Memorandum submitted by the National Trust
(Ofwat 01)
1. EXECUTIVE
SUMMARY
1.1. The National Trust welcomes the opportunity
to contribute to this inquiry. Across the Trust's operations we
are working to use less water and improve water conservation as
part of our strategy to reduce our environmental footprint and
provide public benefit. We are also adopting an integrated approach
to catchment management, looking at the role of land use in addressing
issues of both water quality and quantity, and identifying management
techniques and land use changes which deliver multiple benefits.
1.2. We believe that PR09 offers a crucial opportunity
to:
— tackle water quality problems at
source through catchment management initiatives that offer many
benefits, not just for the environment, but also for the economy
and society.
2. THE NATIONAL
TRUST AND
WATER
2.1. The National Trust is the UK's largest
non-governmental landowner and farming organisation with 2,000
farm tenancies covering more than 250,000ha of land, including
whole catchments, hundreds of headwaters, private water supplies
and sewerage systems, salmonid rivers and major lakes. We are
also Europe's largest conservation charity. We own more than 1,100km
of coastline in England, Wales and Northern Ireland, manage more
than 10% of SSSIs in the UK, and our countryside and open space
properties receive over 100 million visits every year.
2.2. Water is a major issue for the Trust and
is a key theme of our land use work. Every Trust property depends
on and interacts with water in some way and every Trust activity
and business operation requires water of a certain quality, quantity
and consistency of supply. Achievement of large parts of our charitable
role in conserving and enhancing wildlife and the landscape is
shaped principally by the quality and quantity of water resources.
It also has a major impact on the historic significance of our
properties.
2.3. In 2005 we carried out a Water Resources
Risk Assessment (WRRA) to help operational managers understand
the significance of the water resources on their sites and to
enable them to take account of a wide range of risks and opportunities
in their long term planning. The assessment revealed that 43%
of all rainfall across England and Wales drains through National
Trust land emphasising the crucial importance of working to protect
water catchments upstream of our sites as well as managing our
impacts downstream.
2.4. The National Trust is working with
United Utilities on a PR09 bid for peatland restoration on Kinder
Scout. This project is on land owned by the National Trust but
is within a United Utilities' drinking water source catchment.
3. COMMENTS ON
OFWAT'S PRICE
REVIEW 2009 (PR09)
Management of demand
3.1. We believe that PR09 provides an important
opportunity to invest in the roll out of water metering and large
scale water efficiency measures. The provision of clean water
is frequently taken for granted, with many consumers having no
concept of how much water they use. Our work in reducing the Trust's
environmental footprint has shown that it is important to understand
how much water you are using in order to then identify ways of
using less. By installing water meters, we can introduce tariff
schemes that protect vulnerable customers while penalising waste.
It is estimated that introducing full metering and intelligent
tariff schemes to southern England could halve the deficit between
supply and demand predicted by 2030[1].
We would like to see full metering introduced, not just in water
stressed areas, but across the UK.
Management of supply
3.2. We increasingly rely on expensive and energy
intensive treatment to clean water so it's acceptable for drinking—between
2001 and 2006 the water industry made capital investments totalling
£1.94 billion for water treatment. Households and businesses
pay the costs of this through their water bills.
3.3. The Trust believes there is a need for a
more sustainable approach to water resource management, based
on investment in environmental services at a catchment scale.
By investing in land management which will deliver cleaner water
downstream, it is possible to reduce the need for energy intensive
and expensive treatment, and deliver additional environmental
and social benefits.
3.4. We welcome the commitment by OFWAT to consider
water company proposals to address drinking water issues by encouraging
changes to land management in catchments supplying raw water for
public supply as well as through engineering solutions.
3.5. Enabling and encouraging water companies
to invest in solutions that tackle water quality problems at source
provides a sustainable alternative to the current reliance on
resource and carbon intensive water treatment. We believe that
investment through Asset Management Programmes should be permitted
both in land of neighbouring land owners as well as on water companies'
own land. This should not just include designated sites (eg SACs
and SSSIs), but all land where drinking water is sourced. Not
only will this deliver multiple gains for the natural environment—including
the carbon stored in our soils—it will also benefit water
customers through reducing the need for expensive `end of pipe'
treatment of drinking water. PR09 provides a vital opportunity
to set a precedent and deliver a progressive and more rational
framework for water company investment.
Comments on review process
3.6. Our experience would suggest that the
price review is overly bureaucratic—if projects don't tick
the right boxes, they don't get through. For example, because
the land covered by our joint bid with United Utilities is not
owned by the water company, the project cannot be included within
the National Environment Programme (a list of projects put forward
by EA which require funding through the price review to meet statutory
objectives) despite its self evident environmental contribution.
It has been recognised, however, by the Drinking Water Inspectorate
because of its contribution to clean water. We would suggest that
a more flexible approach is needed to encourage innovation within
water industry. This also needs to encourage more use of non-water
company land, as we have proposed with United Utilities on Kinder
Scout.
3.7. We are also concerned that the economic
climate will lead to environmental schemes being cut—catchment
schemes will take time to deliver benefits and are not infallible,
but they are a far more sustainable alternative and will deliver
a range of benefits (not least helping mitigate climate change
through carbon storage in soils). They will also lead to significant
cost savings in the longer term. On average, the environmental
improvements proposed in draft business plans will cost the consumer
less than 1p a day.
Links with Floods and Water Bill
3.8 We believe the forthcoming Floods and
Water Bill provides an important opportunity to reform the water
industry, such that water companies become providers of a water
service, rather than water being treated as a commodity. A Water
Efficiency Commitment, placing an obligation upon water companies
to incentivise water saving and introducing a water service rather
than a water supply culture would be an important step forward.
3.9. We also suggest the Bill provides an opportunity
to place a duty on water companies to manage their landholding
to protect and enhance raw water quality. This duty would provide
a statutory footing for projects like United Utilities' Sustainable
Catchment Management Project (SCaMP) and operationalise policy
statements in Defra's Future Water. While it would be inappropriate
to extend such responsibilities beyond a company's landholding,
it would be helpful to place a duty on water companies to promote
sensitive land management in catchments they have an interest
in, thereby encouraging a more positive and partnership based
approach.
National Trust
February 2009
1 From "Blueprint for Water: 10 steps to sustainable
water by 2015"-www.blueprintforwater.org.uk Back
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