Memorandum submitted by Water UK
INTRODUCTION
1. We are pleased to have the opportunity
to submit written evidence to the Committee for its second inquiry
on sustainable housing, in the light of the Government response
to its predecessor Committee report "Housing: Building a
Sustainable Future" and the ODPM's Five Year Plan "Sustainable
Communities: Homes for All", published earlier this year.
The Committee's focus is very welcome, and can only assist the
process of ensuring clarity of responsibility and delivery in
this very important area of Government activity.
2. The inquiry recognises the importance
of the sustainable communities' policy to the delivery of Government
objectives for the economy, building on the recommendations of
the Barker Review undertaken for the Treasury in 2004. This in
turn recognises the European emphasis on building a knowledge-based
economy, espoused in the Lisbon Agenda. This must include a flexible
workforce, able to respond to market needs for highly skilled
labour. The provision of pleasant, affordable housing in areas
where people want to live and work is part of that.
3. Water UK is the representative body for
the regulated water businesses in the UK. We are a policy-based
organisation and represent the industry's interests with Government,
regulators and stakeholders in the UK and in Europe.
4. Clearly our industry has a key role to
play in delivering the infrastructure required to support the
development of sustainable communities in the four growth areas
already identified, and beyond.
5. Water companies have a statutory duty
to supply clean drinking water in the Water Industry Act 1991,
and to ensure a reliable consistent supply regardless of cost,
environmental considerations and availability of resources. They
are also under a statutory duty to drain their areas; this includes
both surface water drainage and the drainage of foul water and
waste from domestic and business premises.
6. Water UK has a direct interest in two
of the four issues the inquiry is addressing—the code for
Sustainable Buildings, which includes energy efficiency and water
efficiency, and Infrastructure, in which the provision of water
mains and sewers are relevant. Both these issues are addressed
in turn below:
A. THE CODE
FOR SUSTAINABLE
BUILDINGS
1. Can a voluntary code possibly deliver
the degree of change needed in the building industry to achieve
well-designed, energy efficient sustainable buildings which have
minimal impact on the local environment?
2. Is the Government doing enough to
promote the code, with the industry and the general public, ahead
of its imminent introduction in early 2006?
3. Should the Government be introducing
fiscal measures to reward higher building quality and greater
environmental performance?
(i) We welcome the development of the Code
for Sustainable Buildings, but are concerned that insufficient
attention is being paid to it. It is still being developed and
many are confused about its aim and purpose.
(ii) We would like to see the Government
consider the use of a standards "kitemark" for buildings
that meet the standards laid down in the code. This approach would
have some difficulties, not least because it would be difficult
for one building to meet all the code's standards. However, it
is an approach worth considering, but would need to address the
issue of partial conformity, possibly by adopting a star rating
system related to compliance, or something similar, as for electrical
appliances.
(iii) The general public is becoming more
environmentally aware and we think there would be mileage in such
a scheme. More research is needed to assess how much premium people
would be willing to pay, if any, for the benefits of the scheme.
Fiscal incentives such as a reduction in stamp duty could also
be considered. In our view there would be substantial benefits
for the economy in terms of improving energy efficiency, and as
a tangible contribution to the Government's targets for sustainable
development, as set out in the Sustainable Development Strategy
published by Defra in March this year.
(iv) We understand that the Code will relate
to water efficient fittings and fixtures—for example, low
flow shower heads and efficient plumbing runs with lagging of
hot water tanks. In order for it to be effective in this respect,
to protect water resources and the water environment, we recommend
the following be considered for inclusion;
— It should include water efficient
equipment such as dishwashers and washing machines which are often
included in the price of new houses. These machines normally use
less energy as well.
— Energy and resource efficient taps
and bathroom fittings such as dual flush cisterns, which will
help to use less water and reduce wastage (according to the Environment
Agency, dripping taps can waste up to four litres of water a day).
(v) There are also opportunities within
some new buildings to address grey water re-use and the use of
rainwater. This is an area of technology so far not developed
to its potential, particularly in large scale applications. As
Water UK pointed out in its oral evidence to the House of Lords
Select Committee on Science and Technology Inquiry into Water
Management (15 November). We believe that more should be done
by the Government to promote this—it is too good an opportunity
to miss. For example as a minimum, new houses should always have
a water butt for garden watering, for flushing .and grey water
could be considered to flush toilets if practicable.
(vi) We would also like the Code to cover
surface water drainage issues. For example, wherever possible
roof and driveway water should be discharged to soak away or at
least the flow rate should be attenuated before discharge to the
public surface water drainage system. Green roofs are particularly
effective in this respect. Soakaways would be preferable, allowing
replenishment of groundwater whilst reducing the risk of surcharging
and hence flooding downstream.
(vii) Non-permeable areas in new developments,
such as car parks, hard standings etc should be kept to a minimum
to reduce the volume of run-off, particularly during intense rainfall
events. Such measures reduce the risk of surcharging and hence
flooding, and also reduce the quantities discharged at combined
sewer overflows which may pollute the environment. This would
also reduce the extent of diffuse pollution from contaminated
surface water running into watercourses through the surface water
drainage systems. The use of the existing automatic right of building
connection to the public sewer (section 106 of the Water Industry
Act 1991) for surface water should also be amended or repealed.
This right leads not only to the pollution of inland waters but
also the overloading of existing sewerage systems and downstream
foul flooding of property. Repealing this right would lead to
greater take-up of sustainable drainage systems—retention
basins, infiltration trenches, swales and soakaways.
(viii) Building materials, such as those
used in roof construction, can slowly dissolve and cause water
pollution from polluted run-off from interaction with rainwater.
Consideration should be given to the use of more sustainable forms
of construction. Some of the substances used in roof construction
eg copper, zinc and lead compounds can be expensive to remove
or cause environmental damage.
(ix) Finally, we are concerned about the
increasing tendency in recent years to permit development within
the flood plain. This echoes similar concerns expressed by the
Environment Agency. There is insufficient sewer capacity, especially
in the older metropolitan areas, to cope with large volumes of
surface water run-off and this exacerbates the problems of property
flooding and large river flooding downstream. However, if new
homes are to be built in areas prone to flooding, they should
at least be designed to cope, and include as standard design preventative
measures such as door gates and flood resistant underfloor vents;
as well as precautions such as high level electrical sockets.
Developers should also be required to ensure loss of flood plain
capacity resulting from their development does not cause additional
property flooding downstream.
D. INFRASTRUCTURE
7. Is the Government doing enough to secure
sufficient funds for the timely provision of infrastructure, such
as transport links, schools and hospitals in the four Growth Areas?
8. Are the water companies doing enough to
secure the supply of water resources to the four Growth Areas?
And is concern about security of water supply, in the South East
of England in particular, a valid one or simply a knee jerk reaction
to a few hot, dry summers?
9. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
(i) In recent months, Government has demonstrated
a greater understanding of the need to ensure provision of water
and wastewater services. The indigenous water resources in all
of the sustainable communities' areas have effectively been fully
developed. An analysis in companies' Water Resources Plans in
2004 demonstrated the need for water resource development, alongside
demand management, to meet the existing forecast of growth in
the South and East of England, without the 50% acceleration in
the growth rate likely to result from the Government's current
proposals. These areas coincide with high population density areas
in the east and south east of England, where land is also scarce.
(ii) We believe that lack of water and wastewater
services should not be a constraint to economic development. These
services can be provided, but at a higher cost as more sophisticated
engineering solutions may be required in some circumstances.
(iii) The water industry's current investment
programme has been funded to secure the supply-demand balance
through charges to existing customers and, where possible, seeking
contributions from developers. Increasing the planned growth rate
will use up the available headroom [the difference between supplies
and demands required to maintain the security of supplies] and
advance the need for more investment. The cost of providing these
services in terms of the overall economic context of the Sustainable
Communities proposals is relatively low. But in terms of water
bills for customers in those areas, these additional costs could
be very significant. This may not be acceptable to customers,
or to politicians, in the short to medium term. This is a difficulty
that needs to be faced collectively by Government, the industry
and its regulator.
(iv) Developing these resources will need
to be funded within the existing structure of a five-yearly price
review and 25-year water resources plans. Due to a combination
of water resource pressures and increased population demands,
the water industry will be faced with a situation, unique since
privatisation, where it will have to build reservoirs and other
engineering solutions.
(v) In addition, the challenge of the Water
Framework Directive will mean new water quality and environmental
objectives have to be achieved. Therefore funding for new schemes
is only part of the picture and consideration will also have to
be given to the delivery of outcomes in terms of the planning
process. We believe a long term strategic planning framework and
closer alignment of timetables for investment funding, price determinations
and environmental planning mechanisms will be needed.
(vi) The water industry is not a statutory
consultee in the planning process, and as Water UK's oral evidence
to the House of Lords Science and Technology Select Committee
clearly indicated, the process of engagement with the ODPM on
the sustainable communities plan was initially slow. Water companies
can only plan and make sound investment decisions if provided
with timely and accurate information on the location, size and
timing of new communities. We would like to be closely involved
from inception, not to constrain development taking place but
to be able to contribute and develop the best solutions to deliver
water and wastewater services.
(vii) The process of regional development
planning clearly plays a key role in this and we are encouraging
our member companies, particularly the ten water and sewerage
undertakers, to be involved from the very beginning.
(viii) As a consequence of all the pressures
identified above, there will be an increasing need to promote
water efficiency measures. The current water resources situation
in the south of England is the result of a significant period
of below average rainfall. This has been managed effectively up
until now with the use of the appropriate restrictions on water
use that are included in companies' approved Drought Plans. The
industry also reminds its customers of the need for responsible
water use during periods of exceptionally hot dry weather where
potential demand exceeds supply.
(ix) Water UK is promoting the more efficient
use of water through a separately funded body called waterwise,
which is also giving support for initiatives for more water efficient
design and specification in buildings, and for developing more
sustainable living habits in communities. Both Water UK and waterwise
are members of a group set up by Defra Ministers, the Water Savings
Group, which is looking at water efficiency initiatives across
Government and regulators.
(x) We would support a greater focus by
Government through education in schools to develop and understanding
of water conservation alongside energy use and waste minimisation
and recycling.
(xi) Clearly, the Environment Agency plays
a key role in promoting sustainable development through both education
and regulation. We would like to see an increased focus in the
discharge of its regulatory functions, including its new sustainable
development duty, used to facilitate sustainable development,
taking account of economic and social needs alongside those of
the environment.
CONCLUSIONS
Code for Sustainable Buildings
— We welcome the development of the
Code for Sustainable Buildings and would like the Government to
consider the use of a standards kitemark for buildings that meet
the standards laid down in the Code.
— We believe that research is needed
to assess the premium people willing to pay, if any, for the benefits
of the scheme. Fiscal incentives should also be considered.
— The Code should promote the use of
water efficient fixtures and fittings.
— The Government should consider using
the Code to promote grey water re-use and to address surface water
drainage issues.
— When development in the flood plain
is proposed, the resulting increase in volumes of surface water
run off and flooding downstream need to be taken into account
in the planning process.
INFRASTRUCTURE
— Water resources are already scarce
in areas where sustainable communities are proposed.
— A lack of water and wastewater services
should not constrain economic development, but the additional
costs of providing the infrastructure need to be addressed.
— Balancing both sides of the supply-demand
balance may mean more large scale investment in engineering solutions—the
implications of this need to be identified and considered.
— The Water Framework Directive will
mean new water quality and ecological objectives have to be achieved.
— The water industry needs to be involved
in the development of sustainable communities from inception if
it is to contribute to sustainable solutions to the provision
of water infrastructure and resources.
— All parties to the development of
sustainable communities need to promote water efficiency -the
water industry wants to play a full part in this.
December 2005
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