Memorandum submitted by Waterwise (ACC06)

Waterwise is an independent, not-for-profit, non-governmental organisation focused on decreasing water consumption in the UK and building the evidence base for large scale water efficiency. We are the leading authority on water efficiency in the UK. We were the only NGO to sit on the UK Environment Minister's Water Saving Group alongside the water industry and regulators, for which we produced 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. We work with governments, regulators, water companies, retailers, manufacturers, housing providers, NGOs, faith groups and other partners to deliver that aim.

Executive Summary

1. Water efficiency is a key tool in adapting to climate change. The 2009 UK Climate Impact Programme scenarios show clearly that we can expect less water to be available in coming years, and this, combined with demographic changes, means that less water is going to need to go further. Water efficiency is also a key tool in climate change mitigation.

2. Every sector of the economy is dependent on water, and water efficiency must be a key part of the adaptation strategy of any organisation.

3. Waterwise welcomes the Adaptation Reporting Power in the Climate Change Act, the setting up of the Adaptation Sub-Committee, and the commitment to Adaptation Plans for all government departments by spring 2010. We also welcome the work of the Adapting to Climate Change (ACC) Programme, in developing the National Adaptation Programme, including at local and regional level.

4. The government, regulators and water companies have all taken welcome steps in recent years to increase the water efficiency of new homes (through the Code for Sustainable Homes, and the introduction of water efficiency into Building Regulations this year), to increase metering (currently only a third of homes in England and Wales pay their water bills according to the amount they use), and to retrofit increasing numbers of homes.

5. However, water efficiency is neither mainstreamed across the economy, nor mainstreamed in the processes and procedures of government. The water efficiency of existing housing has not yet been sufficiently addressed. And opportunities to drive water efficiency alongside energy efficiency, development of the low-carbon economy and other climate change mitigation policies and strategies are often missed. Water efficiency must be a central part of every sector and organisation's adaptation plans. In the past, Waterwise has observed - across the economy - costly solutions being considered and taken forward before simple measures to waste less water have been exhausted.

6. Below, we set out proposals to rectify this, and to ensure the full contribution of water efficiency to the resilience of the UK economy to climate change is realised.

 

Introduction

7. Water efficiency is unique in that is a key tool in both climate change adaptation and mitigation.

8. The 2009 UK Climate Impact Programme scenarios show clearly that we can expect less water to be available in coming years, and this, combined with population growth, rising household consumption of water, an increase in single-person households, which use more water per person, and much-needed new homes in water-stressed areas, means that less water is going to need to go further.

9. In addition, the heating of water in homes and businesses and the pumping and treating of water and wastewater by the water industry all have a significant carbon footprint - the heating of water in homes for cooking, bathing and cleaning accounts for 5% of the UK's total greenhouse gas emissions.

10. So wasting less water has dual benefits to the UK, helping to deliver both a climate-resilient economy, and government programmes to tackle change (and to meet the legally binding commitment to reduce carbon emissions by 80% by 2050).

11. Every sector of the economy is dependent on water, and water efficiency must be a key part of the adaptation strategy of any organisation.

Water efficiency in homes

12. The government has taken some extremely positive steps in recent years to ensure the water efficiency of new homes - including through the Code for Sustainable Homes, and the introduction of water efficiency into Building Regulations for the first time. However, two thirds of the dwellings that will be in use in 2050 already exist, and the broader challenge of making existing housing stock water efficient has not yet been sufficiently addressed.

13. The government is taking forward measures to increase the energy efficiency of the UK housing stock, including through ambitious and innovative plans to retrofit every home by 2030. Waterwise believes that this programme should include water efficiency - if homes which have received a retrofitting visit are still wasting water then a clear opportunity will have been missed to promote and deliver adaptation of the UK housing stock.

14. Only a third of homes in England and Wales pay for the water they use according to how much they use - only a third are metered. The UK is almost alone in the European Union in not metering every home for water, and successive Water Ministers at Defra since 2005 have stated publicly that metering is the fairest way to pay for water. All stakeholders agree - subject to differences in commitment in terms of timescale, and the framework of protection for vulnerable groups which would need to be in place alongside such a move. The Walker Review was set up to advise government on how a move to full metering could be taken forward, but did not give a final date by which it would like to see this in its Interim Report. The Mayor of London, Boris Johnson, has in recent weeks committed to a water meter in every house in London by 2015, and every block of flats by 2020. Ofwat's draft determinations will provide for metering to move to levels of 47% by 2015, and 56% in areas of serious water stress. However, Waterwise would like to see a water meter in every home in England and Wales by 2020 (subject to the protections referred to above being in place), and to this end would like to see a clear political commitment from the government to full metering in that timescale, which we believe the water industry would then deliver.

15. Social housing retrofitting projects which Waterwise has carried out in partnership with water companies, social housing providers and others, have shown significant water savings, with a positive cost-benefit attached. They have also resulted in social benefits - for example the installation of showers in homes which had only ever had baths. The Decent Homes standard does not currently require showers - Waterwise would like to see water efficiency included in the updated Decent Homes standard, including the installation of showers that are both water-efficient and energy-efficient.

16. Water neutrality requires water efficiency retrofitting measures in schools, hospitals and businesses in the same area as new housing development, so total water demand does not increase. Water neutrality is beginning to be taken forward as a concept in the UK, and the government has committed in part to applying it in some of the growth housing areas in water-stressed areas. Waterwise would like to see water neutrality applied as a standard planning tool across the country, including beyond areas which are currently designated as "water-stressed" - as there is no guarantee that areas not currently water-stressed will remain so in future.

17. Both Ofwat and the water companies have made considerable strides towards large-scale water efficiency in recent years, and the draft determinations for PR09 published in July 2009 included funding for 6 enhanced water efficiency programmes, which Waterwise welcomes. Five years ago a handful of water companies were carrying out water efficiency retrofit projects of more than 500 homes: now many of them have plans to retrofit ten thousand homes in each of the next five years. However, the investment in these programmes is still a drop in the ocean compared to that in large-scale supply-side projects such as reservoirs and desalination plants, which in themselves are vulnerable to climate change. This is to a large extent because the regulatory framework surrounding the water industry is still biased towards capital expenditure, which counts against water efficiency. This year, the Cave and Walker Reviews (on Competition and innovation in water markets, and Charging for household water and sewerage services , respectively) and the recent EFRA Select Committee report on Ofwat's 2009 Price Review have recommended a refocusing of this regulatory framework, to put resource efficiency at its centre. Waterwise fully supports this, which would significantly improve the prospects for robust Adaptation Reports from Ofwat and the water companies, and of the national Adaptation Programme as a whole.

Water efficiency in business - and the Adaptation Reporting Power

18. Organisations could save 40% of their water use through simple measures such as fixing leaks (after identifying these through meters) and switching to technologies such as urinals, toilets, taps and showers which use considerably less water. It is not unheard of for a disconnected pipe or forgotten dripping (or fully on) shower to be wasting huge amounts of water. Making the processes (industrial and manufacturing, and "domestic", such as cooking, cleaning and toilet facilities in workplaces) of an organisation more water-efficient would also save money on water bills. Water audits carried out as part of a wider water-use strategy should be one of the first steps an organisation should take in its adaptation plans. We would like to see this specified in the directions for the Adaptation Reporting Power, for inclusion in the Reports. We also propose a revolving, spend-to-save fund to help businesses waste less water.

19. Several of the major energy sources in the UK's future low-carbon energy mix rely greatly on water availability - namely, nuclear, and carbon capture and storage. This needs to be factored into the Adaptation Reports from those sectors.

20. Waterwise agrees that food, schools and housing should all be invited to report. The food sector is extremely reliant on water availability, and water efficient practices are not yet embedded in the supply chain - although the food industry does now have a collective water efficiency target. Schools and housing are two sectors in which wasting less water, through easy fixes, in partnership with water companies and others, could ensure adaptation was carried out in the most efficient way.

Driving the market in water efficient products

21. Waterwise works closely with retailers (such as B&Q) and manufacturers (such as Procter and Gamble - Ariel) to drive water efficient behaviour and purchasing decisions. We award the Waterwise marque to water-efficient products, and have worked with the Bathroom Manufacturers Association on the development of their water efficiency label. However, as recent Select Committee reports have pointed out, and the Walker Review's Interim Report also identifies, there is a need for a single source of information - Walker recommends that government work with Waterwise and others to review the existing water efficiency labels and consider and develop the case for a mandatory, cross-sector label. Waterwise is already working to this end with the relevant sectors. We would like to see a government commitment to the Walker Review's interim recommendation. In addition, to drive the market in water efficient products, we would like to see fiscal incentives on water-efficient products (these are being pursued at EU level by the UK for energy-efficient products, but not water-efficient ones). Finally, there is a clear need for strict water-efficiency products standards beyond those which exist for toilets, across other ranges such as taps, showers, washing machines and dishwashers, with these standards being regularly reviewed. These could be developed and put in place by government, working with NGOs, retailers and manufacturers - some of whom are already developing their own water efficiency product standards.

Water efficiency opportunities in government mitigation strategies

22. Government policies, strategies, targets and funds to develop the low-carbon economy tend not to include water efficiency. Water efficiency could represent a significant sector in the low-carbon economy - through developing both skilled jobs in the services sector (for example to support the government scheme to retrofit every home by 2030, if this included energy and water efficiency), and the UK manufacturing base in water-efficient products. We recommend that the ACC programme undertake an audit of government mitigation policies, including those to develop the low-carbon economy, in the context of the potential contribution of water efficiency - this will help meet both mitigation and adaptation needs.

Water efficiency in government departments

23. We note that the adaptation plans of some government departments are more advanced than others, and we accept the reasons given for this. However, we are concerned to see that some departments consider only the flooding risks relating to adaptation, with no regard to water scarcity, which could have a major impact on all government (and economic) processes and programmes. We would like Defra to require all government departments' adaptation strategies to include a water audit and water efficiency strategy - we are certain that this would lead to significant water (and cost) savings in every department. Such a programme would include the updating of service contracts as our work with some government departments has illustrated that in some cases a service contract can sit in the way of water efficiency. We also note the significant potential of government procurement in driving the market in water-efficient products, and we would like to see mandatory government procurement standards which reflect the best-available technologies (not the average) currently available on the UK market, with these being regularly reviewed and updated. We also propose a revolving, spend-to-save fund to help public sector buildings waste less water.

24. We note in the NAO report for the Select Committee the observation that partnership working will be essential in meeting adaptation goals. Waterwise believes that partnership working can deliver the best cost-benefit result in terms of retrofitting and policy development. We would like to see greater inclusion of NGOs in the development of adaptation policies and programmes. We also agree that the development of local and regional adaptation plans is essential, and welcome the emphasis on this in the ACC's work.

Building the evidence base

25. We note that two of the key elements of the ACC's work are to "develop a more robust and comprehensive evidence base about the impacts and consequences of climate change on the UK", and "additional "adaptation economic analysis" to improve understanding of the costs and benefits of adaptation measures; to give an overall indication of the scale of the challenge; and to help identify priority areas for action". Waterwise produced (in October 2008), for the UK Environment Minister's Water Saving Group (on which we were the only NGO to sit, alongside the water industry, its regulators, the Consumer Council for Water, and CLG), the Evidence Base for Large-scale Water Efficiency in Homes. This economic analysis drew together for the first time around 20 large-scale water efficiency programmes being undertaken by UK water companies, producing cost-benefit analysis for individual water efficiency measures on a large scale, and for scenarios for delivering them (for example in partnership with an energy company). The Evidence Base was warmly welcomed by the Water Saving Group, which requested that it be kept updated. The Evidence Base has been used by water companies and regulators during the 2009 Price Review and the Water Resource Management Plan process. It is currently being updated and improved, with the inclusion of additional, larger projects, and the attachment of carbon values to individual water efficiency measures. The Evidence Base will be highly relevant to the ACC's work.

3 October 2009