Written evidence submitted by The Royal
Society for the Protection of Birds (RSPB)
EXECUTIVE SUMMARY
RSPB PRIORITIES FOR
LEGISLATIVE AND
POLICY REFORM
Reforms discussed in draft Flood and Water Management
Bill but not taken forward in Act
— Reform of Internal Drainage Board membership,
funding arrangements and duties.
— Introducing a new Water Framework Directive
duty on flood and coastal erosion operating authorities.
— Long term funding stream for Sustainable
Urban Drainage Systems.
Priority legislative and policy reforms from the
Walker and Cave Reviews
— Making Level 3 of the Code for Sustainable
Homes mandatory for all new homes.
— Banning non-water efficient products
from being sold on the UK market.
— Moving to universal payment by metering.
— Making the polluter pay for diffuse pollution,
not water customers.
— Removing the bias to capital expenditure
inherent in economic regulation of the industry.
— Introducing a water efficiency strategy
linked to existing/local campaigns.
— Moving to full environmental pricing
of water abstraction.
— Introducing measures to tackle unsustainable
abstraction.
Other policy priorities
— Making the £2billion/year of public
support received by farmers do more for resource protection.
— Adopting a local catchment scale approach
water quality, water resource and flood risk management to encourage
partnership in water management.
— Introducing planning policies that require
all new housing to be "water neutral".
— Requiring public sector procurement to
specify highly water-efficient goods and services.
— Removing the statutory limit on fines
for pollution.
— Introducing new measures to control pesticide
pollution should including statutory safeguard zones and catchment
based approvals for high risk pesticides.
— Designating Waters at high risk from
diffuse pollution as candidate Water Protection Zones and
introduce regulatory controls if voluntary action fails to meet
required standards.
— Prioritising all spending on flood risk
management works (capital and maintenance) on the basis of need
and demonstrable benefit.
— Strengthening planning safeguards for
floodplain and riparian land.
— Requiring flood risk management authorities
protect peat soils from damage caused by flood defence and land
drainage works.
PRIORITY LEGISLATIVE
REFORMS DISCUSSED
IN DRAFT
FLOOD AND
WATER MANAGEMENT
BILL NOT
TAKEN FORWARD
IN ACT:
1. Reform of Internal Drainage Boards: The
RSPB recognises the value of local knowledge and expertise in
water level management however, we believe the reform of IDBs
is long overdue. Our priorities for action are:
— Introducing a sustainability duty on
water level management activities to match that for flood risk
management works.
— Changing membership rules to better reflect
Local Authority and environmental interests.
— Removing CLG's support for Special Levy
and replace it with a competitive, risk-based funding allocation
that ensures taxpayers' money is being spent where need is greatest.
— Reconstituting IDBs as Water Level
Management Boards to better reflect the role they play in
delivering water levels for a range of benefits, not just drainage.
2. Placing a new Water Framework Directive
Duty on flood and coastal erosion operating authorities. The draft
consultation bill contained a proposal to place a duty on the
EA to have regard to the WFD in its national strategy. Although
the proposed wording was very weak, the principle is important
because flood authorities are uniquely placed to enhance the physical
quality of the aquatic environment through the works they undertake.
As such the RSPB recommend links with the WFD are re-captured
in a more imaginative way that recognises the potential for operating
authorities to enhance the status of water bodies.
3. Provide a long term funding stream for
Sustainable Urban Drainage Systems.
LEGISLATIVE PRIORITIES
FROM THE
WALKER REVIEW
4. Making Level 3 of the Code for Sustainable
Homes mandatory for all new homes.
5. Banning non-water efficient products
being sold on the UK market to encourage the use of more water
efficient fittings and appliances.
6. A swift and fair move to metering. The
Walker Review recommends metering as the fairest approach to charging
where water is scarce, for high discretionary users, and on change
of occupancy. It also concluded that legislation would be needed
to compel water companies to adopt systematic metering where certain
criteria are met and that this would lead to 80% metering by 2020.
The RSPB believes Government policy should go further and require
full compulsory water metering in England and Wales by 2020, with
tariffs that protect vulnerable customers, deter waste and reflect
environmental impact
POLICY PRIORITIES
FROM THE
WALKER REVIEW
7. Tackle diffuse pollution. Although the
Walker review focussed on the water industry it did recognise
that diffuse pollution has a serious impact on water quality and
customer bills, recommending "… governments should
do all they can to ensure the clean-up of diffuse pollution is
paid for by the polluter, not the water customer". Little
has changed since the report was published with the National Audit
Office's report Tackling diffuse water pollution in England
concluding "The Environment Agency's annual expenditure
of £8 million has had little impact in reducing diffuse pollution…".
The RSPB believes Government needs to ensure both better targeting
of voluntary/incentive driven schemes and better enforcement of
existing regulation such as cross compliance.
8. Removing the current bias to capital
expenditure: The Walker Review highlights the inherent problem
associated with economic regulation creating a bias towards capital
investment eg fixed assets such as treatment works rather than
items of operational expenditure such as water metering. While
the solutions suggested by Walker would help incentivise investment
in metering they do not address the fundamental problem and as
a result, would do little to encourage cost-effective and more
sustainable alternatives to capital investment elsewhere in the
industry eg catchment management.
9. A Government led water efficiency strategy
linking with existing/local campaigns. The RSPB fully support
Anna Walker's recommendation that The UK Government and Welsh
Assembly Government should promote a national education strategy
working with stakeholders to influence public behaviour on water
use,… and would welcome the opportunity to participate with
national and local campaigns as appropriate.
10. Government should explicitly link activities
on water and energy efficiency. The Walker Review contains a number
of recommendations that would reinforce the link between energy
and water saving measures. The RSPB sees these as easy wins in
terms of economic efficiency and householder acceptability.
LEGISLATIVE PRIORITIES
FROM THE
CAVE REVIEW
11. Introducing full environmental pricing
of water. As the Cave review pointed out "[Abstraction] Charges
are limited to cost recovery and are relatively crude. ….
it fails to ensure that water goes to those who value it most
(including the environment) or that it is used efficiently".
12. Tackling unsustainable abstraction:
The Cave Review identified the need to tackle unsustainable abstraction
as a precursor to licence trading. While the Cave review suggests
a number of approaches to incentiviiing change the RSPB believe
this would require radical reform of abstraction licensing law:
— Assessing and protecting environmental
water requirements.
— Moving all permanent licences to a time-limited
basis.
— Applying flow related restrictions to
all abstractions.
— Amending or revoking unused portions
of licences that could cause environmental damage if exploited.
OTHER POLICY
PRIORITIES FOR
WATER
13. Making the £2billion/year of taxpayer
support received by farmers do more for resource protection. This
could be achieved by including more effective resource protection
measures in Cross Compliance requirements and/or use National
Envelope rules to shift money from Single Farm Payment into
incentive schemes targeted on specific problems. This has the
potential to free up £160-200 million per year at no net
cost to the exchequer.
14. Adopting a local catchment scale approach
water quality, water resource and flood risk management to encourage
partnership in water management.
15. Planning policy should require all new
housing to be "water neutral" with developers offsetting
demand through efficiencies elsewhere. Building in water-stressed
areas should only be permitted if developers contribute to an
overall reduction in demand through efficiency savings.
16. Public sector procurement should be
required to specify highly water-efficient goods and services.
17. The statutory limit on fines for pollution
should be removed and guidance provided to magistrates to ensure
fines to take account of the damage caused.
18. New measures to control pesticide pollution
should be introduced, including statutory safeguard zones.
19. Waters at high risk from diffuse pollution
should be designated as candidate Water Protection Zones and regulatory
controls introduced if voluntary action fails to meet required
standards by 2015.
20. Spending on flood risk management works
(capital and maintenance) should be prioritised on the basis of
need and demonstrable benefit.
21. Planning policy designed to safeguard
floodplains and riparian land should be strengthened.
22. Flood risk management authorities should
be required to protect peat soils from damage caused by flood
defence and land drainage works.
October 2010
| 
