Written evidence submitted by Yorkshire
Water
EXECUTIVE SUMMARY
1.1 We welcome and support the Flood and
Water Management Act which brings clarity and promotes the multi-agency
approach.
1.2 We welcome the conclusions of the Walker
Review, particularly around social tariffs and information sharing.
1.3 We welcome the conclusions of the Cave
Review and feel innovation is the best way to ensure great customer
service and keep water bills low.
2.1 We support an integrated approach to
flood and water management.
2.2 We propose allowing the water industry
to take over the ownership and management of flood defences.
3.1 We suggest that water companies have
an even greater role to play in surface water management.
3.2 We propose that water companies should
own and manage SUDS.
3.3 We propose a redrafting of the clause
on designation of features to ensure the original intention of
the clause is achieved.
3.4 We urge further consideration on changes
to the Reservoir Act 1975.
1. Which 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?
1.1 Integrated approach to flood and water management
We welcome and support the Flood and Water Management
Act as a means of recognising and joining up the many different
agencies involved in water and flood management. Since the floods
of 2007 we have played an active role in developing a multi-agency
approach to water management planning and flood emergency response
in partnership with regional local authorities and with the Environment
Agency in our region. We feel the multi-agency model is the best
way to deliver improved flood protection and management for the
future and we would welcome this being taken forward as a legislative
priority.
1.2 Walker Review
We welcome the conclusions of the Walker Review
and believe that there should be an enhanced focus on protecting
vulnerable customers. As recommended by the Walker Review, we
would support the introductions of new social tariffs to support
vulnerable customers. We also agree that there should be better
sharing of information between government agencies and water companies
about customers at risk so early support can be provided.
1.3 Cave Review
We welcome the conclusions reached by the Cave
Review team. We feel that innovation is the best way to ensure
that companies can deliver continued lower costs and enhanced
customer service. We would like to see greater incentives for
companies to push the boundaries of innovation. We would also
like to see further discussion on the Review's recommendations
regarding negotiated settlements as we believe that it is important
that customers' voices are heard.
2. Which further policies are required to
ensure flood and water management which delivers optimum social,
economic and environmental outcomes?
2.1 We believe that there should be an integrated
approach to flood and water management. A holistic understanding
of the system would better equip us to deal with the impacts of
climate change. Examples of this could be as follows:
2.2 Taking an integrated approach to flood defence
We believe that flood risk would be better managed
and mitigated if one agency had overall responsibility for managing
this activity. This would facilitate more coherent flood management
approach. The opportunity to access private capital to support
flood defence investment should also be explored as this would
release public sector resources to be spent in other priority
areas.
3. Our comments on further issues related
to the Flood and Water Management Act 2010
3.1 We welcome the Flood and Water Management
Act which creates clearer roles and responsibilities in flood
risk management. However, we feel that water companies have an
even greater role to play in surface water management. We feel
that opportunities have been missed to give water companies greater
responsibilities that would ensure that we have a complete understanding
and control of our networks.
3.2 Ownership of SUDS
We propose that water companies should own and
manage SUDS. Owning, maintaining and operating drainage assets
is a core activity for water and sewerage companies, who are also
able to recover the associated costs through sewerage bills. Indeed
it is counter intuitive to transfer responsibility for private
sewers to water companies whilst at the same time creating new
drainage responsibilities for local authorities.
SUDS will be a key part of an integrated drainage
system and after the private/public transfer takes place there
may be situations where sections of public sewer are interspersed
with sections of SUDS on the same length of public sewer which
cannot be an effective use of resources or allow effective management
of the system as a whole. We feel that it would make sense for
this system of assets to be operated together in order to maximise
the potential for synergy, cost saving and operational effectiveness.
A holistic understanding of the drainage system would better equip
water companies to combat sewer flooding. It would also help our
customers who are often left bewildered by the different agencies
involved in flood and water management all with different responsibilities.
Given the current programme of Government spending
cuts and concerns raised by local authorities, it would seem logical
to give this responsibility to water companies thus relieving
the public burden.
3.3 Designation of features
In the EFRA Committee's report on the draft
Bill, the Committee noted concern "that bodies that would
be able to designate `things' appear unsure about their scope
or scale. The purpose of the provisions is not in question but
there needs to be greater clarity about what could be designated,
how the designating authorities would coordinate with one another
and how differences of opinion between designating authorities
would be resolved." We echo this concern and would advise
that the powers are too wide.
Under the current Act there is the possibility
of an entire sewerage system being designated which would have
the potential effect of transferring the operational control of
that system to a third party, which cannot be what the provision
was designed to achieve. Schedule 1 means that once designated
a structure cannot be altered, removed or replaced without the
consent of the designating authority. There should be greater
clarity around the objectives of designation and powers designed
to meet these objectives. The specific exclusion of assets within
the ownership/control of statutory water & sewerage undertakers
from designations would be beneficial.
3.4 Changes to the Reservoir Act 1975
Whilst changes to the Reservoir Act 1975 are
welcomed there should be very careful consideration about how
and over what timescale they should be introduced given the resources
available in terms of qualified reservoir engineers to be able
to implement the changes and to maintain current high standards.
4. In summary
Our proposals reflect our objective to serve
our communities, improve our environment and deliver these changes
at prices which customers can afford. We feel we could play an
even greater role in the delivery of services which our community
values
Thank you for the opportunity to contribute
once again to this debate. We would be happy to provide further
information if required.
6 October 2010
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