Memorandum submitted by the Drinking Water
Inspectorate
1. The 2004 Periodic Review [PR04] has
a significant strategic importance for drinking water quality,
as we approach the end of the post-privatisation provision for
large quality-driven programmes of work to meet current and future
standards. The water industry is making the transition to water
company-driven strategic maintenance programmes to maintain water
quality. The Drinking Water Inspectorate will seek assurance from
the PR04 process that water companies will have the managerial
and financial flexibility to act proactively to maintain drinking
water quality during the APM4 period and beyond.
DWI's Role
2. DWI is responsible for identifying requirements
for drinking water quality, and for agreeing specific drinking
water quality programmes of work with individual water companies,
which are then funded through the PR04 process.
Objectives
3. For PR04, DWI objectives are to:
— meet current and future drinking
water quality standards; and
— facilitate the transition from large
quality-driven programmes of work as the typical post-privatisation
model to a water company-driven strategic maintenance programme
to achieve agreed minimum levels of service, using mechanisms
such as Distribution Operation and Maintenance Strategies (DOMS)
and the Capital Maintenance Planning Common Framework methodology.
Drivers
4. The main drivers for drinking water
quality for PR04 are as follows:
— completion of the 20 year distribution
mains improvement programme. This applies to mainly to five companies
whose renovation programmes will run through most of AMP4;
— improvements to water treatment facilities
where necessary to meet current and future standards;
— programmes of strategic lead pipe
replacement to meet revised lead standards; and
— improving the acceptability of water
to consumers, by reducing consumer complaints of discoloured water,
and addressing taste and odour issues.
To gain support from DWI, and thus inclusion
in business plans, any scheme proposed by a water company has
to demonstrate justification of need, and have a mechanism to
demonstrate the benefits that accrue to consumers.
Guidance
5. To date DWI has issued a number of Information
Letters[13],
[14],
[15],
[16],
[17]
to companies, outlining expectations and requirements for PR04.
This guidance is in the public domain. We have liaised with individual
water companies throughout the process, as well as other Regulators
and interested parties.
October 2002 Preliminary Assessment of Requirements
6. Water companies submitted their preliminary
assessment of drinking water requirements in response to Information
Letter 13/02. After an initial challenge by DWI, the costs were
used to gauge the potential size of the drinking water quality
programme and any areas of difficulty.
June 2003 Submission of Proposals
7. Water companies submitted detailed proposals
for each individual scheme in June/July 2003 in response to Information
Letter 4/03. DWI carried out a preliminary assessment of the schemes
and issued Preliminary Opinion Letters (PoLs) setting out whether
DWI was minded, or not, to provide technical support for the schemes
to be included as quality programmes in water company draft business
plans. PoLs were circulated to other stakeholders for comment.
A summary of the programme is provided in Annex 1. Detailed assessment
and technical audit of these schemes is in hand, with a view to
providing water companies with a Letter of Support (LoS), or otherwise,
for them to include the schemes in their business plans to be
submitted to Ofwat in April 2004. LoS will take account of Ministerial
guidance on the quality programme.
Water mains renovation
8. The area of greatest cost within the
drinking water quality programme is provision for completion of
the strategic distribution system mains renovation programme.
This programme renovates the pipework used to supply water to
consumers, primarily to prevent dirty water events caused by corrosion
of old cast iron water mains. Work outstanding is for the last
five years of a 20 year programme. Work is concentrated in five
water companies—United Utilities, South West Water, Northumbrian
Water, Yorkshire Water and Dwr Cymru/Welsh Water. All other companies
will have substantially completed their programmes by 2005. Requirements
were identified at the 1999 Periodic Review, and assessment now
is a fine-tuning process.
Nitrates
9. Rising nitrate concentrations in source
waters caused by run-off from agricultural areas are a concern.
Schemes to reduce nitrate concentrations will be supported by
DWI if the need is justified. The steps to be taken are likely
to be a mix of blending and treatment solutions. In parallel,
we support the need for steps to mitigate future pollution, although
these steps will not alleviate the need for action to provide
blending and treatment solutions now for contaminated sources.
Other treatment requirements
10. Treatment improvements are also required
for a variety of other causes, including pesticides, trihalomethanes,
turbidity, cryptosporidium, iron and manganese. These schemes
generally arise from a combination of deterioration of source
water quality and new or revised quality standards.
Lead
11. The EC Council Directive 98/83/EC [the
Drinking Water Directive], which came into force on 25 December
1998, requires an interim standard for lead of 25 µg/l to
be achieved by 25 December 2003, and a final standard of 10 µg/l
to be achieved by 25 December 2013. These requirements have been
transposed within Regulations for England and Wales, and delivery
of the requirements are in hand using two complementary approaches.
12. The first element is to put in place
plumbosolvency measures of control by treatment whenever there
is a risk that water at the consumer's tap will contain a lead
concentration in excess of 10µg/l. Where plumbosolvency treatment
is required, it will have to be maintained whilst there are significant
numbers of properties supplied through lead pipes owned by property
owners, irrespective of whether the water company has replaced
all of its lead pipes. This element will be substantially completed
within the AMP3 period, and evidence to date suggests it has been
effective and efficient in reducing lead concentrations. Most
areas of England and Wales now meet the interim standard due to
plumbosolvency measures alone, and many areas may achieve the
final standard as well.
13. The second element will be to replace
water company lead communication pipes (the communication pipe
is that part of the service pipe owned by the water company, which
runs from the water main to the boundary of the property; the
length of service pipe beyond the boundary is owned by, and is
the responsibility of, the property owner). Where plumbosolvency
measures do not achieve the required standards, the water company
will be required to deliver a strategic programme of lead pipe
replacement of some or all of its lead pipes in the area of supply
that is not likely to meet the new standards. As time is required
for the benefits of plumbosolvency measures to be established,
it has been agreed to estimate likely requirements for lead pipe
replacement during the AMP4 period on a best endeavours basis
and to allow a financial provision within water company business
plans for these potential costs where applicable. Cost estimates
made to date vary significantly across water companies, but in
general are substantially less than originally envisaged.
Acceptability of water to consumers
14. Intermittant discoloured water events
are an irritation and concern for some consumers, and DWI is likely
to support schemes proposed by a number of water companies to
reduce consumer complaints arising from these events. The actions
proposed are relatively low cost solutions such as flushing and
cleaning.
Maintaining drinking water quality
15. DWI has chosen to not promote within
PR04 significant quality programmes of work under regulation 17(1)
of the 2000 [English] and 2001 [Welsh] Water Supply Regulations
[i.e in addition to the need to act on failure, there is a new
regulatory duty to act if a failure is likely to occur].
Instead we have:
— Encouraged development of relevant
Serviceability Indicators.
— Supported the development and adoption
of the Capital Maintenance Planning/Common Framework for estimating
maintenance requirements more accurately.
— Encouraged water companies to reappraise
how they manage their delivery of service by moving from reactive
failure-tolerant customer service to proactive preventative management
of water supplies. To date, DWI has promoted this approach through
the development of DOMS [Distribution System Operation and Maintenance
Strategies].
— Promoted making provision for maintaining
drinking water quality through the Capital Maintenance Planning
/Common Framework, to be used by all water companies as a common
basis for estimating maintenance requirements, instead of using
the powers in the Water Supply Regulations.
16. We believe this to be the most cost
effective and coherent long-term approach to take to maintaining
drinking water quality, but it assumes that water companies will
make a reasonable estimate of maintenance requirements, that Ofwat
will allow funding for those requirements, and that water companies
will deliver on what is funded. If not, there is a risk that drinking
water quality may deteriorate.
Customer Consultation
17. DWI was a contributor to stage 1 of
the joint water industry research into customers' views on water
and sewerage services in England and Wales. The research work
was wide ranging, and among its main findings was a desire by
customers for improvements in the following areas:
— maintaining the quality of coastal
and bathing waters;
— maintaining the quality of river
waters;
— protecting important areas of wildlife
and plants;
— avoiding the risk of homes and gardens
being flooded with sewage; and
— improving tap water taste and smell.
18. On drinking water quality issues the
survey noted:
— the willingness of customers to pay
more for improving the reliability of supply, tap water safety
and infrastructure maintenance;
— customers' support for further improvements
in drinking water taste and smell; and
— the high satisfaction level with
drinking water quality.
19. DWI is participating in stage 2 of the
research, which will explore customers' views on more localised
water related issues and the impact this would have on their bills.
Drinking water quality programme summary
20. A summary of the current status of the
potential drinking water quality programme is provided in Annex
1.
13 October 2003
13 IL 13/02-The 2004 Periodic Review of Prices and
AMP4-Initial Guidance. Back
14
IL 14/02-The 2004 Periodic Review of Prices and AMP4-Confirmation
of Initial Guidance. Back
15
IL 15/02-Distribution Operation & Maintenance Strategies-DWI
Requirements & Expectations. Back
16
IL 4/03-The 2004 Periodic Review of Prices and AMP4-Further Guidance. Back
17
IL 5/03-The 2004 Periodic Review of Prices and AMP4-Appraisal
Methodology for Water Company Proposals for Drinking Water Quality
Improvement Schemes. Back
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