resources, promoting
the storage of winter rainfall in areas that may be subject to
stress during other times of the year. Although DEFRA and the
Environment Agency have actively encouraged water storage on farms,
they have been reluctant to do so in relation to public water
supplies.
Promoting thriving rural communities and economic
prosperity
6.6 To achieve this objective will require
major reforms in the way that rural practices are supported at
present. For example, intensive farming contributes to the increase
in flooding as excessive grazing results in water running off
close-cropped grass too rapidly, yet is encouraged by subsidies
based on number of animals.
6.7 The countryside is dynamic and care
should be taken not to fossilise it through over zealous planning
policies. The water industry claims much of its water for drinking
water supply from rural catchments and has to have adequate infrastructure
to collect and distribute it. Likewise, sewage collection and
treatment facilities are needed in rural communities. DEFRA should
ensure that planning policies support such essential infrastructure.
6.8 Significant developments in rural areas
are already subject to thorough prior assessment of, taking into
account not only environmental impacts but also economic and social
implications. A further check of their sustainability is the ability
of service providers, such as water and sewerage operators, to
meet their requirements. DEFRA should make sure that the views
of such providers should be actively sought and taken on board
before decisions are made.
Water UK conclusion
6.9 The rural affairs agenda has been set
by DEFRA's Vision and actively involves the water industry. DEFRA
has an important role in setting out the policy framework and
ensuring appropriate actions follow.
7. Conclusions
7.1 DEFRA has the potential to deliver benefits
to all stakeholders through its Vision. It has made a start. These
are early days with considerable distractions from inherited problems
and ongoing, short-term activities.
7.2 Joined up thinking and action within
DEFRA and with other Departments across the UK will be essential
if real progress towards the Vision is to be made. This presupposes
balanced attention and resource allocation within DEFRA to the
whole range of issues that the Vision encompasses. It is not obvious
from DEFRA's annual report 2002 that this balance exists.
7.3 To date, water has not received the
attention that its contribution to the Vision merits. The periodic
review of prices provides an immediate opportunity for DEFRA to
demonstrate its leadership in relation to water.
7.4 The concept of sustainable development
provides a set of principles and an integrated approach that should
help DEFRA to focus on its Vision. Under the guidance of sustainable
development, DEFRA should develop strategies to ensure the long-term
viability of the water industry and the services it provides,
to improve water quality through prevention of pollution at source
and tackling diffuse pollution, and to define more clearly the
responsibilities and accountabilities of the agencies that it
uses.
7.5 Stakeholder involvement is key since
all parts of society have contributions to make to achieve the
Vision. DEFRA is prepared to engage stakeholders but often in
an ad-hoc way such as attendance at meetings and conferences.
In respect of water, we would like to see a more formal mechanism,
a National Water Forum.
May 2002
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