Memorandum submitted by Waterwise
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 six 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 10,000 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
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