Memorandum submitted by United Utilities
(J14)
1. Thank you for providing United Utilities
with the opportunity to comment on the implementation of the Water
Framework Directive. We are a multi-utility involved in the supply
and treatment of drinking water, and the treatment of wastewater
in the north west of England. We also have an interest in issues
affecting the agricultural community, as we own significant areas
of catchment land (58,000 hectares) much of which is used for
agricultural purposes.
2. The Water Framework Directive was agreed
in December 2000 with a timetable for initial implementation extending
over the subsequent 15 years. This duration was essential to allow
for the development of the River Basin Management approach to
precede development and implementation of derived solutions.
3. It is now essential that the work done
across Europe by the various regulatory bodies in developing the
River Basin Management framework is rapidly moved forward and
tested on pilot areas in preparation for full implementation.
This same approach should be pursued within the UK and United
Utilities would welcome the opportunity to participate in any
such pilot trial if a river basin within the north west of England
was selected. As an example the work done by the Mersey Basin
Campaign on which both United Utilities and the Environment Agency
are represented could form a platform from which to build a pilot
trial. This pilot should not only be used to test the methodology
proposed but also to assess the resource implications on all bodies
that will be involved in what is possibly the largest and most
complicated piece of water legislation in history.
4. In parallel with the testing of the River
Basin Management approach work should also be put in place to
develop and test the implementation approaches that will be required.
This is particularly relevant to the area of diffuse pollution
control where technologies may be less well developed and tested
than in areas of wastewater treatment. Again United Utilities
would welcome the opportunity to participate in trials in this
regard, and as a major agricultural landowner we can provide particular
opportunities. In this regard we have recently presented to Defra
officials on our approach to catchment mapping and land use management
including issues such as livestock management, nutrient budgeting,
vegetation management, storage and use of fertilisers. We have
also developed experience in aspects of diversification to enable
our farming tenants to reduce their dependency upon traditional
more intensive farming techniques. We would be happy to host site
visits for interested parties to our demonstration farm at High
Hullockhowe near Haweswater in the Lake District where we have
been working closely with the RSPB in developing a model of best
practice for sustainable upland farming.
5. Given that the River Basin Management
approach is not yet fully developed it is difficult to predict
the level of cost that implementation will require or where this
will fall. Those with the task of developing River Basin Management
plans will face a problem in the comparative evaluation of solutions.
This will be a particular issue when there is a choice between
further restrictions on point source discharges (eg wastewater
treatment discharges) or reductions in diffuse pollution. Information
on the issues and costs in point source control are widely available
as compared with a comparative lack of information on these same
issues for diffuse pollution control. This aspect should not unduly
influence the choice of solution. The collection of such information
should be a key issue in any trials of diffuse pollution control
techniques such as referred to above. It will be essential that
guidance is provided that sets out clearly how aspects such as
the "polluter pays principle" are incorporated within
the River Basin Management approach.
6. The River Basin Management approach will
need to be implemented rigorously and consistently across the
country. This must be a key role for the Environment Agency over
the next 10 years providing a single central focus defining the
methodology and dealing with the technical issues that will arise.
At present there remains a lack of clarity on the definitions
of river basins, water bodies, human activity, heavily modified
water bodies etc and this is an area that needs urgent attention.
It is hoped that the current parallel consultations on such technical
issues will speedily resolve these areas.
7. The Water Framework Directive has the
potential to provide cost effective tangible environmental benefits.
However the extent to which it is viewed as a success depends
critically upon the work done over the next few months in carefully
defining the methodology by which the these factors (cost effectiveness
and benefits) are assessed. The requirement for a wider stakeholder
involvement will pose a particular additional challenge in this
area. Again these are issues that should be reviewed in any pilot
areas to ensure that the level of benefit demonstrably justifies
the expenditure and impacts on society involved.
United Utilities
20 September 2002
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