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Memorandum submitted by Water UK (ACC08)
Summary
1. Our key comments are concerned with: a. The crucial role of water at the forefront of dealing with the impacts of climate change b. The need for clarity and consistency in cross-government and regulatory support for adaptation measures c. The uncertain impacts of climate change, which should be openly acknowledged and addressed, and not used as an excuse for inaction/delay d. The importance of working in partnership across sectors to manage the impacts of climate change most effectively e. The synergies between adaptation and mitigation and the need to ensure that adaptive measures are consistent with national greenhouse gas reduction targets f. Reporting frameworks for adaptation, which should be aligned and consistent with requirements by government and regulators in other areas. g. The protection of critical national infrastructure, which may not always be cost beneficial using existing accounting assessments
Introduction
2. Water
3. We have been encouraged by the lead
that the
4. Our members are active in all the regional climate change partnerships where they seek to engage and share knowledge and responses to climate change with other stakeholders.
Impacts of climate change on water
5. Water is where many of the impacts of climate change will be felt first and most acutely. It is imperative that we get it right in our sector, because every other sector of the economy is dependent on the services we provide. This puts the water industry at the forefront of adapting to a changing climate.
6. Climate change will impact all areas of the water industry. For example: · Water availability will be affected by changing weather patterns and we will need to build additional infrastructure, for example winter storage capacity. · Demand for water is likely to increase · Reservoirs will be impacted in terms of operation, quantity, quality and structure · Pipe systems for both drinking water supply and sewerage will be more prone to cracking as climate changes lead to greater soil movement, as a consequence of wetting and drying cycles. · Colour and odour problems will result from higher temperatures and more intense rainfall events · Assets on the coast or in flood plains (that covers most of them) will be at increased risk from flooding, storm damage, coastal erosion and a rise in sea level. · Dams will be more prone to siltation resulting from increased soil erosion, and the slippage risk to soil dams from intense rainfall events is also increased. · Existing sewerage systems were not designed to take climate change into account. This means that more intense rainfall is likely to exceed the capacity of parts of the network and cause local flooding. · Lower river flows and reduce the dilution of wastewater effluent. We may need additional treatment to meet higher standards which are likely to be achievable only by using energy- intensive processes with all that means for greenhouse gas emissions.
7. Continued adaptation is essential to maintain high, reliable levels of service. It is not a once only activity. Water companies have a wealth of experience in planning for climate change and have for many years been working to embed the effects into long-term plans, based on the best available evidence and extensive research.[2]
8. Water
9. Water
10. Given the nature of the impacts on water, it is crucial that all policies and measures around adaptation take full account of the role of the water sector.
Supporting adaptation in water
11. Adaptation to climate change is a key component of both water company
Strategic Business Plans and Water Resource Management Plans. Indeed, there is a statutory duty for companies to consider the
effects of climate change on supply of and demand for water. These plans are produced every
five years and (in
12. In addition, water companies in
13. Generally, measures proposed and incorporated into company plans are within the remit of water companies. These include changes to infrastructure but also less tangible measures such as water efficiency. However, they require regulatory support and approval.
14. A key concern for the industry relates to the lack of support for adaptation measures and the conflicting expectations and requirements. For example, despite the strong lead from government and explicit guidance from the EA, Ofwat has not allowed any climate change driven investment related to water resources for the period 2010-15, because the "evidence available to companies when they prepared their final business plans was out of date".[4] In these circumstances, programmes and policies proposed in a water company's plan may never come to fruition, unless the implementation of those programmes and policies becomes a statutory obligation.
15. Clearly, a supportive regulatory framework is crucial in a heavily regulated industry. Whilst companies can identify the need for and propose actions to address climate change, they cannot be implemented without regulatory approval.
Dealing with uncertainty
16. There is a significant degree of uncertainty associated with the potential impacts of climate change, and many of the impacts are not expected to be fully noticeable until some way into the future. This has led to suggestions that we should wait until the science is more certain, or we should focus on more pressing issues where the economic benefits of action are clearer.
17. However, the impacts of climate change on water are already being felt. The water sector also has long-lived assets and long-term planning horizons. As a result, we need to plan for impacts up the end of the century, and potentially beyond. The recent UK Water Industry Research report, Climate Change - A Programme of Research for the UK Water Industry, looks at risks and adaptation options to 2100.
18. The water industry is used to dealing with uncertainty. For climate change, it comes from a range of different areas, e.g. emissions pathways, modelling, impacts on precipitation and impacts on run-off. Information from UKCP09 is already allowing water companies to consider a broader range of uncertainty, providing a much richer picture than ever before.
Working in partnership
19. There are many areas where the water industry cannot deliver solutions to climate change alone, including diffuse pollution, surface water management, sustainable urban drainage, and the more efficient use of water. These require partnership working. We would suggest that the adaptation sub-committee of the Climate Change Committee has a key role to ensure that the interdependencies between organisations, agencies and government bodies are picked up and that these links form part of the national risk assessment.
20. For example, it is not possible or sustainable to separate decisions about land use planning from water management. The water industry owns and operates some surface water drainage systems, some of which are combined with foul water drainage systems. These systems are generally designed to drain areas of wastewater and surface water. However, our members have had little influence on land use in the catchment areas and this lack of control means that following periods of heavy rainfall, systems may be overwhelmed and result in flooding which may be very distressing for citizens particularly as flood water may be mixed with sewage. The reasons for this include increasing urbanisation, poor planning control, rising impermeable surface area, land use in the catchment, flood prevention schemes such as raising river banks and climate change. Together, these contribute to the pollution of watercourses and may impact on achieving 'good status' for the Water Framework Directive. Solutions to this problem include attenuating flows and reducing volume of rainwater entering combined sewer systems, better surface water management planning, overland flow routes, sustainable drainage and sacrificial areas for flooding.
21. The water industry is already working
with and helping to finance other sectors to implement catchment protection
measures, which deliver water quality outcomes as well as helping to adapt to
climate change. In fact, the
22. For water efficiency, this is dependent on behaviour and requires education and awareness, in addition to measures such as making existing buildings more water efficient and developing a clear water efficiency labelling system. Again, the industry has led the way by setting up Waterwise, an independent organization to promote water efficiency.
23. Adaptation measures must also be sustainable and measures taken by one sector should not undermine adaptation in another. Examples of this maladaptation are nitrate-intensive agricultural practices encouraged by Common Agricultural Policy incentives and the need for large quantities of water to support bioenergy crops.
Linking adaptation and mitigation
24. A key principle for the
25. There is no doubt that some existing EU Directives, whilst benefiting the water environment, have resulted in significantly higher emissions, primarily as a result of increased energy-intensive treatment. Concerted effort is needed by all sectors to reduce emissions, if the worst impacts of climate change are to be avoided. We would therefore expect all action at a European or national level to demonstrate how it has taken account of the recently revised Commission RIA guidelines. These state "it is important to identify environmental impacts where relevant, and then to place a monetary value on them. An example of an area where this can be done is for the release of a unit of carbon dioxide (or other greenhouse gases)." The use of these guidelines will help identify and deliver the most sustainable overall solutions.
26. This is likely to include innovative solutions such as catchment or seasonal consenting, diffuse pollution source controls, infrastructure charge rebates for developers who provide surface runoff reduction measures, etc.
27. More specifically, most local water quality issues have in the past been addressed through relatively expensive and energy-intensive end-of-pipe solutions. There is increasing evidence to suggest that controls introduced at source (for phosphates, nitrates, etc) could both reduce the amount of energy required to remove these from the aquatic environment and ensure our ecosystems are higher quality and more resilient to the impacts of climate change.
28. Positive links between adaptation and mitigation can be found in other areas. Using water more efficiently both reduce the amount of energy (and carbon) associated with abstracting, treating, distributing and heating[5] that water, and that also means that more water is available for the natural environment or other uses, enhancing our ability to cope with the impacts of climate change. So awareness, information, incentives and regulation to promote water efficiency is key.
29. Therefore, we need policy makers, regulators and others to recognize the links between adaptation and mitigation and to promote 'win win' policies that do not potentially increase emissions.
Reporting
30. Water companies will be covered by the new statutory reporting power on adaptation. Given that climate change is already embedded within existing systems in the water sector, we have suggested to Defra that water company adaptation reports largely consist of signposting to the relevant sections of business plans, water resource plans and other pertinent material. We have also suggested that, to reduce the burden on companies and ensure consistency, Water UK works with Defra to coordinate a standard reporting format for water companies that would meet the requirements of the new power and minimise the need for additional reporting.
31. We would also expect the government to explain clearly how potential conflicts involving the government and regulators will be resolved. For example, the reporting authority may not receive funding from the economic regulator to implement plans agreed by the Secretary of State. This situation has occurred recently with statutory water resources plans, where ministerial directions have conflicted with the determinations of the economic regulator.
32. Finally, we would suggest that the Committee reviews progress on the issues covered by this inquiry once the information from the adaptation reports under the new power are available.[6]
Protecting critical infrastructure
33. The water industry is responsible for a range of assets and infrastructure, including water and wastewater treatment works, many of which are located in areas vulnerable to flooding. Although the most critical assets are well-defended and regularly assessed for flood and other risks, the impacts of climate change and poor land use planning means that levels of protection may need to be revised in future. However, given the uncertain nature of potential climate change, the comparatively low probability of flood events and the high cost of additional protection, it is often difficult to make a strictly economic case for action using existing accounting assessments.
34. Indeed, a significant amount of expenditure related to resilience and reducing sewer flooding has been disallowed by Ofwat in the PR09 draft determination.
[1] A list of Water [2] Further information can be found at http://www.water.org.uk/home/policy/climate-change [3] A summary of this event is available at http://www.water.org.uk/home/news/press-releases/water-sector-launch-ukcp09 [4] Ofwat's draft determination did allow limited funding for the protection of prioritised strategic assets from flood inundation. [5] Defra has
estimated that the heating of water in the home (e.g. for baths/showers) is
responsible for around 5% of total [6] Water |