Memorandum submitted by Waterwise (DFWMB
12)
THE DRAFT
FLOOD AND
WATER MANAGEMENT
BILL
Waterwise is an independent, not for profit,
non-governmental organisation focused on decreasing water consumption
in the UK by 2010 and building the evidence base for large scale
water efficiency. We are the leading authority on water efficiency
in the UK. We sat on the UK Environment Minister's Water Saving
Group alongside the water industry and regulators, for which we
produced, in October 2008, the Evidence Base for Large-scale Water
Efficiency in Homes.
Our aim is to reverse the upward trend in how much
water we all use at home and at work by 2010.
EXECUTIVE SUMMARY
1. Waterwise welcomes the draft Bill. As Ministers
recognise in the foreword to the consultation paper on the draft
Bill, it will help us be better prepared for the increasingly
frequent severe weather events such as floods and drought which
we will experience as a result of climate change.
2. We particularly welcome the draft Bill's provisions
to update the hosepipe ban restrictions, which are over 50 years
old. However, in addition to enabling a wider range of discretionary
uses, we would like these provisions to enable the use of time-limited
restrictions, as this would maximise the sustainability of water
usage.
3. We are disappointed that the updating of hosepipe
ban legislation is the only measure in the draft Bill which is
aimed at the more efficient use of water, but we recognise that
it is the stated intent of Ministers to use the Bill to respond
to recommendations from the Cave and Walker reviews. We set out
below further water efficiency measures which we propose for inclusion
in the Bill, including to reflect some of the Cave review's recommendations
and those which may arise from the Walker review.
4. Water efficiency continues to be one of the
most effective tools to both mitigate and adapt to climate change.
It is essential as the government seeks not only to make the UK
economy as climate-resilient as possible, but also as predicted
water shortages and population growth mean that less water will
need to go further. A step-change in water efficiency programmes,
by themselves and linked to energy efficiency retrofit programmes,
will also make a significant contribution to the green economy.
5. In this written evidence we are responding
specifically to the Inquiry's following questions:
— Are the proposals contained in the
draft bill necessary, workable, efficient and clear? Are there
any important omissions in the Bill?
— Is the proposed institutional framework
appropriate and sufficient for the enforcement of measures contained
in the draft bill?
INTRODUCTION
6. Waterwise welcomes the draft Bill. As Ministers
recognise in the foreword to the consultation paper on the draft
Bill, it will help us be better prepared for the increasingly
frequent severe weather events such as floods and drought which
we will experience as a result of climate change.
7. Water efficiency continues to be one of the
most effective tools to both mitigate and adapt to climate change.
8. For example, the heating of water for cooking,
bathing and cleaning in the home accounts for 5% of the UK's total
greenhouse gas emissions, and the UK water industry contributes
almost 1%. In this context, it is clear that wasting less water
in homes, buildings and businesses will help the government meet
its legally binding requirement to cut emissions by 80%. The government
has recognised this in policy statements such as Future Water
and in the welcome regulation it has introduced to ensure water
efficiency in new homes (including the Code for Sustainable Homes,
and the introduction of water efficiency into Building Regulations
for the first time). We are currently working with the government
to take forward water efficiency alongside its ambitious and innovative
plans to retrofit every home in the country for energy efficiency.
9. Predicted reductions in water availability
and population growth also mean that less water will need to go
further, as the UK adapts to climate change.
10. The legislative framework, including that
surrounding the regulation of the water industry, needs to reflect
the priority that water efficiency should take in the UK's climate
change armoury. It is essential as the government seeks not only
to make the UK economy as climate-resilient as possible, but also
to tackle climate change. A step-change in water efficiency programmes,
by themselves and linked to energy efficiency retrofit programmes,
will also make a significant contribution to the green economy.
11. We set out below our views on the single
water efficiency provision contained in the Bill, and on other
water efficiency measures we believe should be included in the
Bill.
UPDATING THE
HOSEPIPE BAN
RESTRICTIONS
12. We very much welcome the inclusion of a provision
in the draft Bill to enable Ministers to allow water companies
to cover a wider range of discretionary uses of water in drought-related
restrictions. This was one of the major recommendations in Waterwise's
report on garden watering restrictions, commissioned by Defra
in 2006, and will help companies better manage resources during
drought and in the long-term. It will enable the restrictions
regime to be responsive to new technological advances—pressure
washers and swimming pools were not widespread when the legislation
was originally passed over 50 years ago! We look forward to working
with the government as they develop the detail of the wider range
of uses to be covered.
13. However, we recommend that the Bill also
contain a provision for time-based restrictions on the use of
water, to maximise the effectiveness of water usage. For example,
restricting the use of hand-held hoses for watering to evenings
and mornings would waste less water as it would prevent watering
at times when evaporation is high. Restrictions could also be
set for various levels of drought—the lowest level could
include restricted sprinkler times and a total ban on watering
on Mondays, level two could allow watering on alternate days only,
during certain hours, and a third level could ban outdoor hosing
and sprinklers at any time. Alternate watering days could be staggered
by postcode or house number (odds or evens) to allow for management
of peak demand.
14. We therefore believe the enabling power should
not only cover a wider range of uses (and therefore technologies),
but should also allow for time-based restrictions.
15. Time-based restrictions on the use of water
have been used to great effect in Australia, Canada and the USA.
OTHER WATER
EFFICIENCY MEASURES
WATERWISE WOULD
LIKE TO
SEE IN
THE BILL
- We recognise that it is the stated intent of
Ministers to use the Bill to respond to recommendations from the
Cave and Walker reviews, and welcome this.
17. We are interested in the Cave review's recommendation
of a statutory duty to support innovation, particularly that which
will be in the long-term interests of consumers. Water efficiency
is clearly in the long-term interest of the consumer, as it is
a more flexible option than permanent supply-side measures which
are many years in the planning, execution and lifespan.
18. As more and more water companies carry out
larger and larger water efficiency projects—in itself innovation—the
evidence base for this will grow, and we have also proposed elsewhere
that Ofwat allow "demonstration" activity in the meeting
of the water efficiency targets, as Ofgem does in CERT: these
will help address the current comparative uncertainty attached
to water efficiency measures as against supply-side measures,
or at least how they are treated in the regulatory system. They
will help stimulate innovation in the water industry.
19. In any case, as we state above, water efficiency
will prove increasingly necessary as, in coming years, there is
less water and there are more people. If the Bill does eventually
reflect the Cave review's recommendation of an innovation duty
on Ofwat, Waterwise would like it to be specified that innovation
in this context includes new processes and techniques, as well
as new technologies—such as water companies developing the
expertise for retrofitting tens of thousands of homes for water
efficiency and energy efficiency. As well as being innovative,
this will make a significant contribution to the development of
the green economy.
20. However, Waterwise would favour a specific
duty on Ofwat to promote climate change mitigation and adaptation,
which would in itself spur innovation as water companies meet
this challenge, but would mean innovation was specifically targeted
at the main driver of government policy currently, namely 80%
cuts in emissions. By the time the Bill achieved Royal Assent
we believe it would be even clearer that it is already that this
could only mean better value to the consumer.
21. Waterwise would like to see all homes in
England and Wales fitted with water meters by 2020—supported
by tariffs to promote efficient water use and protect vulnerable
customers. Successive UK Environment Ministers since 2005 have
expressed the view that the current rateable value system of charging
is unsustainable, and that metering is the way forward. We would
like the Bill to respond to the recommendations the Walker Review
come up with on metering—specifically, we would like an
enabling provision, building on the welcome change that has been
made by the government specifically for water-stressed areas as
a result of Water Saving Group discussions, to allow water companies
to compulsorily meter across England and Wales.
22. We would also like to see the government
respond in the Bill to any Walker review recommendations on increasing
the water efficiency of homes and businesses, on fiscal incentives
and on the availability of water efficient products.
23. Finally, in our UK manifesto launched last
month (this can be found on www.waterwise.org.uk), Waterwise calls
for UK accounting rules to be amended to remove the requirement
to treat water efficiency retrofitting schemes as operational
expenditure. We would like this measure taken forward in the Bill.
This would help incentivise the water industry to treat demand
management measures equally with plans to develop new resources
such as reservoirs and desalination plants—essential in
the context of climate change, as we outline elsewhere in this
written evidence. It would also reflect the Cave review's recommendation
that Ofwat should address the potential bias towards capital expenditure.
May 2009
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