Written evidence submitted by The Chartered
Institution of Water and Environmental Management (CIWEM)
The Chartered Institution of Water and Environmental
Management (CIWEM) is the leading professional body for the people
who plan, protect and care for the environment and its resources,
providing educational opportunities, independent information to
the public and advice to government. Members in 96 countries include
scientists, engineers, consultants, civil servants, local authority
workers and academics.
EXECUTIVE SUMMARY
1. CIWEM welcomes the opportunity to comment
on the EFRA Committee inquiry into future floods and water management
legislation. CIWEM believe that learned bodies like ours must
be engaged in the development of such legislation. We believe
that the legislation in the Floods and Water Management Act is
adequate and we are supportive of many of the measures, but we
have concerns that funding will not be made available for local
authorities to carry out the new duties placed upon them. CIWEM
believes that more integration of the activities of the planners,
regulators, operators and utility providers is needed to achieve
sustainable water management.
2. Legislation on market reform and water
charging are likely to be considered as part of the Water White
Paper and a subsequent Water Bill. We would hope to see a blend
of legislative, policy, regulatory and market mechanisms in the
future to set the platform for the delivery of effective and efficient
water, sewerage and environmental services with sufficient freedom
and incentives to encourage the development and uptake of new
ways of working. In particular CIWEM supports the principle of
near universal metering, smart metering, carbon reduction targets
for the industry and a national education campaign to improve
demand management.
Which of the key issues covered by the consultation
into the draft Flood and Water Management Bill and by the Walker
and Cave reviews should be taken forward as legislative priorities
3. CIWEM considers that the legislation
in the Flood and Water Management Act is sufficient and further
legislation can potentially be linked to the forthcoming Water
White Paper and a subsequent Water Bill. We do feel that there
are certain areas where there could be further integrated management
of the water cycle but the measures we are particularly supportive
of within the Flood and Water Management Act are local authority
responsibility, SUDS, partnership working and streamlining organisational
responsibilities. CIWEM hopes that there will be streamlining
of processes rather than the creation of more links between various
organisations all playing a small part in every process.
4. CIWEM endorses the increase in responsibility
for upper tier/unitary local authorities. The importance of local
expertise in the context of effective flood risk management cannot
be underestimated and this increased responsibility reflects such
importance. We believe that local authorities should be legally
required to produce annual reports on the way they are managing
local flood risk. Our primary concern lies in the provision of
sufficient funding for local authorities who have new duties.
Many local authorities appear to be delaying recruitment in flood
and coastal risk management until funding is allocated. This will
prove to be counterproductive and leave them with a skills shortage.
Sufficient funding and capacity building to support local delivery
and decision making is needed to ensure that local authorities
can act as an "intelligent client" when dealing with
their supply chain. The Act provides a significant opportunity
to deliver better-integrated environmental management given adequate
support, guidance and funding.
5. The recommendations of the Cave and Walker
Reviews can be embedded into the 2011 Water White Paper. CIWEM
considers that there needs to be a focus on near universal metering
and for water to be included as part of efforts towards multi-utility
metering which at present appears to be discounted.
6. CIWEM supports the Walker Review's recommendation
that a national education campaign on water efficiency is needed.
We believe that more needs to be done to educate and encourage
the public in order to reduce water demand and increase acceptance
for water charges that reflect the cost of their provision particularly
when water is scarce and demand is high.
7. We consider that carbon reduction targets
are needed for the water industry to ensure that the financial
regulator allows companies greater revenues to cover these costs.
For example if a regulatory target is set for metering and other
demand management measures then the companies' revenues would
be protected against such investment. Some water companies had
their meter installation programmes cut back by OFWAT at PR09
in the absence of such targets.
8. Barriers to joint working between energy
and water companies need to be removed within the framework of
the Carbon Emissions Reduction Target (CERT) and the Water Efficiency
Targets (WET) and any successor. As heating water contributes
to 89% of energy use in the home, emission reduction targets can
be met cost-effectively through water and energy efficiency measures
working in tandem, through the use of flow restrictors for example.
Under the current framework of CERT and WET set by OFWAT, water
and energy companies cannot claim the credits for the energy savings
from the same device. This regulatory mechanism was designed to
stop double-counting carbon savings but actually works to preclude
a joined-up approach. If the barriers were removed water companies
could claim energy reduction credits which would incentivise demand
management.
9. Whilst the Cave review concluded that
market forces may provide a tool for managing water in the future,
the choice should not be between markets and regulation, but ensuring
that the two can work in mutual support with aligned objectives
to deliver sustainable outcomes.
10. CIWEM believes that the full value of
water needs to be established, communicated to and accepted by
customers as soon as possible, to support the introduction of
market-based instruments. Until the true value of water is established
and communicated, demand management measures will continue to
be under-valued and under-used.
Which further policies which are required to ensure
flood and water management which delivers optimum social, economic
and environmental outcomes
11. The policies in place are generally
suitable if they are effectively delivered and if there is integration
with other environmental legislation such as the Water Framework
Directive and Urban Waste Water Treatment Directive. This is often
not the case and there is a lack of joined up policy. We consider
that the primacy of the Water Framework Directive in melding water
regulation and management in its widest terminology needs to be
established. Effective implementation of the Directive will require
improvements in engagement, policies and governance. There is
also a need to consider, by all parties the issues of the interaction
of surface water, fluvial, groundwater, piped network and coastal
flooding mechanisms.
12. The Flood and Water Management Act does
not address the bigger picture of the need for overarching legislation
to enable truly joined-up water and environmental management which
considers the whole water cycle. This wider consideration should
include the technical standards, environmental enhancement and
third party funding. CIWEM would hope to see a water industry
which is an integral part of wider water and environmental management
approaches which bring together land management, flood risk management,
water and drought management, planning and development. We hope
the Water White Paper will address this.
Any issues related to the Flood and Water Management
Act 2010 (including sustainable drainage systems (SUDS) and the
transfer of private sewers and lateral drains)
13. CIWEM would hope to see a presumption
for SUDS included within all new developments unless there are
compelling reasons otherwise. We would also wish to see further
retrofitting of SUDS to existing developments where feasible.
Surface water management is most effective when placed at the
heart of urban design. The retrofitting of measures to manage
risk in existing urban areas is especially challenging where little
potential remains for additional greenspace. Achievements have
been modest in terms of SUDS retrofit and stormwater quality control
in the UK; the US is significantly ahead.
14. Ideally, SUDS that require minimal maintenance
should be implemented. The Flood and Water Management Act deems
that where the SUDS Approving Body adopts a drainage system it
becomes responsible for maintaining the system. CIWEM believes
that the most appropriate organisation should take responsibility
for the funding and maintenance whether this is the developer,
utility company, highways agency or local authority.
15. Whilst SUDS control flow rates from
the source, the use of open channels rather than drains allows
for the storage and transfer of excess water in storm events.
We would like to see better integration and enhancement of natural
watercourses in development proposals. This is important because
SUDS alone cannot cope with the magnitude of flood flows seen
in 2007.
FURTHER INFORMATIONCIWEM
has recently published its vision "Regulation for a Sustainable
Water Industry" which calls for a wide reaching view of the
governance of the water industry. The full vision can be found
at:
http://www.ciwem.org/policy-and-international/current-topics/water-management/regulation-for-a-sustainable-water-industry.aspx
CIWEM responds to a range of public consultations.
Our responses to the Cave and Walker reviews and the draft Flood
and Water Management Bill can be found at:
http://www.ciwem.org/policy-and-international/consultation.aspx£
October 2010
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