Memorandum submitted by the Environmental
Industries Commission (DFWMB 19)
Thank you for the opportunity to provide evidence
to the Committee concerning the Draft Flood and Water Management
Bill.
EXECUTIVE SUMMARY
1. EIC was launched in 1995 to give the
UK's environmental technology and services industry a strong and
effective voice with Government. With over 300 Member companies,
EIC has grown to be the largest trade association in Europe for
the environmental technology and services (ETS) industry. EIC's
Water Pollution Control Working Group represents over 80 companies,
providing expertise and technologies in water pollution control
and the sustainable management of water resources.
2. EIC is concerned that the Draft Flood and
Water Management Bill does not adequately promote the use of Sustainable
Urban Drainage Systems (SUDS).
3. EIC believes that the Bill should more
fully address this issue, by requiring:
(i) Local authorities to take a more proactive
role in promoting the use of SUDS. This is particularly important
as part of the process of considering major new development schemes.
(ii) Ofwat to recognise SUDS as part of Water
Company Assets for the purposes of Ofwat financial settlements.
(iii) The National Policy Statement for water
infrastructure drawn up under the Planning Act 2008 to promote
and take into account the use of SUDS and water efficiency measures.
4. EIC also believes that Building Regulations
and planning guidance should include a presumption in favour of
the use of SUDS in new building developments.
5. Whilst clearly flood risk is an important
issue, particularly in the light of climate change, there is also
a need to focus on the water aspect of adaptation to climate change,
and on quantitative issues concerning availability of future water
supply and the efficiency of water use.
6. EIC believes that companies need greater
incentives, through Ofwat regulation, to invest in innovation
in treatment processes, energy efficiency, and leakage and water
efficiency activities, as there is little evidence that competition
is currently delivering sufficiently rapid innovation in these
areas.
ENVIRONMENTAL INDUSTRIES
COMMISSION (EIC)
7. EIC was launched in 1995 to give the
UK's environmental technology and services industry a strong and
effective voice with Government. With over 300 member companies,
EIC has grown to be the largest trade association in Europe for
the environmental technology and services (ETS) industry. It enjoys
the support of leading politicians from all three major parties,
as well as industrialists, trade union leaders, environmentalists
and academics.
8. EIC's Water Pollution Control Working Group
represents over 80 companies, providing expertise and technologies
in water pollution control and the sustainable management of water
resources.
SUSTAINABLE URBAN
DRAINAGE SYSTEMS
9. EIC's concerns about the Draft Flood
and Water Management Bill centre on what we consider to be inadequate
current arrangements for promoting the use of Sustainable Urban
Drainage Systems (SUDS), and our view that the Bill should more
fully address this issue, and should establish an effective set
of new arrangements.
10. The details of SUDS differ, but in general
Sustainable Urban Drainage Systems can be seen as systems that
are in some way in between reliance on engineered drainage systems
and reliance on purely natural drainage.
11. SUDS, where successfully implemented,
can achieve the following objectives:
(a) reducing the risk of flooding, through increasing
the capacity of land to absorb water;
(b) reducing the risk of contamination of water;
and
(c) increasing the sustainability of water use,
thereby avoiding the risk of inadequate quantities of water being
available to meet future demand, and also tending to reduce any
requirements for new reservoir construction, and its financial
and other costs.
12. EIC is concerned that the Pitt Review
did not give adequate attention to the potential for SUDS schemes
to reduce the risk of flooding. We believe that this should be
remedied in the drafting of the Bill.
13. EIC would like to see amendments to
the Draft Bill to increase the amount of consideration given to
the potential for SUDS schemes, and to make the implementation
of SUDS more widespread, both within specific development schemes
and through local authority planning more generally. These amendments
would be consistent with the overall purpose of the Bill as currently
drafted.
14. In addition, whilst clearly flood risk
(highlighted in the Pitt Review and in the Draft Bill) is an important
issue, particularly in the light of climate change, there is also
a need to focus on the water aspect of adaptation to climate change
(referred to in the Stern Report), and on quantitative issues
concerning availability of future water supply (issues raised
particularly by the Environment Agency) and the efficiency of
water use. We do not believe that these aspects of water management
have received sufficient consideration in the drawing up of the
Draft Bill. Consideration of these aspects strengthens the case
for the more widespread implementation of SUDS.
DEFINITION OF
"SUSTAINABLE DRAINAGE"
15. EIC would like to see an addition to
the definition and aims of "sustainable drainage" in
Clause 219, to add "increasing the efficiency of the use
made of available water".
ROLE OF
LOCAL AUTHORITIES
16. Although we welcome the role it is proposed
should be given to local authorities regarding approval of drainage
systems, EIC would also like to see local authorities required
to take a more proactive role in promoting the consideration and
implementation of Sustainable Urban Drainage Systems, and in drawing
together stakeholders for this purpose. This is particularly important
as part of the process of considering major new development schemes.
This should be achieved through an additional clause to require
local authorities to draw up Surface Water Management Plans.
17. This additional duty on local authorities
should be integrated with their responsibilities concerning climate
change adaptation, in order to encourage a joined-up approach
to water management issues. This should be approached through
requiring local authorities to have regard, when carrying out
their duties under a new Flood and Water Management Act, to Statutory
Guidance on adaptation to be issued under the Climate Change Act
2008.
18. There will be a need for increased specialist
staff dealing with water issues in local authorities, and a need
for training in order to provide staff with the necessary skills.
NATIONAL POLICY
STATEMENT
19. It is important that any quantification
of expected future demand for water, and expected future need
for reservoir capacity, should take into account the potential
for the more sustainable use and re-use of available water; and
that any decisions about the need for new reservoir capacity should
be considered in a joined-up way alongside decisions and policy
about SUDS, water efficiency, and the water aspect of climate
change adaptation.
20. EIC therefore believes that the National
Policy Statement for water infrastructure to be drawn up under
the Planning Act 2008 should be worded so as to promote more efficient
use of water resources, promote the use of Sustainable Urban Drainage
Systems, and take water efficiency, climate change adaptation,
and SUDS into account in its assessment of future demand for water
and reservoir capacity. This should be provided for by an obligation
about the drawing up of the NPS, given to the Minister through
an additional clause in the Flood and Water Management Bill.
OFWAT
21. An additional clause in the Bill should
require Ofwat to recognise SUDS as part of Water Company Assets
for the purposes of Ofwat financial settlements. Currently there
is little incentive for water companies to take part in SUDS schemes.
22. We note the Government's intention to
consider including in the Bill provisions on competition and innovation
in water markets, following the Cave Review. EIC believes that
companies need greater incentives, through Ofwat regulation, to
invest in innovation in treatment processes, energy efficiency,
and leakage and water efficiency activities, as there is little
evidence that competition is currently delivering sufficiently
rapid innovation in these areas. The Bill should include an amendment
to Ofwat's duties so that they have an obligation to promote a
more long-term (20 years or more) approach by water companies
to their investment programmes. Ofwat should also actively assess
water companies' proposals for their encouragement of environmental
innovation.
23. EIC supports the Cave Review's recommendation
to establish an early stage public research and development programme
for the water industry and water management, although we believe
that this should be co-ordinated by Defra rather than Ofwat.
HOME BUYERS'
INFORMATION PACKS
24. Home buyers' information packs should
include information about drainage arrangements, including any
use of SUDS.
BUILDING REGULATIONS
25. Building Regulations should be amended
to include a presumption in favour of the use of SUDS in new building
developments.
PLANNING GUIDANCE
26. Planning guidance should be amended
to include a presumption in favour of the use of SUDS in new building
developments.
27. Housing density guidelines in planning guidance
should be reviewed in the light of the need for greater use of
SUDS.
May 2009
| 
