Written evidence submitted by Water UK
EXECUTIVE SUMMARY
1. Water UK represents all UK water and wastewater
suppliers at national and European level. We provide a positive
framework for the industry to engage with government, regulators,
other organisations and the public.
2. Water UK is delighted to give evidence to the
Efra Select Committee on Defra's consultation on the draft National
Policy Statement on Waste Water. We have focussed on Part 2 and
have responded to the questions as set out in the consultation
document.
3. Overall, Water UK believes the draft NPS has considerable
merit, however, there are some areas of concern. For example:
— We
believe the assumptions made about the benefits of the alternatives
to large scale waste water treatment are overly optimistic and
not supported by the evidence base.
— There
is a risk that the criteria for "good design", as set
out in 5.5, may compromise the vital requirements of functionality,
accessibility and safe operation, and disproportionately increase
customer costs.
— Meeting
the odour impact exposure standard, as laid out in 6.3.7, is likely
to be disproportionate to the benefit.
— The
draft Waste Water National Policy Statement does not recognise
that the cost of waste water infrastructure development falls
directly on customers. The IPC should be required to give consideration
to the impact of infrastructure development on customer bills.
WATER UK'S
EVIDENCE ON
DEFRA'S CONSULTATION
ON THE
NATIONAL POLICYSSTATEMENT
ON WASTE
WATER
We have used the structure of the questions as set
out in the Consultation Document pp 16-18.
Question 6.1: Do you think this draft Waste Water
NPS clearly establishes the need for such infrastructure for those
considering nationally significant projects in this area?
The draft waste water NPS recognises the importance
of waste water treatment infrastructure for public health and
the environment. It clearly sets out the key drivers for investment
in new and improved infrastructure. The statements of government's
policy objectives help clarify the national strategy relating
to waste water. However, it lacks a clear statement of the regulatory
imperative that is almost always the principal driver for such
projects.
Question 6.2: Do you think the draft Waste Water
NPS adequately sets out for the Infrastructure Planning Commission
the key assessment principles to inform the assessment of future
waste water development applications?
The draft Waste Water NPS contains a lot of useful
policy content. Existing national policy
does not provide support for the benefits that new wastewater
infrastructure brings. In considering individual projects, the
focus is often on short term construction impacts rather than
the permanent benefits.
Question 6.3: Do you think the draft Waste Water
NPS adequately sets out for the Infrastructure Planning Commission
on how they should consider alternatives when it comes to particular
projects?
The assumptions made in the benefits from the
alternatives in section 2.4, pertaining to alternatives to new
large scale waste water capacity, are overly optimistic and are
not supported by an evidence base.
For example it is assumed in 2.4.2 that a reduction
in household water consumption could lead to a reduction in flow
discharged to the sewerage system of 10%. Sewerage companies think
this unlikely.
Similarly, the use of Sustainable Drainage and separate
sewer systems, which the industry fully supports, will take a
long time to become the de-facto system in common operation. We
welcome recognition in 2.4.12 that upgrading existing drainage
systems to current standards is unlikely to be cost beneficial.
We support the conclusion in 2.4.4 on cost incentives
for trade effluent, but consider the need for new waste water
infrastructure will continue in most circumstances.
Question 6.4: Do you think the draft Waste Water
NPS gives appropriate guidance to decision makers on how they
should assess the need to consider "Good Design" for
waste water infrastructure?
Waste water infrastructure is not inherently attractive
and its design reflects its functionality, accessibility and safe
operation. Good design will seek to maximise the use of existing
infrastructure and avoid the need for unnecessary pumping. Therefore,
locations for siting new infrastructure can be limited when sustainability
issues are properly considered.
There is a risk that a requirement for good aesthetic
and functional design may compromise these requirements and increase
costs to customers disproportionately.
We support the requirement in paragraph 5.5.4 for
the IPC to take account of the ultimate purpose of the infrastructure.
We suggest it should also consider the cost benefit of design
requirements and customers' willingness to pay.
We have concerns with the requirement in paragraph
6.4.22 for essential wastewater infrastructure [that has to be
located in flood risk areas] to remain operational when floods
occur. This appears to be a misinterpretation
of Planning Policy Statement 25.
The physical nature of wastewater collection and
treatment leads to the low lying location of many wastewater treatment
works and Pumping Stations. In addition, the conveyance systems
are in open communication, making it unrealistic that they remain
fully operational during flooding events. Such a requirement would
have significant cost implications that would outweigh resulting
benefits.
We consider it to be more important for operations
to commence as soon as possible after flooding has subsided. Therefore,
it is suggested that this policy should be changed to "….be
designed to be resilient to the effects of flooding."
Question 6.5: It is a requirement of the Planning
Act that an NPS must include an explanation of how the policy
set out in the statement takes account of Government policy relating
to the mitigation of, and adaptation to, climate change. Do you
think the draft Waste Water NPS adequately fulfils this requirement?
Yes, section 5.6 provides comprehensive guidance
on the need to consider climate change and adaptation measures
for new infrastructure. However, in some cases it will be very
difficult to reinstate, restore or enhance biodiversity on a site
following construction. Other nearby habitats might be separate
from the construction scheme but offer better potential.
Question 6.6: Have all the potential environmental
impacts of waste water development, and options for their mitigation,
been identified in the Assessment Principles and Generic Impacts
chapter of the draft Waste Water National Policy Statement?
They have, but we challenge the standards proposed
in Section 6 Generic Impacts. In paragraph 6.3.7 an odour standard
of 1.5 ou/m3 is proposed. The cost of meeting this
standard is likely to be disproportional to the benefit. We
suggest the standard to be adopted should be open to discussion
and based on cost benefit analysis and customers' willingness
to pay.
In most cases a standard of 1.5 ouE.m-3
could only be achieved by locating works remotely from sensitive
receptors, or by process enclosure and odour treatment. Our experience
shows that enclosure causes significant operational difficulties,
and the associated costs are disproportionate to the benefits.
There are five reasons for our concern with this
section of the policy:
— The
H4 guidance is still draft. The industry has made representations
on the guidance and further consultation will be required before
it is approved in final form.
— The
draft H4 guidance is for Environmental Permitting and only applies
to certain sludge treatment facilities, not effluent treatment
plant where odour levels are significantly lower.
— The
proposal standard contradicts Defra's Odour Guidance for Local
Authorities.
— Additional
costs would have to be sought with the agreement of Ofwat.
— If
funding is approved by Ofwat, there remain concerns about the
operational capability of treating effluent within closed spaces.
We would therefore advocate an approach that assesses
projects against a range of odour standards, agreed on a case-by-case
basis, taking into consideration relevant industry guidance, practicability
and effectiveness.
Question 6.7: Do you think the draft Waste Water
National Policy Statement considers all the significant potential
impacts of waste water development? If not, what do you think
is missing and why?
The draft Waste Water National Policy Statement
does not recognise that the cost of waste water infrastructure
development falls directly on customers. The IPC should be required
to give consideration to the impact of infrastructure development
on customer bills and whether customers support any increase in
bills that result from its delivery.
Question 6.8: Do you think that the two schemes
outlined by the draft Waste Water National Policy Statement capture
the level of need for nationally significant infrastructure in
this area? If not, what further schemes should be included?
Some companies feel the concept of establishing a
threshold for national significant infrastructure by population
equivalent may exclude infrastructure development of national
significance that falls below the threshold although we understand
the Secretary of State will have the power to call in certain
developments.
However, others believe the planning system has effectively
delivered many schemes of this nature without delay. There is
a danger that the IPC could unnecessarily slow down important
projects.
In general terms, if these projects have been determined
as Nationally Significant then the applicant needs to demonstrate
an awareness of the issues and undertake a reasonable or acceptable
level of mitigation, but the IPC and other regulatory bodies
need to recognise there are other legal drivers necessitating
the construction of these projects within a particular timescale.
QUESTIONS POSED
BY THE
EFRA SELECT
COMMITTEE
2. Do the general planning principles set out
in the proposed Waste Water NPS form a coherent, appropriate,
proportionate and practical framework within which the Infrastructure
Planning Commission and other planners can assess future waste
water infrastructure planning applications?
Overall they do. However the industry would like
the IPC or other planning authorities to be subject to a requirement
to consider cost benefit or the impact on customer bills.
January 2011
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