Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by the Royal Society for the Protection of Birds



    —  A combination of rising numbers of households, increased per capita demand and poor raw water quality is putting pressure on water resources. Climate change will increase these pressures.

    —  The aquatic environment is in a poor state, with over 45% of freshwater Sites of Special Scientific Interest (SSSIs) in England in unfavourable condition, partly because of water scarcity. Decisions taken on water resource management over the next few years will determine whether climate change has a devastating impact on an already degraded aquatic environment.

    —  Current policy and practice is inadequate to meet the challenges posed by climate change. Land-use planning is not linked to water scarcity, demand management and leakage control are poor, strategic management of abstractions is lacking, and water company plans focus on the development of new resources to the exclusion of other more sustainable approaches.

    —  The Water Act 2003 is a step forward, introducing new measures to encourage efficient use of water by all abstractors and conservation of water by public authorities. However, much more must be done to mitigate the effects of climate change and increased housing development.

    —  This must include land-use planning that recognises environmental limits, robust action on demand management, greater efforts in leakage control, and the integration of water-efficient design into housing and industry. Where new resources are developed, these must be linked to demand and leakage controls and demonstrably necessary to secure public water supply.

    —  Where water storage schemes are required, damage to existing nature conservation interests must be minimised, and the benefits for wildlife maximised, including reductions in abstraction in environmentally sensitive areas.


  1.  The RSPB works for the conservation of wild birds and their environment. We are Europe's largest wildlife conservation charity, with over one million members. We manage one of the largest conservation estates in the UK, totalling more than 125,000 hectares, including extensive freshwater and coastal wetland habitat. We provide advice on the management of wetland habitats, and contribute to the development of policy on a wide range of water policy issues including water resources, biodiversity, water quality and flood defence.

  2.  Wetlands are fragile ecosystems, dependent on the way water is managed, and much remains to be done to achieve sustainable water management. Action is planned under the fourth periodic review to tackle some of the impacts on aquatic habitats from water company abstractions, but more will be necessary as the Environment Agency and English Nature complete their review of consents near or on internationally important wildlife sites. In the medium term, a move is needed to a system of water resource management that allocates abstractions strategically to maintain supply and prevent environmental damage, and actively promotes the efficient use of water.


  3.  Whilst, due to historical emissions of "greenhouse gases", some degree of climate change is inevitable, measures should be taken to reduce emissions of these gases and, therefore, minimise the impacts of climate change over the next fifty years and beyond. The RSPB supports the Government's targets, set out in the Energy White Paper (2003), to cut UK carbon dioxide emissions by 60% by 2050.

  4.  Current estimates of climate change suggest that, by the 2020s, there will be on average more winter rainfall and less summer rainfall throughout England. Higher temperatures mean that potential evaporation rates will probably increase.

  5.  There is also evidence that climate change will increase the year-to-year variability of rainfall. Effectively, this means the climate will be less predictable, with both more dry years and more wet years. While drought years will be more likely, evidence about the possibility of longer droughts is unclear and increased weather variability may make droughts that last over several years slightly less likely. However, it is important to note that the understanding of changes in extreme climate events is more limited than that of changes in average climate.

  6.  Higher temperatures and a probable reduction in soil moisture will cause a reduction in the period of groundwater recharge (ie the period in which groundwaters are "topped up" in the winter and early spring). This could have serious implications for those regions of England that rely on groundwater sources (the south-east relies on these for 60% of its water, while the figure is up to 90% on parts of the south coast). Paradoxically, there are likely to be increases in winter rainfall which could provide greater security of water supply for those regions that draw most of their water from reservoirs (the north and west of England).

  7.  Higher temperatures are also likely to lead to higher consumption levels, putting pressure on supplies at times when water availability is lowest. Higher human water demands will make it difficult to maintain licensed summer abstractions from either surface or groundwater, putting great pressure on both irrigators and wetland managers.


  8.  Biodiversity is already under stress in the water environment, with large declines recorded in breeding wading birds of wet meadow habitats (including a 60% decline in the population of snipe), decreases in the number and diversity of aquatic fly populations (with knock-on impacts on fish populations), and reductions in the diversity of aquatic flora.

  9.  The impacts of unsustainable water abstractions are being felt on up to 400 river and wetland sites in England and Wales, while poor river water quality (from excessive concentrations of phosphates and nitrates derived from sewage and agricultural sources) has profound impacts on the vegetation composition, invertebrate and fish populations of lowland rivers. In the future, more sites are likely to be affected as the pressure on public water supplies increases.

  10.  These trends will be exacerbated by climate change, which is likely to lead to increases in the duration of soil moisture deficits (putting further pressure on breeding wading birds) and more years in which river stretches suffer from low flows. These low flows will, in turn, increase water quality problems (by concentrating pollutants and reducing dilution).

  11.  This analysis should be seen in conjunction with work undertaken at Cambridge University, looking at possible impacts of climate change on the distribution of birds, including a range of wetland species. This research predicted substantial northerly and westerly movements in the core range of a number of species, linked to earlier vegetation growth (limiting nesting opportunities) and reductions in soil moisture (reducing prey availability).

  12.  Any increase in abstraction of water from the environment to meet increased demand is likely to prevent the UK's network of internationally and nationally important wetland sites from meeting their conservation objectives and make legally binding targets for biodiversity conservation unachievable.

  13.  The Environment Agency, in its 2001 Water Resources Strategy, attempted to calculate the likely reductions needed in current levels of abstraction to restore abstraction to sustainability and ensure favourable condition of the water environment. It calculated that, by 2010, this would need to be in the order of 257 million litres per day, and by 2025, 716 million litres per day. This may seem to be a large amount, but it is dwarfed by the current levels of water company leakage, which in 2002-03 amounted to 3,623 million litres per day.


  14.  The latest government projections show an increase of 3.3 million households in England and Wales between 1996 and 2016. This is largely due to the trend towards smaller household size, as the total population is predicted to grow by no more than 2.8 million over the same period. Much of this increase is expected to take place in the already relatively water scarce south and east of England.

  15.  Population change influences the demand for and provision of water services. Firstly, more households will demand more water. Secondly, expanding urban populations place extra strain on the sewage and drainage infrastructure, which in most cases was not designed to cope with the volumes of waste generated by modern cities.

  16.  New development can have a dramatic impact on local and regional water resource availability, potentially requiring large-scale investment in new resources and maintaining already unsustainable levels of abstraction from the environment.

  17.  Maps published in the Government's Water Strategy document "Directing the Flow", and in the Environment Agency's 2001 Water Resources Strategy, show that most "resource zones" in the south and east of England are already classified as having unacceptable or unsustainable abstraction rates. With the additional pressures from predicted housing growth and climate change, this situation can only worsen, unless there is substantial investment in water efficiency for both new-build and existing housing stock and industrial/commercial buildings.


  18.  The Government's Water Act (2003) included some welcome measures to encourage water efficiency and sustainable abstraction, recognising the challenges posed by climate change and housing development in water scarce areas. All abstractors of water were given a duty to use that water efficiently, and public bodies (such as local planning authorities) will be encouraged to make water conservation a key element of their operations. However, given the scale of the problems facing the water environment and the way demand for water has risen over recent decades, the Water Act can only be seen as a start, and much more must be done.

  19.  In southern England, The Environment Agency has been working with the Regional Assembly to model and estimate the effects of levels of housing growth on public water supplies. Government statements have suggested that 30% more housing than planned for in regional planning guidance may be required. The results of the modeling are stark. Even with planned water resource developments, more than three-quarters of the south-east's water resource zones will be in summer deficit (many by several millions of litres per day) by 2025. Engineering solutions to this deficit, in addition to being hugely expensive and potentially environmentally damaging, may not be available, as neighbouring water resource zones have very little surplus, and many are also in deficit.

  20.  Despite these warnings, and the Government's apparent commitment to "sustainable communities", little thought appears to have been given to the critical issues of water availability and demand management. Studies suggest that water efficiency savings of between 30 and 50% are possible in new-build houses (compared to building regulations standards) through the introduction of simple, tried and tested water efficiency and demand management measures, such as water efficient appliances, grey water recycling and rainwater harvesting.

  21.  The Greenwich Millennium Village, for example, aims to achieve a saving of between 30 and 35% compared to conventional housing through simple means such as dual flush toilets, efficient taps, efficient showers and grey water recycling. Gusto Homes, the winner of the Environment Agency's 2003 water efficiency award, has achieved 50% savings at its development in Newark. The Stirling Prize runner-up, BedZed in south London (built for and managed by the Peabody Trust), has so far achieved average water efficiency savings of between 50 and 60% compared to average per capita consumption. Such development has to become the norm rather than the exception if supply deficits and environmental damage are to be averted.

  22.  If change is to be effected in reality, government must insist that ambitious minimum performance standards are adopted and strictly enforced in new developments. 30% water savings should be a minimum requirement, with 50% the target, achievable and realistic with the significant economies of scale afforded by the major "sustainable community" housing developments.


  23.  The regime governing water abstraction and supply in England does not facilitate the protection of water resources. No one body is responsible for achieving reductions in water use. As a consequence, the UK has fallen behind many other European countries in its approach to dealing with water scarcity. Per capita water consumption has increased steadily since 1970, despite the major reductions in leakage achieved by water companies during the 1990s, and the fact that the UK's population has remained relatively static. In contrast, Germany reduced its household water consumption by 8.5% between 1991 and 1998 while the amount of water abstracted from the environment declined by 11.4%. If similar shifts could be achieved in England, then the concerns of the RSPB and similar organisations over climate change and water availability would be substantially reduced.

  24.  The Environment Agency is required to produce water resource strategies, balancing current and future needs and environmental impacts. However, the Agency has little influence over spatial planning and building regulations, and is further hampered by a system of permanent abstraction licences, which has prevented it achieving a sustainable abstraction regime. The 2003 Water Act was designed in part to address these problems. However, the implementation of its provisions will require firm action on the part of the Government and the Environment Agency to secure the conversion of permanent into time-limited licences (and the Government resisted calls for a statutory mechanism in the Act to ensure that permanent licences would be converted to time limits).

  25.  Water companies have responded to climate change and possible supply deficits by proposals for cross-catchment transfers, new reservoirs and the construction of desalination facilities around the south coast. They submitted their 25-year water resource plans to the Environment Agency in 2003. The emphasis on new resource development was alarming, when so little attention was given to tackling leakage (indeed some companies proposed allowing it to rise) and restraining public demand. In southern England alone, the water companies have plans for six new reservoirs and eight desalination plants.


  26.  A combination of rising numbers of households, increased per capita demand and poor raw water quality is putting pressure on water resources. These trends will be exacerbated by climate change. An integrated approach to water, planning and related policies is essential if the UK is to be prepared for water scarcity problems—and all of the associated environmental, social and other implications—which are likely to accompany climate change. In particular, government, the Environment Agency and water companies will need to adopt a more strategic approach to water resource planning that includes demand management, leakage control and the development of new resources only where necessary and appropriate.

  27.  Action must be taken now to ensure that the provisions of the Water Act are fully implemented, by producing and following a "road-map" for the conversion of permanent to time-limited licences. This will allow the Environment Agency to implement catchment-scale abstraction allocation, and protect long-term security of supply.

  28.  Land-use planning should be more effectively linked to water availability. In the medium term, this will be essential to deliver the requirements of the Water Framework Directive, and could be secured by creating appropriate powers and duties for the Environment Agency and local authorities under the River Basin Planning regime.

  29.  In order to mitigate the effects of climate change on water resources there needs to be a more concerted push to restrain and reduce consumer demand. Charging by volume used (through metering) must become the accepted norm as soon as practicable, and the Government must be more pro-active in promoting metering, which it has stated it supports, but is currently doing relatively little to advance. We recommend that water meter installation should be targeted initially at water resource zones that are predicted to be in summer deficit by 2025 and/or to zones already showing environmental stress.

  30.  RSPB research has shown that vulnerable groups (the poor, sick and elderly) can be protected from excessively high water bills in a situation where metering is the norm through the use of tariffs that provide a low-cost "essential use" block of water with progressively higher blocks for further non-essential use. Users requiring more water for medical reasons would be allocated additional low-cost blocks. Such a system would have the merit of providing a substantial disincentive for "luxury" use by ensuring that tariffs rose steeply on use over and above basic domestic needs. The establishment of a "Water Savings Trust", to promote water efficiency and the installation of water-efficient technologies in homes and industry should be seen as an essential companion to any adopted metering strategy.

  31.  Despite these measures, there may be places where the development of new resources to secure public supply is necessary. However, such developments generally have serious environmental consequences, and so should be regarded as the last, rather than the first, resort of water resource planners. Reservoir construction is likely to impact directly on the areas allocated for storage, but also indirectly on areas from which water is sourced and transferred. Summer abstraction will reduce dilution rates and water quality, and damage plants and animals dependent on inundation. Winter abstraction may alter down-stream siltation rates and salinity gradients, with resulting consequences for wildlife.

  32.  The environmental costs and benefits of creating additional water storage capacity should be thoroughly and strategically reviewed. Such additional capacity should be opposed where it is not clearly linked to demand and leakage controls, where it is not essential to meet public water supply, and where it damages nature conservation interests. Where schemes for creating additional capacity are the most appropriate means to address water shortages, it is essential that benefits for wildlife are maximised and that reductions on abstraction in environmentally sensitive areas are sought.

Royal Society for the Protection of Birds

April 2004

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